719.pdf
- Type
- pdf
- Source set
- house-oversight-doj
- Pages
- 8
- Text status
- Searchable text available
- OCR confidence
- 0.9380390845915627
Original source
Extracted text
Case 1:20-cr-00330-PAE Document 719 Filed 07/12/22 Page1of8 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca My 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] HADDON MORGAN FOREMAN December 13, 2021 VIA Email The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: — United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, Ms. Maxwell has disclosed to the government the December 19, 1996 Agreement for Sale of 44 Kinnerton Street London SW1. Gov. Letter Mot., Ex. A. The 1996 Agreement is impeachment evidence, the relevance of which Ms. Maxwell could not have known until Kate testified on direct examination that Ms. Maxwell lived in the Kinnerton Street home in 1994. The 1996 Agreement contradicts Kate’s testimony by proving that Ms. Maxwell did not purchase Kinnerton Street until 1996. Ms. Maxwell was not required to disclose the 1996 Agreement to the government until now. The government does not deny the authenticity or relevance of the 1996 Agreement. The 1996 Agreement shows that Ms. Maxwell contracted to purchase 44 Kinnerton Street in December 1996 and completed the sale in early 1997. The Kinnerton home is in the Belgravia neighborhood of London. Kate, by contrast, testified under oath that she visited Ms. Maxwell’s home on Kinnerton Street in 1994 when Kate was 17 years old. DOJ-OGR-00011333
Case 1:20-cr-00330-PAE Document 719 Filed 07/12/22 Page2of8 The Honorable Alison J. Nathan December 13, 2021 Page 2 Q. When you were approximately 17 years old, where were you living? A. I was living in England, London. Q. What neighborhood in London did you live? A. Belgravia. TR 12/6/2021, p 1172:2-6. She said: Q. And approximately what year were you 17 years old? A. God, I can’t do the math. So that was ’94. Q. Is that 1994? A. Yes. Id. at 1172:22-25. Then, after identifying a photo of Ms. Maxwell’s Kinnerton Street…
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