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Case 1:20-cr-00330-PAE Document 703 Filed 07/12/22 Page6éof7 Third, this failure to disclose has caused prejudice to the Government. The sale agreement is an isolated document with a handwritten date, and it PO ae. The Government should have an opportunity to investigate and obtain records from the United Kingdom regarding the defendant’s place of residence in the mid-1990s. That is a time-consuming international, intergovernmental process involving multiple agencies in each country that is not likely to generate admissible evidence by the conclusion of trial. And there is every reason for the Government to seek to investigate this document: the defendant has previously testified, under oath in a deposition, that she lived at the Kinnerton Street address beginning in 1992 or 1993. (See Exhibit B at 8). Such an investigation did not become necessary until the defendant sought to introduce a document in support of an apparent argument that, contrary to that testimony, the defendant lived elsewhere prior to the purchase of this home. Fourth, no remedy other than preclusion is appropriate. Insofar as the defendant waited until now to disclose the agreement, she “ran the risk that the exhibit would be excluded.” Napout, 2017 WL 6375729, at *8. Its introduction would prejudice the Government, and it should be so excluded. Finally, the agreement should be excluded under Rule 403. As explained above, the agreement runs the risk of “confusing the issues” and “misleading the jury” by presenting a document from which the jury is asked to infer conclusions that range far beyond the evidence. DOJ-OGR-00011211