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Case 1:20-cr-00330-PAE Document 719 Filed 07/12/22 Page1of8 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca oO 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com joagliuca@hmflaw.com 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