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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 home: Q. Kate, in what neighborhood was this townhouse? A. In the same neighborhood I lived in, in Belgravia. Id. at 1177:5-6. The 1996 Agreement proves that Kate’s testimony is not accurate. Confronted with proof that Kate did not tell the truth, the government asks this Court to preclude Ms. Maxwell from offering the 1996 Agreement into evidence on the theory that, because Ms. Maxwell did not disclose the 1996 Agreement earlier, the government was not able to fully and fairly investigate its case. Gov. Letter at 6. The government’s argument is groundless.! ' It is also tone-deaf, considering the government’s pattern and practice of discovering evidence in dead of night, just hours before witnesses testify. Some examples: e The government first disclosed Kate’s driver’s license at 11:11 p.m. the night before she testified. DOJ-OGR-00011334