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Case 1:20-cr-00330-PAE Document 719 _ Filed 07/12/22 Page5of8 The Honorable Alison J. Nathan December 13, 2021 Page 5 correct? A. I testified that I thought I was around that age, yes. Q. And I think you said, when asked to do the math, that it was approximately 1994; correct? A. Yes.”) Second, the government’s theory of prejudice is bewildering. The government contends that it was prejudiced by its own failure to investigate whether its witness was telling the truth.” Gov. Letter at 6. Again, before her testimony, Kate had told the government two different stories about where Ms. Maxwell lived in 1994—at a home in the Kensington neighborhood, or at the Kinnerton Street home in the Belgravia neighborhood. The government chose not to investigate where Ms. Maxwell actually lived in 1994 and which, if any, of Kate’s stories were true. That is not Ms. Maxwell’s fault. And neither is it her duty to do the government’s work for it. The government cannot seriously contend that an investigation into where Ms. Maxwell lived “did not become necessary” until after Kate testified. Gov. Letter at 6. The government complains about the difficulty of conducting investigations abroad. Gov. Letter at 6 (“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.”). The government’s complaints are overwrought. For one thing, the government had investigators in the United Kingdom investigating Ms. Maxwell’s college record. There was nothing preventing these investigators from asking the most basic of questions: When did Ms. Maxwell purchase the Kinnerton Street property? ? The government’s failure to investigate is not limited to Kate’s allegations. The veracity of another accuser, Jane, is the subject of a post-testimony 3500 disclosure. ay DOJ-OGR-00011337