DOJ-OGR-00011338.jpg

Case 1:20-cr-00330-PAE Document 719 _ Filed 07/12/22 Page6of8 The Honorable Alison J. Nathan December 13, 2021 Page 6 For another thing, evidence that Ms. Maxwell did not purchase the Kinnerton Street home until 1996 is publicly available and accessible via the internet.? The government could have asked those same investigators to obtain property records. Further, the government has the ability to avail itself of a Mutual Legal Assistance Treaty (MLAT), an agreement between the United States and United Kingdom and an investigatory tool frequently used by the government for the purpose of gathering and exchanging information with the United Kingdom in the course of criminal investigations. Now that the date of Ms. Maxwell’s purchase of Kinnerton Street is relevant, Ms. Maxwell has requested these registry entries from Her Majesty’s Land Registry. These entries show the transfer of title of 44 Kinnerton Street to Ghislaine Maxwell in March 1997 after the 1996 Agreement for Sale. Ms. Maxwell will provide these documents to the government as soon as she has them. In addition, just this morning, Ms. Maxwell obtained a copy of the Transfer of Title for Kinnerton Street to Ms. Maxwell. Ms. Maxwell provided this document to the government within three hours of first receiving it. Thus, once it became clear that the 1996 Agreement was relevant, it took just days for Ms. Maxwell to obtain independently relevant and admissible evidence proving the same point—that Kate testified to an impossibility. Because the government has received a copy of the Transfer of Title, and because Ms. Maxwell will immediately produce the public records she obtains from the Land Registry, the government cannot claim to be prejudiced by the discovery of the 1996 Agreement. 3 https://eservices.landregistry.gov.uk/eservices/FindA Property/view/QuickEnquirylnit.do (last visited Dec. 13, 2021). DOJ-OGR- 00011338