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Case 1:20-cr-00330-PAE Document 721 Filed 07/12/22 Pagelof9 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 jeagliuca@hmflaw.com HADDON MORGAN FOREMAN December 14, 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, I write under Rules of Evidence 608 and 403 to request that this Court preclude cross- examination Of i by the government concerning a regulatory settlement agreement involving Mr. 3 ¢clated to | HB. twenty years after the real estate transaction reflected in the documents he will serve as a foundational witness to admit. Mr. EE is a retired British Solicitor who represented Ms. Maxwell in the purchase of 44 Kinnerton Street, London SW1. The government has refused to stipulate to the admission of the 1996 Agreement for Sale for 44 Kinnerton Street and other related title documents, which show that Ms. Maxwell did not contract to purchase 44 Kinnerton Street until December 1996 (and did not complete the purchase until January 1997), long after Kate claims she engaged in a sexualized massage with Jeffrey Epstein in that residence. As a result, although the government does not contest the authenticity or relevance of these records, Ms. Maxwell DOJ-OGR-00011345