Case 1:20-cr-00330-PAE
Cy
HADDON
MORGAN
FOREMAN
December 13, 2021
VIA Email
The Honorable Alison J. Nathan
United States District Court
Souther District of New York
40 Foley Square
New York, NY 10007
Document 719
Filed 07/12/22 Pagelof8
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
[email protected]
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