Case 1:20-cr-00330-PAE Document 721 Filed 07/12/22 Page1of9
Haddon, Morgan and Foreman, P.C
Jeffrey S. Pagliuca
My 150 East 10th Avenue
Denver, Colorado 80203
PH 303.831.7364
FX 303.832.2628
www.hmflaw.com
[email protected]
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 [yy
MB. twenty years after the real estate transaction reflected in the documents he will serve as a
foundational witness to admit.
Mr. J 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