Case 1:20-cr-00330-PAE Document 722 Filed 07/12/22 Pagelof7
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 15, 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 to alert the Court and the government to the inconsistent statements Ms. Maxwell
intends to prove up by extrinsic evidence during her case.
Ms. Maxwell conferred with the government about this issue. After conferral, and given
the press of time, counsel concluded it was most efficient to provide this notice to the Court and
the government and to allow the government to consider which other statements it would
stipulate to in addition to those the parties have already agreed on.
A. Jane Inconsistent Statements
Trial Testimony | 3500 material cite 3500 quote
375:20 — 376:20 | 3509-008, p. 12, 4" From when Jane met Epstein to when she moved
paragraph, last sentence | to New York she lived in the same house in
Florida. This house was in a gated community
called Bear Lakes. It was a 3 bedroom house.
447:2 — 447:20 3509-002, p. 1 GM walked by w/ dog. JE came up to meet her.
DOJ-OGR-00011356