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From: )" <=1.1Mla To: Subject: FW: Reference materials further to our call Date: Tue, 01 Sep 2020 17:35:30 +0000 Inline-Images: image001.jpg; image002.jpg Our response (for now) below. From Sent: ues ay, ep em er : PM To: Gary Bloxsome Cc: (USANYS) Subject: RE: Reference materials further to our call S.; Daniel Cundy ; Jennifer Richardson Gary, We have received the below communication, and we will revert back as appropriate. thank you, Assistant U.S. Attorney Southern District of New York >; From: Gary Bloxsome Sent: Tuesday, September 01, 2020 13:04 To: ; ) < >; Daniel Cundy ; Jennifer Richardson Subject: Re: Reference materials further to our call Dear We have found our recent conferences with you and your team (on 27 July, 3, 11 and 20 August 2020) helpful and informative and again I extend my thanks for your taking the time to discuss these matters at length. In the UK the provision of a signed witness statement - bearing a statement attesting as to its truth - is a commonly used approach when a witness provides evidence. Whilst we appreciate that such an approach differs from what is standard in the US, we do not consider such an approach would be unhelpful, or of no utility, to your case. Our client is willing to provide you with a witness statement, addressing any issues that he may be able to,in relation to Ghislaine Maxwell and Jeffrey Epstein, his association with them and his knowledge of them such as may be relevant to the prosecution of Ghislaine Maxwell. In addition - should you make written requests for clarification arising from that witness statement - our client could provide written answers by way of a supplementary/addendum statement. Such an interaction could take place more than once if necessary. Providing written answers to either written questions or to questions previously put, is again a common practice in the UK. EFTA00073197 You have invited us to identify any areas or subject topics which we would consider to be inappropriate or irrelevant to be put to our client; we consider that questions put/topics raised should rightfully be limited to the indictment period in the current proceedings (i.e. US v Ghislaine Maxwell), being 1994-1997. We are of course aware that you have requested a witness interview in your request to the UKCA and to ourselves; you have confirmed to us however (in January this year, through your liaison officer immediately prior to our recent conferences, and then during our conferences) that you regard our client not as a witness but as a subject. We have ventilated at some length our concerns regarding our client being interviewed in those circumstances and we consider a witness statement and the offer of further engagement with written questioning to be a fair compromise and one which would be acceptable in the UK. To move forward with the above approach, we would continue to require your assurance that the content of any such witness statement and supplementary written responses be treated with the utmost confidentiality, not used for any purpose other than in relation to the criminal proceedings against Ms Maxwell, and not be shared with any parties outside of your department, including complainants and their representatives in your investigation and in civil matters outside of it. Kind regards Gary Gary Bloxsome I Partner Blackfords LIP 1 15 Old Bailey I London I EC4M 7EF DX 161400 Old Bailey 5 I 020 3427 3343 I www.blackfords.com RANKED IN Chambers j % UK AP • S O 20 7 0 e Ft, III ;UP HER COVID-19 - Please see our website here for our updated position in relation to Coronavirus. In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 8686 6232 where we will respond to the messages in the order they are received or by emailing your enquiry to [email protected] Blackfords LLP is a limited liability partnership registered in England & Wales with registered number 0C325398 at Hill House, 1 Mint Walk, Croydon, CRO LEA. A list of members' names is available at this address. GOPR: details of how we handle personal data can be found in our Privacy Statement Authorised and regulated by the Solicitors Regulation Authority under number 462078. On 19 Aug 2020, at 18:19, External email: is it safe to open attachments and links? Received, thank you. We'll speak with you then. wrote: EFTA00073198 From: Gary Bloxsome Sent: Wednesda Au ust 19 2020 12:39 T Cc: < >; >; Jennifer Richardso ; Daniel Cundy Subject: Re: Re erence materia s urt er to our ca I Yes Same dial in details as before. Regards Gary 8loxsome I Partner ac ors LIP I 15 Old Bailey I London I EC4M 7EE DX 161400 Old Bailey 5 I 020 3427 3343 I www.blackfords.com COVID-19 — Please see our website here for our updated position in relation to Coronavirus. In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 8686 6232 where we will respond to the messages in the order they are received or by emailing your enquiry to covidPblackfords.com Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, Croydon, CR0 lEA. A list of members' names is available at this address. GDPR: details of how we handle personal data can be found in our Privacy Statement Authorised and regulated by the Solicitors Regulation Authority under number 462078. On 19 Aug 2020, at 17:36, Wrote: External email: is it safe to open attachments and links? Gary, Are we still planning to speak via phone tomorrow at 2:30 London time? Regards, From: Daniel Cundy Sent: Sunday, August 09, 2020 12:30 To Jennifer Richardson Subject: Reference materials further to our call ; Gary Bloxsome Dear EFTA00073199 Apologies for the slight delay. Please find attached an extract from The Decision Procedure and Penalties manual (DEPP 7) from the Financial Conduct Authority handbook — drawing attention to 7.2.14. This practice and approach resonates with the law as set out in United States v. Allen, 864 F.3d (2d Cir.2017). We also attach an extract from the publication `Montgomery and Ormerod on Fraud: Criminal Law and Procedure' (2008) which summarises the approach taken by the Serious Fraud Office (see A7-327) to the limitations and protections on use when their compulsory powers are used in MUT requests, an approach which reflects such cases as Kastigar v. United States, 406 U.S. 441 (1972) as well as decisions in UK domestic law. We reiterate the protection at Article 7 (2) of the MLAT treaty although there is no need to attach it. Kind regards Daniel Cundy I Partner Blackfords LLP I 15 Old Bailey I London I EC4M 7EF DX 161400 Old Bailey 5 1 020 3427 3343 I www.blackfords.com COVID-19 — Please see our website here for our updated position in relation to Coronavirus. In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 8686 6232 where we will respond to the messages in the order they are received or by emailing your enquiry to covidPblackfords.com Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, Croydon, CR0 lEA. A list of members' names is available at this address. GDPR: details of how we handle personal data can be found in our Privacy Statement Authorised and regulated by the Solicitors Regulation Authority under number 462078. Daniel Cundy I Partner ac ors I 15-ORFEVailey [London FEC4IVI 7EF DX 161400 Old Bailey 5 1 020 3427 3343 I www.blackfords.com COVID-19 — Please see our website here for our updated position in relation to Coronavirus. In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 8686 6232 where we will respond to the messages in the order they are received or by emailing your enquiry to [email protected] Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, Croydon, CR0 lEA. A list of members' names is available at this address. GDPR: details of how we handle personal data can be found in our Privacy Statement Authorised and regulated by the Solicitors Regulation Authority under number 462078. EFTA00073200