EFTA00078983¶
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.¶
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 anv¶
EFTA00078984¶
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 | Partner¶
Blackfords LLP | 15 Old Bailey | London | EC4M 7EF¶
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Received, thank you. We’ll speak with you then.¶
Yes¶
Same dial in details as before.¶
Regards¶
Gary Bloxsome | Partner¶