DOJ-OGR-00006416.pdf

--- Page 1 --- **Document Extract** **Case Number:** 1:20-cr-00330-PAE **Document Number:** 438-1 **Filed Date:** 11/12/21 **Page Number:** 2 of 3 **Company Name:** COHEN & GRESSER LLP **Contact Information:** * Christian R. Everdell * +1 (212) 957-7600 * ceverdell@cohengresser.com **Email Address:** cevedell@cohengresser.com **Letterhead:** * BY FIRST CLASS MAIL * Mr. Kenneth A. Polite, Jr. * Assistant Attorney General * Criminal Division * U.S. Department of Justice * 950 Pennsylvania Avenue, NW * Washington, D.C. 20530-0001 **Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)** **Dear Assistant Attorney General Polite:** We represent the defendant, Ghislaine Maxwell, in the above-referenced matter. This letter constitutes a request made pursuant to United States ex. Rel. Touhy v. Regan, 340 U.S. 462 (1951), for the testimony of (1) FBI Special Agent, (2) FBI Special Agent, (3) FBI Special Agent, and (4) Task Force Officer, Detective at the trial in this case on November 29, 2019 at 9:00 A.M., before the Honorable Alison J. Nathan, United States District Judge. In accordance with 28 C.F.R. § 16.23(c), we make the following statement setting forth a summary of the testimony we seek: were co-case agents in charge of an investigation into allegations of sexual abuse by Jeffrey Epstein conducted by the Palm Beach FBI and the U.S. Attorney's Office for the Southern District of Florida from approximately July 2006 to June 2008. We request testimony from [illegible] and [illegible] concerning the scope, timeline, and resolution of the investigation, as well as the various investigative steps taken by the agents, including but not limited to testimony about numerous witness interviews they conducted, physical evidence they reviewed, documents they obtained by subpoena, and their testimony before the grand jury. and are the co-case agents in charge of the current investigation being conducted by the New York FBI and the U.S. Attorney's Office for the Southern District of New York, which resulted in the indictment against Jeffrey Epstein returned on July 2, 2019 (19 Cr. 490 (RB)) and the above-captured superseding indictment against Ms. Maxwell (S2 20 Cr. 330 (AJN)), the initial indictment against Ms. Maxwell having been returned on June 29, 2020 (20 Cr. 330 **2028844.3** **DOJ-OGR-00006416**