Keyboard shortcuts

/
Search the files
j k
Move through a list of results
[ ]
Previous or next document
g g · G
Top or bottom of the page
Esc
Leave a search field or close this box
?
Show this box

Go to a page: g then

h
Index
t
Timeline
p
People
r
Redactions
x
Explore
w
News
l
Legislation
a
About

Correspondence · Aug. 30, 2021

Maxwell defense letter to DOJ requesting FBI agents' testimony, Aug. 2021

Defense counsel for Ghislaine Maxwell requests under federal regulations the testimony of FBI agents from the Epstein and Maxwell investigations.Machine-written summary

Exhibit A

I iaa 1..v. lc a. IA len:* • 2’29577600 phone

Ginn= R Eretckll +1 (212) 957-7600 cevencle114cohengtessex co:.

August 30, 2021

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 Slates 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 a. Rel. Touhv v. R an, 340 U.S. 462 . for the testimony of (1) FBI Special A ent , (2) FBI Special , (3) FBI Special Agent Tas c Force Officer, at the trial in this case on ovem r 2 2019 at 9:00 A.M., before the son athan, 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 approximate) July 2006 to June 2008. We request testimony from and concerning the scope, timeline, and resolution of the investigation, as wel as e 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 bell Mi nicted 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-captioned 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 U.S. Department of Justice August 30, 2021 Page 2

(AJN)). We request testimony from and concerning the scope, timeline, and resolution of the investigation, an.re.ste 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, their testimony before the grand jury, and the indictments returned by the grand jury.

The testimony of these law enforcement officers is relevant and material to the issues in this case. Furthermore, it is Ms. Maxwell’s position that the disclosure is appropriate under rules of procedure and that disclosure, to Ms. Maxwell’s knowledge, would not violate any statute or regulations or reveal confidential sources, classified information, trade secrets, ongoing investigations, or investigatory techniques. (28 C.F.R. § 16.26(b)).

me. If you have any questions or would like to discuss further, please do not hesitate to contact

Sincerely,

/s/ Christian R. Everdell

Christian R. Everdell

& GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600

cc: All counsel of record (by email)

Maxwell defense letter to DOJ requesting FBI agents' testimony, Aug. 2021

Emails and letters

Defense counsel for Ghislaine Maxwell requests under federal regulations the testimony of FBI agents from the Epstein and Maxwell investigations.

Court Records: United States v. Maxwell (S.D.N.Y. 1:20-cr-00330) · Aug. 30, 2021

Exhibit A I iaa 1..v. lc a. IA len:\ • 2'29577600 phone Ginn= R Eretckll +1 (212) 957-7600 cevencle114cohengtessex co:. August 30, 2021 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 Slates 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 a. Rel. Touhv v. R an, 340 U.S. 462 . for the…