{
  "document_metadata": {
    "page_number": "3",
    "document_number": "438-1",
    "date": "11/12/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 438-1 Filed 11/12/21 Page 3 of 3\n\nU.S. Department of Justice\nAugust 30, 2021\nPage 2\n\n(AJN)). We request testimony from and 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, their testimony before the grand jury, and the indictments returned by the grand jury.\n\nThe 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)).\n\nIf you have any questions or would like to discuss further, please do not hesitate to contact me.\n\nSincerely,\n\n/s/ Christian R. Everdell\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor\nNew York, New York 10022\n(212) 957-7600\n\ncc: All counsel of record (by email)\n\n2028844.3\nDOJ-OGR-00006417",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 438-1 Filed 11/12/21 Page 3 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nAugust 30, 2021\nPage 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "(AJN)). We request testimony from and 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, their testimony before the grand jury, and the indictments returned by the grand jury.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "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)).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "If you have any questions or would like to discuss further, please do not hesitate to contact me.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Sincerely,",
      "position": "body"
    },
    {
      "type": "signature",
      "content": "/s/ Christian R. Everdell",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor\nNew York, New York 10022\n(212) 957-7600",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "cc: All counsel of record (by email)",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "2028844.3\nDOJ-OGR-00006417",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Christian R. Everdell",
      "Ms. Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "COHEN & GRESSER LLP"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "August 30, 2021",
      "11/12/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 438-1",
      "2028844.3",
      "DOJ-OGR-00006417"
    ]
  },
  "additional_notes": "The document appears to be a letter from Christian R. Everdell to the U.S. Department of Justice, discussing the testimony of law enforcement officers in a case involving Ms. Maxwell. The document is well-formatted and legible, with no visible redactions or damage."
}