{
  "document_metadata": {
    "page_number": "2 of 3",
    "document_number": "380-1",
    "date": "10/29/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 380-1 Filed 10/29/21 Page 2 of 3 COHEN & GRESSER LLP Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com 800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com 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 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  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, 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-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 2028844.3 DOJ-OGR-00005449",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 380-1 Filed 10/29/21 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "COHEN & GRESSER LLP",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell +1 (212) 957-7600 ceverdell@cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "800 Third Avenue New York, NY 10022 +1 212 957 7600 phone www.cohengresser.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "August 30, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BY FIRST CLASS MAIL",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Mr. Kenneth A. Polite, Jr. Assistant Attorney General Criminal Division U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, D.C. 20530-0001",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Assistant Attorney General Polite:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "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.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "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  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, and their testimony before the grand jury.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": " 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-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",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2028844.3 DOJ-OGR-00005449",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Christian R. Everdell",
      "Kenneth A. Polite, Jr.",
      "Ghislaine Maxwell",
      "Jeffrey Epstein",
      "Alison J. Nathan"
    ],
    "organizations": [
      "COHEN & GRESSER LLP",
      "U.S. Department of Justice",
      "FBI",
      "U.S. Attorney's Office for the Southern District of Florida",
      "U.S. Attorney's Office for the Southern District of New York"
    ],
    "locations": [
      "New York",
      "Washington, D.C.",
      "Palm Beach",
      "Florida"
    ],
    "dates": [
      "August 30, 2021",
      "November 29, 2019",
      "July 2006",
      "June 2008",
      "July 2, 2019",
      "June 29, 2020",
      "October 29, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 380-1",
      "S2 20 Cr. 330 (AJN)",
      "19 Cr. 490 (RB)",
      "20 Cr. 330",
      "2028844.3",
      "DOJ-OGR-00005449"
    ]
  },
  "additional_notes": "The document is a letter requesting testimony from FBI agents in the case United States v. Ghislaine Maxwell. The letter is from Christian R. Everdell of COHEN & GRESSER LLP and is dated August 30, 2021. The document contains redactions, likely for the names of the FBI agents."
}