EFTA00028103.pdf

Type: pdf
Source set: data-set-8

Extracted text

Exhibit A
EFTA00028103

CL
COHEN & GRESS ER LLP
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2' 2957 7600 phone
Quastian R. Everdell
+I (212) 957-7600
ceventell@cohengresses 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. Re!. Toul v. R an 340 U.S. 462
, for the testimony of (1) FBI Special A ent
, (2) FBI Special
, (3) FBI Special Agent
Tas Force Officer,
at the trial in this case on ovem r 2 , 2019 at 9:00 A.M., before the
ison
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 t 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 being
by the New York FBI and the U.S. Attomey'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 (MN)), the initial
…

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