EFTA00028103.pdf
151 KB
Extraction Summary
9
People
8
Organizations
5
Locations
4
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal correspondence (touhy request)
File Size:
151 KB
Summary
A formal 'Touhy request' letter dated August 30, 2021, from Ghislaine Maxwell's attorney Christian Everdell to Assistant Attorney General Kenneth Polite. The letter requests the testimony of four redacted FBI/Task Force agents for Maxwell's upcoming trial. These agents were involved in two key investigations: the 2006-2008 Palm Beach FBI investigation into Jeffrey Epstein and the subsequent New York FBI investigation that led to the 2019/2020 indictments of Epstein and Maxwell.
People (9)
| Name | Role | Context |
|---|---|---|
| Christian R. Everdell | Attorney |
Sender of the letter; Partner at Cohen & Gresser LLP; Counsel for Ghislaine Maxwell.
|
| Kenneth A. Polite, Jr. | Assistant Attorney General |
Recipient of the letter; Official at U.S. Department of Justice, Criminal Division.
|
| Ghislaine Maxwell | Defendant |
Subject of the criminal case S2 20 Cr. 330 (AJN).
|
| Jeffrey Epstein | Subject of Investigation |
Mentioned as the subject of FBI investigations in 2006-2008 and 2019.
|
| Alison J. Nathan | District Judge |
Presiding judge for the trial scheduled for November 29, 2021.
|
| [REDACTED] (Agent 1) | FBI Special Agent |
Co-case agent for Palm Beach FBI investigation (2006-2008); testimony requested.
|
| [REDACTED] (Agent 2) | FBI Special Agent |
Co-case agent for Palm Beach FBI investigation (2006-2008); testimony requested.
|
| [REDACTED] (Agent 3) | FBI Special Agent |
Co-case agent for New York FBI investigation (Current/2019); testimony requested.
|
| [REDACTED] (Agent 4) | Task Force Officer, Detective |
Co-case agent for New York FBI investigation (Current/2019); testimony requested.
|
Timeline (4 events)
2006-07 to 2008-06
Investigation into allegations of sexual abuse by Jeffrey Epstein conducted by Palm Beach FBI and USAO SD of Florida.
Palm Beach, Florida
Jeffrey Epstein
Palm Beach FBI Agents
2019-07-02
Indictment against Jeffrey Epstein returned (19 Cr. 490 (RB)).
Southern District of New York
2020-06-29
Initial indictment against Ghislaine Maxwell returned (20 Cr. 330 (AJN)).
Southern District of New York
2021-11-29
Scheduled trial date for United States v. Ghislaine Maxwell.
Southern District of New York
Relationships (2)
Letter states 'We represent the defendant, Ghislaine Maxwell'
Mentioned in context of connected indictments and investigations.
Key Quotes (3)
"This letter constitutes a request made pursuant to United States ex. Rel. Touhy v. Regan... for the testimony of... FBI Special Agent [REDACTED]... at the trial in this case on November 29, 2021"Source
EFTA00028103.pdf
Quote #1
"[REDACTED] 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."Source
EFTA00028103.pdf
Quote #2
"The testimony of these law enforcement officers is relevant and material to the issues in this case."Source
EFTA00028103.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (3,498 characters)
Exhibit A
EFTA00028103
EFTA00028103
COHEN & GRESSER LLP
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
800 Third Avenue
New York, NY 10022
+1 212 957 7600 phone
www.cohengresser.com
Christian R. Everdell
+1 (212) 957-7600
ceverdell@cohengresser.com
+1 (212) 957-7600
ceverdell@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
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 [REDACTED], (2) FBI Special Agent [REDACTED], (3) FBI Special Agent [REDACTED], and (4) Task Force Officer, Detective [REDACTED], at the trial in this case on November 29, 2021 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:
[REDACTED] 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 [REDACTED] and [REDACTED] 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.
[REDACTED] and [REDACTED] 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
EFTA00028104
EFTA00028104
U.S. Department of Justice
August 30, 2021
Page 2
August 30, 2021
Page 2
(AJN)). We request testimony from [REDACTED] and [REDACTED] 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.
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)).
If you have any questions or would like to discuss further, please do not hesitate to contact me.
Sincerely,
/s/ Christian R. Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue, 21st Floor
New York, New York 10022
(212) 957-7600
cc: All counsel of record (by email)
2028844.3
EFTA00028105
EFTA00028105
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