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From: Christian EverdellSubject: Re: CBP Question
Case File
efta-efta00093488DOJ Data Set 9Other

COHEN & GRESSER LLP

COHEN & GRESSER LLP August 30, 2021 BY FIRST CLASS MAIL 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.: Lo.4.111J Ne,v"oil 1,." ICO22 . I 212 057 70) p'1*-. on. We represent the defendant, Ghislaine Maxwell, in the above-referenced matter. This letter constitutes a request made pursuant to United States a. Rel. Touh v. Re an, 340 U.S. 462 (1951), for the testimony of (1) FBI Special A ent (2) FBI Special Agent (3) FBI Special Agent , and (4) Task Force Officer, Detecti 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: SA and SA were co-case agents in charge of an investigation into alleg

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00093488
Pages
2
Persons
3
Integrity

Summary

COHEN & GRESSER LLP August 30, 2021 BY FIRST CLASS MAIL 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.: Lo.4.111J Ne,v"oil 1,." ICO22 . I 212 057 70) p'1*-. on. We represent the defendant, Ghislaine Maxwell, in the above-referenced matter. This letter constitutes a request made pursuant to United States a. Rel. Touh v. Re an, 340 U.S. 462 (1951), for the testimony of (1) FBI Special A ent (2) FBI Special Agent (3) FBI Special Agent , and (4) Task Force Officer, Detecti 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: SA and SA were co-case agents in charge of an investigation into alleg

Persons Referenced (3)

CHRISTIAN R. EVERDELL

“...uld like to discuss further, please do not hesitate to contact Sincerely, /s/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New...”

Ghislaine MaxwellJeffrey Epstein

“...-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 Souther...”

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COHEN & GRESSER LLP August 30, 2021 BY FIRST CLASS MAIL 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.: Lo.4.111J Ne,v"oil 1,." ICO22 . I 212 057 70) p'1*-. on. We represent the defendant, Ghislaine Maxwell, in the above-referenced matter. This letter constitutes a request made pursuant to United States a. Rel. Touh v. Re an, 340 U.S. 462 (1951), for the testimony of (1) FBI Special A ent (2) FBI Special Agent (3) FBI Special Agent , and (4) Task Force Officer, Detecti 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: SA and SA 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 SA and SA 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. SA and TFO 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 20288443 EFTA00093488 U.S. Department of Justice August 30, 2021 Page 2 (AJN)). We request testimony from SA and TFO 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)). 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 COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 cc: All counsel of record (by email) 20288443 EFTA00093489

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Related Documents (6)

Court UnsealedLegal FilingUnknown

Court filings and motions: 38

The documents include court filings related to the cases of Jeffrey Epstein and Ghislaine Maxwell, focusing on issues such as the disclosure of victim identities, protective orders, and access to discovery materials. The filings demonstrate the legal strategies employed by both the prosecution and the defense in these high-profile cases.

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00094289 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 I. Reconsideration of the Court's Bail Decision is Appropriate Under 18 U.S.C. § 3142(O 7 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict Bail Conditions 10 A. Ms. Maxwell Has Deep Family Ties to the United States and Numerous Sureties to Support Her Bond 10 1. Ms. Maxwell is Devoted to Her Spouse and Stepchildren and Would Never Destroy Her Family By Leaving th

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DOJ Data Set 8CorrespondenceUnknown

EFTA00011452

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DOJ Data Set 9OtherUnknown

LBUCmaxl

120 LBUCmaxl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Trial New York, N.Y. November 30, 2021 8:50 a.m. HON. ALISON J. NATHAN, APPEARANCES DAMIAN United States Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM -and- RENATO STABILE Also Present: District Judge , FBI NYPD Sunny Drescher, Paralegal, U.S. Attorney's Office Ann Lundberg, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068582 121 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury not present) THE COURT: Looks like we have everybody. Matt

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00090990 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare fo

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Court UnsealedCorrespondenceUnknown

Court filings and letters: 30

The documents include a letter from the U.S. Attorney's Office regarding Jeffrey Epstein's foreign passport and court filings related to Ghislaine Maxwell's case, focusing on disputes over discovery materials and the disclosure of alleged victims' identities.

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