COHEN & GRESSER LLP (.11nquan R I November 15, 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 Unite ouhy v. Regan, 340 U.S. 462 (1951), for the testimon of 1 FBI S ial Agent and (2) former Assistant United States Attorney 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: SAnas co-case agent 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 (the "Florida Investigation"). During the course of the Florida Investigation, SA was present for numerous interviews of witnesses who alleged that they were sexually abused by Jeffrey Epstein, including at least one witness who is anticipated to testify against Ms. Maxwell at the trial in the above- captioned case the The interview of the Witness took place on August 7, 2007. SA took contemporaneous notes of the interview and summarized ' • an FBI 302, dated August 13, 2007. The government has produced S notes and the FBI 302 to the defense as part of the criminal discovery in this case. In the event that the Witness's testimony at trial is inconsistent with the statements she made at the August 7, 2007 interview, the defense would seek to call SA to impeach the Witness. is a former Assistant United States Attorney in the United States Attorney's Office for the