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ts against Jeffrey Epstein for sexually abusing them. I am also familiar with the criminal justice system, having served as state prosecutor in the Broward County State Attorney's Office. 2. This affidavit covers factual issues regarding the Government's assertions of privilege to more than 13,000 pages of do
egarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Ferrer, asking him to personally investigate what happened during the Epstein prosecution and how the victims were treated during that investigation. Based
pated in the trafficking of Jane Doe No. 3. Where sexual issues are relevant to a case, they must not be stricken. See, e.g., Zdenekl School Bd. of Broward County, No. 07-CV-61110, 2007 WL 4521489, at •2 (S.D. Fla. Dec. 19, 2007) ("given the Eleventh Circuit standards on what constitutes actionable sexual hara
ourt's anticipated approval. Three months later, having received no response from the Government, victims' counsel sent an additional letter to Mr. Ferrer, requesting agreement to add an additional victim to the case — a young woman identified in current pleadings as Jane Doe No. 34: Dear Mr. Ferrer:
ts against Jeffrey Epstein for sexually abusing them. I am also familiar with the criminal justice system, having served as state prosecutor in the Broward County State Attorney's Office. 2. This affidavit covers factual issues regarding the Government's assertions of privilege to more than 13,000 pages of do
egarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. Attorney, Mr. Ferrer, asking him to personally investigate what happened during the Epstein prosecution and how the victims were treated during that investigation. Based
ed in the trafficking of Jane Doe No. 3. Where sexual issues are relevant to a case, they must not be stricken. See. e.g., Zdenek I. School lad. q• Broward County, No. 07-CV-61110, 2007 WL 4521489, at *2 (S.D. Fla. Dec. 19, 2007) ("given the Eleventh Circuit standards on what constitutes actionable sexual hara
ourt's anticipated approval. Three months later, having received no response from the Government, victims' counsel sent an additional letter to Mr. Ferrer. requesting agreement to add an additional victim to the case — a young woman identified in current pleadings as Jane Doe No. 34: Dear Mr. Ferrer:
Entities connected to both Broward County and Ferrer

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSONJane Doe
PERSON
Kenneth Marra
PERSONMaria Farmer
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSONJack Goldberger
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Prince Andrew
PERSON
United States
LOCATION
Virginia Giuffre
PERSON
Bill Clinton
PERSON
Julie K. Brown
PERSONRoy Black
PERSON