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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
the Government to give him a more favorable plea arrangement and/or non-prosecution agreement, including efforts by former President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf.
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
the Government to give him a more favorable plea arrangement and/or non-prosecution agreement, including efforts by former President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Elt tefkowitz, and Roy Black on his behalf.
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
sion from "defense attorneys representing Epstein (including . . . Alan Dershowitz)" and from "agents acting in support of Epstein (including . . . Andrew Albert Christian Edward (Ala Prince Andrew Duke of York))." The Government responded to these (and other RFPs) by asserting privilege over 14,825 pages of documents that i
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
the Government to give him a more favorable plea arrangement and/or non-prosecution agreement, including efforts by former President Bill Clinton, Andrew Albert Christian Edward (aAda Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf.
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
ssion from "defense attorneys representing Epstein (including . . . Alan Dershowitz)" and from "agents acting in support of Epstein (including .. . Andrew Albert Christian Edward (a/Wa Prince Andrew Duke of York))." The Government responded to these (and other RFPs) by asserting privilege over 14,825 pages of documents that
Entities connected to both Broward County and Andrew Albert Christian Edward

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Ghislaine Maxwell
PERSONMaria Farmer
PERSONLeon Black
PERSONJane Doe
PERSON
Prince Andrew
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATION
Bill Clinton
PERSON
Department of Justice
ORGANIZATION
Palm Beach County
LOCATIONRoy Black
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Virginia Giuffre
PERSONFBI
ORGANIZATION