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ial facts necessary ~o establish the ••• cl.aims .·asseri:eq. because rieither Defendant Aron berg, nor The Office. of the State Attorn~y for the . Fifteenth Judicial Circuit is. in custody or control of the .2006 grand jury !materials sought therein: Simply put, the deciaratory n:lief sought by the Plaintiff, seeks recor
LORIDA COUNTY OF NASSAU BEFORE ME, the undersigned authority appeared Douglas A. Wyler, Esq., who, after being first duly sworn, deposes and says: 1. Affiant is a partner of JACOBS, SCHOLZ & WYLER, LLC, counsel for Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, (“Aronberg”), as
jury indicted Jeffrey Epstein on allegations similar to those in the instant action (State of Florida v. Jeffrey Epstein, Case No. 2006 CF 09454A, Fifteenth Judicial Circuit, Palm Beach County) (the "Florida Criminal Action"). Shortly thereafter, the United States Attorney's Office for the Southern District of Florida (
other offenses. 3. Throughout the investigat ion, when a victim was identified, victim not i ficat ion letters were provided to her both from your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, T.M., C.W., and
d jury indicted Jeffrey Epstein on allegations similar to those in the instant action (State of Florida I Jeffrey Epstein, Case No. 2006 CF 09454A, Fifteenth Judicial Circuit, Palm Beach County) (the "Florida Criminal Action"). Shortly thereafter, the United States Attorney's Office for the Southern District of Florida (
gst other offenses. 3. Throughout the investigation, when a victim was identified, victim notification letters were provided to her both from your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, and Your Affi
nd jury indicted Jeffrey Epstein on allegations similar to those in the instant action (State of Florida" Jeffrey Epstein, Case No. 2006 CF 09454A, Fifteenth Judicial Circuit, Palm Beach County) (the "Florida Criminal Action"). Shortly thereafter, the United States Attorney's Office for the Southern District of Florida (
gst other offenses. 3. Throughout the investigation, when a victim was identified, victim notification letters were provided to her both from your Affiant and from the FBI's Victim-Witness Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, T.M., C.W., and
Entities connected to both Fifteenth Judicial Circuit and Affiant

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSONJane Doe
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Bradley Edwards
PERSONFBI
ORGANIZATION
United States
LOCATION
Scarlett Johansson
PERSON
Palm Beach Police Department
ORGANIZATION
Alexander Acosta
PERSON
West Palm Beach
LOCATION
Department of Justice
ORGANIZATION
Minnesota
LOCATION
Sacramento
LOCATIONJames Eisenberg
PERSON
the United States District Court
ORGANIZATIONthe U.S. District Courts
ORGANIZATION
Palm Beach
LOCATION