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t claims she has suffered substantial prejudice as a result of pre- indictment delay due to the unavailability o fJeffrey Epstein, Epstein 's mother, Michael Casey (the alleged agent of Minor Victim-1), and Palm Beach Police Department Detective Joseph Recarey. She contends that the loss of Epstein demonstrate
he defendant invites the Court to engage in a balancing test that weighs the prejudice to the defendant against the Government's reasons for delay. (Del Mot. 7 at 5,6 n.4). This Court should reject the defendant's invitation. The defendant cites United States v. Brand, 556 F.2d 1312, 1317 n.7 (5th Cir.
st claims she has suffered substantial prejudice as a result of pre- indictment delay due to the unavailability of Jeffrey Epstein, Epstein's mother, Michael Casey (the alleged agent of Minor Victim-1), and Palm Beach Police Department Detective Joseph Recarey. She contends that the loss of Epstein demonstrate
ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February
st claims she has suffered substantial prejudice as a result of pre- indictment delay due to the unavailability of Jeffrey Epstein, Epstein's mother, Michael Casey (the alleged agent of Minor Victim-1), and Palm Beach Police Department Detective Joseph Recarey. She contends that the loss of Epstein demonstrate
ance with the subpoenas. (Def. Mot. 3, Ex. C). Following a request by Judge Sweet for briefing supporting the Government's initial application, see Del Mot. 3, Ex. D at 4, 20; Ex. G at 6, the Government submitted a pane and sealed letters in support of its applications to each court on or about February
Entities connected to both Michael Casey and Del Mot

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Scarlett Johansson
PERSON
John F. Kennedy
PERSON
Department of Justice
ORGANIZATIONMyers
PERSON
Cornell University
ORGANIZATION
Kaplan
PERSONSchneider
PERSON
Michael Jackson
PERSONSalerno
PERSONSnyder
PERSONJoe Recarey
PERSON
George W. Bush
PERSONChacko
PERSONSalameh
PERSONLovasco
PERSON