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pstein's house. Sec In Re Grand Jury Subpoenas Duces Tecum OLY-63 and OLY.64,Nu. F(31 07-103(WPB) (S.D. Fla. July 31, 2007). At the time she tiled Detective Recarey's affidavit, she knew it contained numerous material misrepresentations, including gross misstatements of witness statements and other evidence. Secon
Jury's indictment, the Chief took the unprecedented step of releasing his Department's raw police reports of the investigation (including Detective Recarey's unedited written reports of witness statements and witness identification information), that were later proven to be highly inaccurate transcript
d serious misrepresentations before a court. On July 31, 2007, in the grand-jury litigation arising out of this case, she filed the "Declaration of Joseph Recarey," attaching the state detective's affidavit in support of a search warrant for Epstein's house. Sec In Re Grand Jury Subpoenas Duces Tecum OLY-63 an
aw police reports of the investigation (including Detective Recarey's unedited written reports of witness statements
have "traditionally exercised restraint in assessing the reach of federal criminal statutes, both out of deference to the prerogatives of Congress, Dowling'. United States, 473 U.S. 207 (1985), and out of concern that 'a fair warning should be given to the world in language that the common world will u
navailability 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 demonstrates actual prejudice because Epstein "would have" testified that the defendant did not engage in th
m Beach Police Department even began investigating Epstein in 2005. (Def. Mot. 7, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00100013 2018 respectively,
, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00100013 2018 respectively, would have testified, and that such testimony would have been exculpat
in this Indictment have told the USAO-SDNY. In sum, the defendant has not put "specific evidence" before this Court demonstrating that the loss of Detective Recarey's testimony, even if admissible, has caused her actual prejudice. Scala, 388 F. Supp. 2d at 400. The defendant next contends that had the Government
122 Doe I v. United States, 359 F. Supp. 3d 1201 (S.D. Fla. 2019) 14 Doe No. I. v. United States, 749 F.3d 999 (11th Cir. 2014) 173, 174, 176 Dowling v. United States, 493 U.S. 342 (1990) 76 Duren v. Missouri, 439 U.S. 357 (1979) 289, 296 Edwards v. Mazzuca, No. 00 Civ. 2290 (RJS), 2007 WL 2
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 demonstrates actual prejudice because Epstein "would have" testified that the defendant did not engage in th
m Beach Police Department even began investigating Epstein in 2005. (Def. Mot. 7, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00077678 2018 respectively,
, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00077678 2018 respectively, would have testified, and that such testimony would have been exculpat
in this Indictment have told the USAO-SDNY. In sum, the defendant has not put "specific evidence" before this Court demonstrating that the loss of Detective Recarey's testimony, even if admissible, has caused her actual prejudice. Scala, 388 F. Supp. 2d at 400. The defendant next contends that had the Government
122 Doe 1 v. United States, 359 F. Supp. 3d 1201 (S.D. Fla. 2019) 14 Doe No. 1. v. United States, 749 F.3d 999 (11th Cir. 2014) 173, 174, 176 Dowling v. United States, 493 U.S. 342 (1990) 76 Duren v. Missouri, 439 U.S. 357 (1979) 289, 296 Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 29
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 demonstrates actual prejudice because Epstein "would have" testified that the defendant did not engage in th
m Beach Police Department even began investigating Epstein in 2005. (Def. Mot. 7, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00039493 2018 respectively,
, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00039493 2018 respectively, would have testified, and that such testimony would have been exculpat
in this Indictment have told the USAO-SDNY. In sum, the defendant has not put "specific evidence" before this Court demonstrating that the loss of Detective Recarey's testimony, even if admissible, has caused her actual prejudice. Scala, 388 F. Supp. 2d at 400. The defendant next contends that had the Government
122 Doe 1 v. United States, 359 F. Supp. 3d 1201 (S.D. Fla. 2019) 14 Doe No. 1. v. United States, 749 F.3d 999 (11th Cir. 2014) 173, 174, 176 Dowling v. United States, 493 U.S. 342 (1990) 76 Duren v. Missouri, 439 U.S. 357 (1979) 289, 296 Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 29
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 demonstrates actual prejudice because Epstein "would have" testified that the defendant did not engage in th
m Beach Police Department even began investigating Epstein in 2005. (Def. Mot. 7, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00095138 2018 respectively,
, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00095138 2018 respectively, would have testified, and that such testimony would have been exculpat
fied in this Indictment have told USAO-SDNY. In sum, the defendant has not put "specific evidence" before this Court demonstrating that the loss of Detective Recarey's testimony, even if admissible, has caused her actual prejudice. Scala, 388 F. Supp. 2d at 400. The defendant next contends that had the Government
. Lovasco, 431 U.S. 783, 795 (1977). The Supreme Court has "defined the category of infractions that violate `fundamental fairness' very narrowly," Dowling v. United States, 493 U.S. 342, 352 (1990), and the Supreme Court has "stressed the importance for constitutional purposes of good or bad faith on t
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 demonstrates actual prejudice because Epstein "would have" testified that the defendant did not engage in th
m Beach Police Department even began investigating Epstein in 2005. (Def. Mot. 7, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00103071 2018 respectively,
, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00103071 2018 respectively, would have testified, and that such testimony would have been exculpat
in this Indictment have told the USAO-SDNY. In sum, the defendant has not put "specific evidence" before this Court demonstrating that the loss of Detective Recarey's testimony, even if admissible, has caused her actual prejudice. Scala, 388 F. Supp. 2d at 400. The defendant next contends that had the Government
122 Doe 1 v. United States, 359 F. Supp. 3d 1201 (S.D. Fla. 2019) 14 Doe No. 1. v. United States, 749 F.3d 999 (11th Cir. 2014) 173, 174, 176 Dowling v. United States, 493 U.S. 342 (1990) 76 Duren v. Missouri, 439 U.S. 357 (1979) 289, 296 Edwards v. Mazzuca, No. 00 Civ. 2290 (US), 2007 WL 29
y have “traditionally exercised restraint in assessing the reach of federal criminal statutes, both out of deference to the prerogatives of Congress, Dowling v. United States, 473 U.S. 207 (1985), and out of concern that ‘a fair warning should be given to the world in language that the common world will un
Page: HOUSE_OVERSIGHT_012145 →d Jury’s indictment, the Chief took the unprecedented step of releasing his Department’s raw police reports of the investigation (including Detective Recarey’s unedited written reports of witness statements and witness identification information), that were later proven to be highly inaccurate transcriptio
Page: HOUSE_OVERSIGHT_012160 →aw police reports of the investigation (including Detective Recarey’s unedited written reports of witness statements
Page: HOUSE_OVERSIGHT_012160 →g out of this case, she filed the “Declaration of Joseph Recarey,” attaching the state detective’s affidavit in su
Page: HOUSE_OVERSIGHT_012162 →Entities connected to both Joe Recarey and Dowling

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
United States
LOCATION
Lesley Groff
PERSONRoy Black
PERSON
Alexander Acosta
PERSON
Marc Rich
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONGerald Lefcourt
PERSONMaria Farmer
PERSONFBI
ORGANIZATION
Barry Diller
PERSON
Ken Starr
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION