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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
d States v. Villegas, 899 F.2d 1324 (2d Cir. 1990) 115 EFTA00099964 United States v. Walker, 191 F.3d 326 (2d Cir. 1999) 70 United States v. Walsh, 194 F.3d. 37 (2d Cir. 1999) 228, 266, 271 United States v. Walters, 910 F.3d 11 (2d Cir. 2018) 152 United States v. Washington, 431 U.S. 181
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
ed States v. Villegas, 899 F.2d 1324 (2d Cir. 1990) 115 EFTA00077629 United States v. Walker, 191 F.3d 326 (2d Cir. 1999) 70 United States v. Walsh, 194 F.3d. 37 (2d Cir. 1999) 228, 266, 271 United States v. Walters, 910 F.3d 11 (2d Cir. 2018) 152 United States v. Washington, 431 U.S. 181
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
ed States v. Villegas, 899 F.2d 1324 (2d Cir. 1990) 115 EFTA00039444 United States v. Walker, 191 F.3d 326 (2d Cir. 1999) 70 United States v. Walsh, 194 F.3d. 37 (2d Cir. 1999) 228, 266, 271 United States v. Walters, 910 F.3d 11 (2d Cir. 2018) 152 United States v. Washington, 431 U.S. 181
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
2007) 114 United States v. Villegas, 899 F.2d 1324 (2d Cir. 1990) 82 United States v. Walker, 191 F.3d 326 (2d Cir. 1999) 48 United States v. Walsh, 194 F.3d. 37 (2d Cir. 1999) 151, 174, 179 United States v. Walters, 910 F.3d 11 (2d Cir. 2018) 105 United States v. Washington, 431 U.S. 181
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
ed States v. Villegas, 899 F.2d 1324 (2d Cir. 1990) 115 EFTA00103022 United States v. Walker, 191 F.3d 326 (2d Cir. 1999) 70 United States v. Walsh, 194 F.3d. 37 (2d Cir. 1999) 228, 266, 271 United States v. Walters, 910 F.3d 11 (2d Cir. 2018) 152 United States v. Washington, 431 U.S. 181
d before me this 1" day of May, 2006 by Det Joe Recarey, who is personally known to inc. Signature of Po
d stating that she had no direct contact with Epstein The foregoing instrument was sworn to or affirmed before me this l w day of May, 2006 by bet Joe Recarey, who is personally known to me. Signature of Police filet (F.S.S. 117.10) State of Florida Coun of Palm Beach Signatur Date: 05/01/2006 g Offi
ant; may I provide that to the 7 Court as well? 8 Your Honor, as you know, 9 Mr. Goldberger and I represent Mr. Epstein. 10 We have hired Ms. Walsh and Ms. Compiani as 11 appellate counsel to assist in the filing 12 of a writ of certiorari. I know that comes 13 as no surprise to the Court i
massage and at one point she climbed onto the massage The foregoing instrument was sworn to or affirmed before me this 1" day of May, 2006 by Pet Joe Reearey, who is personally known tome. Alt Signature of Police Office (F.S.S. 117.10) Date: 05/0 /2006 State of Florida County of Palm Be h Signatur> A
epartment - Probable Cause Affidavit of Det. Joe Recarey - Defendant dated May 1, 2006 A6 Palm Beach Sh
ant; may I provide that to the 7 Court as well? 8 Your Honor, as you know, 9 Mr. Goldberger and I represent Mr. Epstein. 10 We have hired Ms. Walsh and Ms. Compiani as 11 appellate counsel to assist in the filing 12 of a writ of certiorari. I know that comes 13 as no surprise to the Court i
Entities connected to both Joe Recarey and Walsh

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Joe Biden
PERSON
United States
LOCATION
George W. Bush
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Bradley Edwards
PERSON
Donald Trump
PERSON
Palm Beach Police Department
ORGANIZATION
Julie K. Brown
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSONJack Goldberger
PERSONFBI
ORGANIZATION
Palm Beach
LOCATION
Bill Clinton
PERSON
Scarlett Johansson
PERSON