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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
00099955 United States v. Green, 981 F.3d 945 (11th Cir. 2020) 124 United States v. Greer, 956 F. Supp. 525 (D. Vt. 1997) 72 United States v. Griffith, No. 99 Cr. (HB), 2000 WL 1253265 (S.D.N.Y. Sept. 5, 2000) 264 United States v. Guerrier, 18 Cr. 284 (JSR) 286 United States v. Guzman, 337 F.
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
A00095080 United States v. Green, 981 F.3d 945 (11th Cir. 2020) 87 United States v. Greer, 956 F. Supp. 525 (D. Vt. 1997) 49 United States v. Griffith, 99 Cr. (HB), 2000 WL 1253265 (S.D.N.Y. Sept. 5, 2000) 172 United States v. Guzman, 337 F. Supp. 140 (S.D.N.Y. 1972) 208 United States v. Halkb
ce searched the home as part of their investigation.M The court documents record that a search of Epstein's residence by Palm Beach Police detective Joseph Reearey in 2005 uncovered an incriminating Amazon receipt containing books on S&M. The books he ordered are titled: SILT Ica: A Realistic Introduction, Slav
Ministra. Rudd was elected to the Australian House of ISsentatives at the 1998 federal election, as a member ofparlianient (MP) for the division of Griffith. He Was promoted to the shadow cabinet in 2001 as Shadow Minister for Foreign Affairs. In December 2006, he adeated Kim Beads in a leadership spil
h Circuit soundly rejected the argument, citing the other circuits reaching the same conclusion. Jones , 471 F.3d at 538-39 (citing United States v. Griffith , 284 F.3d 338, 351 (2d Cir. 2002); United States v. Taylor , 239 F.3d 994, 997 (9th Cir. 2001); United States v. Scisum , 32 F.3d 1479, 1485-86 (1
Page: EFTA02857763_p3 →om Gerald Lefcourt (Appendix A), you will see that most of the letter is an attack on the police report and probable cause affidavit drafted by Det. Joe Recarey from PBPD. Neither document is ideal and his interviews of the girls and other investigative steps had some problems (although did an incredibly in
Page: EFTA02857763_p45 →rassment. (It did, however, lead other girls to come forward and tell their stories.) Very early in the investigation, the FBI and I decided to put Recarey's police report and PC Affidavit to the side and to look at the case with fresh eyes. The facts discussed herein are based upon a personal review o
Page: EFTA02857763_p45 →Entities connected to both Joe Recarey and Griffith

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSONLeon Black
PERSON
United States
LOCATION
George W. Bush
PERSON
Bradley Edwards
PERSON
Joe Biden
PERSON
Palm Beach Police Department
ORGANIZATIONJack Goldberger
PERSON
Prince Andrew
PERSON
Palm Beach
LOCATIONRoy Black
PERSONJane Doe
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATIONGerald Lefcourt
PERSON
Julie K. Brown
PERSONMaria Farmer
PERSON
Alfredo Rodriguez
PERSON