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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
United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 240, 268 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 37 United States v. Johnson, 21 F. Supp. 2d 329
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
46 United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 240, 268 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 37 United States v. Johnson, 21 F. Supp. 2d 329
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
46 United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 240, 268 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 37 United States v. Johnson, 21 F. Supp. 2d 329
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
Jenkins, 727 F. App'x 732 (2d Cir. 2018) 130 xiv EFTA00095081 United States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 110 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 159, 176 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 28 United States v. Johnson, 21 F. Supp. 2d 329
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
United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d 1488 (9th Cir. 1992) 162 United States v. Jimenez, 824 F. Supp. 351 (S.D.N.Y. 1993) 240, 268 United States v. Johns, 15 F.3d 740 (8th Cir. 1994) 37 United States v. Johnson, 21 F. Supp. 2d 329
ble and triple hearsay directed toward filing charges against a defendant named See A.6 (Palm Beach Police Department - Probable Cause Affidavit of J. Recarey, dated May 1, 2006). Furthermore, the Florida State Attorney msly rejected the claims asserted in the police affidavit (which sought to charge as
lice Department - Probable Cause Affidavit of J. Recarey, dated May 1, 2006). Furthermore, the Florida Sta
1268 (4th Dep't 2007) 31 People v. Ferguson, 53 A.D.3d 571 (2d Dep't 2008) 39 People v. Gilbert, 78 A.D.3d 1584 (4th Dep't 2010) 47 People v. Jimenez, 178 Misc. 2d 319, 679 N.Y.S.2d 510 (Sup. Ct. Kings Cty. 1998) 18 People v. Johnson, 11 N.Y.3d 416 (2008) 18 People v. Jordan, 31 A.D.3d 1196
hearsay directed toward filing charges against a defendant named Sarah Kellen. See A.6 (Palm Beach Police Department - Probable Cause Affidavit of J. Recarey, dated May 1, 2006). Furthermore, the Florida State Attorney expressly rejected the claims asserted in the police affidavit (which sought to charge
lice Department - Probable Cause Affidavit of J. Recarey, dated May 1, 2006). Furthermore, the Florida Sta
1268 (4th Dep't 2007) 31 People v. Ferguson, 53 A.D.3d 571 (2d Dep't 2008) 39 People v. Gilbert, 78 A.D.3d 1584 (4th Dep't 2010) 47 People v. Jimenez, 178 Misc. 2d 319, 679 N.Y.S.2d 510 (Sup. Ct. Kings Cty. 1998) 18 People v. Johnson, 11 N.Y.3d 416 (2008) 18 People v. Jordan, 31 A.D.3d 1196
t submitted by police to the Florida prosecutor. See A.65 (Board Recommendation); A.6 (Palm Beach Police Department - Probable Cause Affidavit of J. Recarey, dated May 1, 2006). The allegations, even when aggregated, were not deemed by the Florida prosecutor who reviewed them to constitute sufficient "p
lice Department - Probable Cause Affidavit of J. Recarey, dated May 1, 2006). The allegations, even when
268 (4th Dep't 2007) 31 People v. Ferguson., 53 A.D.3d 571 (2d Dep't 2008) 39 People v. Gilbert, 78 A.D.3d 1584 (4th Dep't 2010) 47 People v. Jimenez, 178 Misc. 2d 319, 679 N.Y. S.2d 510 (Sup. Ct. Kings Cty. 1998) 18 People v. Johnson, 11 N.Y.3d 416 (2008) 18 People v. Jordan, 31 A.D.3d 1196
Entities connected to both Joe Recarey and Jimenez

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
United States
LOCATION
George W. Bush
PERSON
Bradley Edwards
PERSON
Joe Biden
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Palm Beach
LOCATION
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Alfredo Rodriguez
PERSONFBI
ORGANIZATION
Donald Trump
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSONthe Southern District
LOCATION