Epstein Secrets

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

74) 225, 227 vi EFTA00099947 Hemphill v. United States, 392 F.2d 45 (8th Cir. 1968) 268 Herring v. United States, 555 U.S. 135 (2009) 123 Howell v. Superintendent Rockview SCI, 939 F.3d 260 (2d Cir. 2019) 302 Huddleston v. United States, 485 U.S. 681 (1988) 254 In re Enter. Mort. Accepta

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

974) 225, 227 vi EFTA00077612 Hemphill v. United States, 392 F.2d 45 (8th Cir. 1968) 268 Herring v. United States, 555 U.S. 135 (2009) 123 Howell v. Superintendent Rockview SCI, 939 F.3d 260 (2d Cir. 2019) 302 Huddleston v. United States, 485 U.S. 681 (1988) 254 In re Enter. Mort. Accepta

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

974) 225, 227 vi EFTA00039427 Hemphill v. United States, 392 F.2d 45 (8th Cir. 1968) 268 Herring v. United States, 555 U.S. 135 (2009) 123 Howell v. Superintendent Rockview SCI, 939 F.3d 260 (2d Cir. 2019) 302 Huddleston v. United States, 485 U.S. 681 (1988) 254 In re Enter. Mort. Accepta

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

tes, 418 U.S. 87 (1974) 150, 151 Hemphill v. United States, 392 F.2d 45 (8th Cir. 1968) 176 Herring v. United States, 555 U.S. 135 (2009) 87 Howell v. Superintendent Rockview SCI, 939 F.3d 260 (2d Cir. 2019) 210 Huddleston v. United States, 485 U.S. 681 (1988) 166 In re Enter. Mort. Accepta

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

974) 225, 227 vi EFTA00103005 Hemphill v. United States, 392 F.2d 45 (8th Cir. 1968) 268 Herring v. United States, 555 U.S. 135 (2009) 123 Howell v. Superintendent Rockview Sc!, 939 F.3d 260 (2d Cir. 2019) 302 Huddleston v. United States, 485 U.S. 681 (1988) 254 In re Enter. Mort. Accepta

Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799415 Counsel for Epstein then examines Edwards regarding Officer Recarey: Q: What was the purpose of your conversation? Transcript of Deposition dated March 23, 2010, page 288; line 13-14. MR. SCAROLA: To the extent tha

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

s is protected by a privilege. I instruct him not to answer. Id. at page 287; line 3-6. Counsel for Epstein then examines Edwards regarding Officer Recarey: Q: What was the purpose of your conversation? Transcript of Deposition dated 14 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.