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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
Corp., 567 U.S. 142 (2012) Colorado v. Connelly, 51 479 U.S. 157 (1986) 139, 141, 142 Colorado v. Spring, 479 U.S. 564 (1987) 138 County of Sacramento v. Lewis, 523 U.S. 833 (1998) 152 Cruz v. Maypa, 773 F.3d 138 (4th Cir. 2014) 43 Davis v. United States, 564 U.S. 229 (2011) 122 Doe I v. Un
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
Corp., 567 U.S. 142 (2012) Colorado v. Connelly, 51 479 U.S. 157 (1986) 139, 141, 142 Colorado v. Spring, 479 U.S. 564 (1987) 138 County of Sacramento v. Lewis, 523 U.S. 833 (1998) 152 Cruz v. Maypa, 773 F.3d 138 (4th Cir. 2014) 43 Davis v. United States, 564 U.S. 229 (2011) 122 Doe 1 v. Un
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
Corp., 567 U.S. 142 (2012) Colorado v. Connelly, 51 479 U.S. 157 (1986) 139, 141, 142 Colorado v. Spring, 479 U.S. 564 (1987) 138 County of Sacramento v. Lewis, 523 U.S. 833 (1998) 152 Cruz v. Maypa, 773 F.3d 138 (4th Cir. 2014) 43 Davis v. United States, 564 U.S. 229 (2011) 122 Doe 1 v. Un
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
cham Corp., 567 U.S. 142 (2012) 37 Colorado v. Connelly, 479 U.S. 157 (1986) 97, 98, 99 Colorado v. Spring, 479 U.S. 564 (1987) 97 County of Sacramento v. Lewis, 523 U.S. 833 (1998) Cruz v. Maypa, 773 F.3d 138 (4th Cir. 2014) Davis v. United States, 564 U.S. 229 (2011) Doe No. 1. v. United Stat
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
Corp., 567 U.S. 142 (2012) Colorado v. Connelly, 51 479 U.S. 157 (1986) 139, 141, 142 Colorado v. Spring, 479 U.S. 564 (1987) 138 County of Sacramento v. Lewis, 523 U.S. 833 (1998) 152 Cruz v. Maypa, 773 F.3d 138 (4th Cir. 2014) 43 Davis v. United States, 564 U.S. 229 (2011) 122 Doe 1 v. Un
same things that you had asked me to do earlier is improper meddling in civil litigation. Much of your letter reiterates the challenges to Detective Recarey's investigation that have EFTA00799653 Case 9:08-cv-80736-KAM Document 403-19 Entered on FLED Docket 06/02/2017 Page 50 of 176 JAY P. LEFKOWITZ,
each Police Department's probable cause affidavit has never been filed with the Court. If, in fact, you are referring to the Ex Parte Declaration of Joseph Recarey that was filed in response to the motion to quash the grand jury subpoena, it was filed both under seal and ex parte, so no one should have access
Much of your letter reiterates the challenges to Detective Recarey's investigation that have EFTA00799653 Case 9:
ed from the University of California at Berkeley School of Law (Boalt Hall) in 1993. After serving as a judicial clerk to the Hon. David F. Levi in Sacramento, California, I was admitted to practice in California in 1995. I also am admitted to practice in all courts of the states of Minnesota and Florida,
State Attorney's Office was likely to do nothing about Epstein, approached the FBI, who, in turn, approached me. We met with the police detective, Joe Recarey, and discussed the investigation. When the State Attorney's Office EFTA00208240 presented the case to a grand jury (an extremely unusual step for
oached me. We met with the police detective, Joe Recarey, and discussed the investigation. When the State
at Berkeley School of Law (Boalt Hall) in 1993. Following graduation, I served as a judicial clerk to United States District Judge David F. Levi in Sacramento, California. After my clerkship, I worked at the law firms of Morrison & Foerster in San Francisco, California; Rosen, Bien & Asaro in San Francisc
estigation of Clinton’s relationship with an intern, would play rough. When the Palm Beach police started to identify victims, according to Detective Joe Recarey’s report, Dershowitz began sending the detective Facebook and MySpace posts to demonstrate that some of these girls were no angels. Reiter's deposition
eposition also states that he heard from local private investigators that Dershowitz had launched background checks on both the police chief and Det. Recarey. Dershowitz denies all of that. According to Reiter, both he and Recarey also became aware that they were under surveillance for several months, with
was a troubled teenager, whose slender figure, delicate complexion, hesitant voice and soulful blue eyes made her look young for her years. Born in Sacramento, California, in August 1983, Virginia spent her early years on a small ranch on the West Coast of America. This seemingly idyllic childhood ended wh
stigation of Clinton's relationship with an intern, would play rough. When the Palm Beach police started to identify victims, according to Detective Joe Recarey's report, Dershowitz began sending the detective Facebook and MySpace posts to demonstrate that some of these girls were no angels. Reiter's depositi
position also states that he heard from local private investigators that Dershowitz had launched background checks on both the police chief and Det. Recarey. Dershowitz denies all of that. According to Reiter, both he and Recarey also became aware that they were under surveillance for several months, wit
was a troubled teenager, whose slender figure, delicate complexion, hesitant voice and soulful blue eyes made her look young for her years. Born in Sacramento, California, in August 1983, Virginia spent her early years on a small ranch on the West Coast of America. This seemingly idyllic childhood ended w
re me this 20 day of September, 2005 by Det. Joe Recarey ,who is personally known to me. Signature of Pol
Haley Robson had worked for him for many years. The foregoing instrument was sworn to or affirmed before me this 20 day of September, 2005 by Det. Joe Recarey ,who is personally known to me. Signature of Police Officer (F.S.S. 117.10) Pagel of 4 State of Florida County of Palm Beach Signature/ Arrestin
event - to the tune of $15,917 - on Richardson's behalf. Former Vice President Al Gore was the featured guest at the event. The Maloofs own the Sacramento Kings basketball team and the Palms Casino and Resort in Las Vegas, Nev. The Maloofs also donated a $1,500 trip to its Las Vegas resort as an a
Entities connected to both Joe Recarey and Sacramento

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