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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
v EFTA00099956 United States v. Israel, 05 Cr. 1039 (CM) 286 United States v. Jackman, 46 F.3d 1240 (2d Cir. 1995) 300, 301 United States v. Jeffries, 405 F.3d 682 (8th Cir. 2005) 33,37,38,46 United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d 1
Falter, 23 F.3d at 425-26). And other circuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Falter establish that Congress may retroactivel
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
v EFTA00077621 United States v. Israel, 05 Cr. 1039 (CM) 286 United States v. Jackman, 46 F.3d 1240 (2d Cir. 1995) 300, 301 United States v. Jeffries, 405 F.3d 682 (8th Cir. 2005) 33, 37, 38, 46 United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d
g Faker, 23 F.3d at 425-26). And other circuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Faker establish that Congress may retroactively
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
v EFTA00039436 United States v. Israel, 05 Cr. 1039 (CM) 286 United States v. Jackman, 46 F.3d 1240 (2d Cir. 1995) 300, 301 United States v. Jeffries, 405 F.3d 682 (8th Cir. 2005) 33, 37, 38, 46 United States v. Jenkins, 727 F. App'x 732 (2d Cir. 2018) 194 United States v. Jennings, 960 F.2d
g Faker, 23 F.3d at 425-26). And other circuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Faker establish that Congress may retroactively
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
Falter, 23 F.3d at 425-26). And other circuits have emphasized this distinction in the context of Section 3283. Leo Sure Chief, 438 F.3d, at 922-25; Jeffries, 405 F.3d 685. Read together, the Second Circuit's decisions in Weingarten, Vernon, Enterprise, and Falter establish that Congress may retroactivel
Entities connected to both Joe Recarey and Jeffries

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
United States
LOCATIONLeon Black
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Joe Biden
PERSON
Prince Andrew
PERSONFBI
ORGANIZATIONMaria Farmer
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Barry Diller
PERSON
Julie K. Brown
PERSON
Ken Starr
PERSON
Virginia Giuffre
PERSON