Epstein Secrets

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 EFTA00185240 JAY P. LEFKOWITZ, ESQ. DECEMBER 13, 2007 PAGE 3 OF 5 already been submitted to the Office on several occ

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 EFTA00185240 JAY P.

esh your memory that Villafon• le tried to get Apetelo to pay for Cheri. to represent you 19 In the federal case? 20 A. 21 O. Do toe know if Detective Recesiby has Moan 22 with your hither? 23 24 9. Do you know if Detective tecerey has spoken 25 to your ategmother7 Pklagra; "‘ — MVPS Ouch ., 500W

mendment right against compelled self-incrimination in connection with civil litigation, a court can stay discovery or the entire civil case. Diaz'. Jenne, 2007 WL 624286 al (S.D. Fl. Feb. 23, 2007) (Cooke, J.). "However, 'the Constitution does not require a stay of civil proceedings pending the outco

10 tilde Phan( 9 11 ind 10 12 TARA A. MORGAN. ESQUIRE. TARA A. P124141GAN. PA 11 13 224 Datum SEM 12 DEPOSITION OF SAW 900 DETECTIVE JOSEPH RECAREY 14 West ids 33401 13 Plan. 14 15 Tuesday, April 27, 2010 1003 - 5:23 p.m. Is 16 17 Oo bd./gelthe De /W. Setiney Epsiesn: MEI IAN PIKE.

ory on any tape recording of this statement on 12 Q. This is page 20 of E:dtibit I, which is 12 January 9th with Ms. M., were you? 13 Detective Reearey's — 13 A. A tape recording? 14 MR. PIKE: If you would, could you please turn 14 Q. Yes. 15 to that page because there's some writing on this

r working on 10 the Epstein investigation? 11 A. Not that I'm aware of. 12 Q. Did he ever tell you that he had any 13 communications with Mr. Jenne, or Mr. Fandrey or 14 Mr. Fisten? 15 A. Not that fin aware of. 16 Q. And have you ever seen any note, report, 17 document, memorandum, e-mail

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

e 14-16; and Same objection as well as attorney-client privilege and instruct you not to answer. 198/21-23] Q: Did you ever authorize or direct Mr. Jenne to perform any investigation on the Epstein files? Id. at page 201; line 4-6. MR. SCAROLA: Same objection, same instruction. Id. at page 201; line

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

e 14-16; and Same objection as well as attorney-client privilege and instruct you not to answer. 198/21-23] Q: Did you ever authorize or direct Mr. Jenne to perform any investigation on the Epstein files? Id. at page 201; line 4-6. MR. SCAROLA: Same objection, same instruction. Id. at page 201; line