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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. Myers, 692 F.2d 823 (2d Cir. 1982) 153, 161 United States v. Napolitano, 552 F. Supp. 465 (S.D.N.Y. 1982) 241 United States v. Nejad, No. 18 Cr. 224 (AJN), 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 225 United States v. Nersesian, 824 F.2d 1294 (2d Cir. 1987) 233 EFTA00099959
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
United States v. Myers, 692 F.2d 823 (2d Cir. 1982) 153, 161 United States v. Napolitano, 552 F. Supp. 465 (S.D.N.Y. 1982) 241 United States v. Nejad, No. 18 Cr. 224 (MN), 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 225 United States v. Nemesian, 824 F.2d 1294 (2d Cir. 1987) 233 xviii EFTA000776
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
United States v. Myers, 692 F.2d 823 (2d Cir. 1982) 153, 161 United States v. Napolitano, 552 F. Supp. 465 (S.D.N.Y. 1982) 241 United States v. Nejad, No. 18 Cr. 224 (MN), 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 225 United States v. Nemesian, 824 F.2d 1294 (2d Cir. 1987) 233 xviii EFTA000394
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
United States v. Myers, 692 F.2d 823 (2d Cir. 1982) 105, 110 United States v. Napolitano, 552 F. Supp. 465 (S.D.N.Y. 1982) 159 United States v. Nejad, 18 Cr. 224 (AJN), 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 150 United States v. Nemesian, 824 F.2d 1294 (2d Cir. 1987) 154 United States v. Nit
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. Myers, 692 F.2d 823 (2d Cir. 1982) 153, 161 United States v. Napolitano, 552 F. Supp. 465 (S.D.N.Y. 1982) 241 United States v. Nejad, No. 18 Cr. 224 (MN), 2019 WL 6702361 (S.D.N.Y. Dec. 9, 2019) 225 United States v. Nersesian, 824 F.2d 1294 (2d Cir. 1987) 233 xviii EFTA00103
Entities connected to both Joe Recarey and Nejad

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Bradley Edwards
PERSON
George W. Bush
PERSON
Palm Beach
LOCATIONFBI
ORGANIZATIONJane Doe
PERSON
Prince Andrew
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Ken Starr
PERSON
Scarlett Johansson
PERSON
Virginia Giuffre
PERSONMartin Weinberg
PERSON
Sarah Kellen
PERSON
Adriana Ross
PERSON