Epstein Secrets

on, of the persons named below, at the time, on the date, at the hour of the place indicated: NAME DATE AND TIME PLACE OF TAKING DEPOSITON Det. Joseph Recarey do Joanne M. O'Connor, Esq. Jones, Foster, Johnson & Stubbs, P.A. 505 S. Flagler Drive, #1100 West Palm Beach, FL 33401 February 25, 2010 © 9:

AND TIME PLACE OF TAKING DEPOSITON Det. Joseph Recarey do Joanne M. O'Connor, Esq. Jones, Foster, John

v. JEFFREY EPSTEIN, Defendant. Plaintiff, PLAINTIFF'S CROSS NOTICE OF DEPOSITION OF DETECTIVE JOSEPH RECARY PLEASE TAKE NOTICE that plaintiff, E.W., will take the deposition by oral examination, of the persons named below, at the time, on the date, at the hour of the place indicated: NAME DAT

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

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

reet, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799405 lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., has Mr. Howell participated in the case; that is, has he done work on the case? Id. at page 90; lines 20-23. A: Yes. Id. at page 90; line 24. Q:

olice Department. See, e.g., Police Detective Joe Recarey Depo. at 281, Jane Doe No. 2'. Epstein, No. 9:08

stein, No. 502008CA037319 XXXX-MB-AB (Palm Beach Cty. Cir. Ct. Nov. 23, 2009) (excerpts attached as Exhibit 28); see also Depo. of Police Detective Joe Recarey at 301-302 and 309-10, Jane Doe No. 2'. Epstein, No. 9:08-cv-80119-ICAM (S.D. Fla. Mar. 19, 2010) (excerpts attached as Exhibit 29) Later, Dershowi

z] who you know to have stayed at Jeffery Epstein's house on many occasions, correct? And also somebody who you know to have been at the house when E.W. was in Jeffrey Epstein's bedroom getting sexually abused, correct? 26 Of course, in a proceeding such as this one, the victims are entitled to an i

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

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

Attorney-Client and work-product privileges. Id. at page 89; lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., 3 It is significant to note that other jurisdictions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iow

l during their research. By then, relations between police and prosecutors were fraying. At a key meeting with prosecutors and the defense, Detective Joseph Recarey, the lead, investigator, was a no-show, according to Epsteins attorney. "The embarrassment on the.prosecutor’s face was evident when the police offic

rassment on the.prosecutor’s face was evident when the police officer never showed up for the meeting,” attorneyJack Goldberger said. Later in April, Recarey walked into a prosecutor’s office at the state attorney’s office and learned the case was taking an unexpected turn. The prosecutor, Lanna Belohlavek

h to do so today. "It.is against public policy for these documents to be have been sealed and hidden from public scrutiny. As a member of the public, E.W. has a right to have these documents unsealed," wrote former CircuitJudge Bill Berger, now in private practice-and representing one ofthe women. The P