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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
elled 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 outcome of related criminal procee
tz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by the f
ershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by the f
each, FL 33401 Telephone: Facsimile: CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July , 2007, the foregoing document and the Declaration of Joseph Recarey will be served via hand delivery on Attorney Roy Black, counsel for Jeffrey Epstein. The same documents will be served on William Richey, counsel fo
an attorney does not render everything he does for or with the client privileged." Gutter v. E.I. DuPont de Nemours and Co. , 1998 WL 2017926, *1 (S.D. Fl. May 18, 1998) EFTA00211785 (citations omitted). If an attorney (or his agent) was doing something other than rendering legal advice, neither the
tz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by the f
ershowitz. Fa As explained in the Declaration of Joseph Recarey, Epstein knew of the state investigation by the f
500 South Australian Avenue, Suite 400 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July , 2007, the foregoing document and the Declaration of Joseph Recarey will be served via hand delivery on Attorney Roy Black, counsel for Jeffrey Epstein. The same documents will be served on William Richey, counsel fo
s an attorney does not render everything he does for or with the client privileged." Gutter I E.I. DuPont de Nemours and Co. , 1998 WL 2017926, *1 (S.D. Fl. May 18, 1998) EFTA00223001 (citations omitted). If an attorney (or his agent) was doing something other than rendering legal advice, neither the
eet. Excluding also removes the ammunition about Detective Recarey and alleged misrepresentations of EFTA00191645
rances that she wo treated as a victim, she insisted on full immunity before she would meet. Excluding also removes the ammunition about Detective Recarey and alleged misrepresentations of EFTA00191645 statements to Recarey. also was the person who instructed the girls to say they were 18. The evid
n 3142 (g). United States . King, 849 F.2d 485, 488 (11th Cir. 1988). Sciacca (unpublished opinion), Court File No. 03-80164-Cr-Hurley, at pp. 4-5 (S.D. Fl. Feb. 25, 2004). Here, the defendant's blatant disregard of the order of the Florida court regarding his contact with the victim shows his continu
Entities connected to both Joe Recarey and S.D. Fl

Jeffrey Epstein
PERSON
United States
LOCATION
Kenneth Marra
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONFBI
ORGANIZATIONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Palm Beach Police Department
ORGANIZATIONJane Doe
PERSONRoy Black
PERSON
Palm Beach
LOCATION
Prince Andrew
PERSONGerald Lefcourt
PERSONMaria Farmer
PERSON
Barry Diller
PERSON