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on Jeff was unable to touch her buttocks". There is no mention in her There were three Probable Cause Affidavits prepared and executed by Detective Recarey on the same date. The affidavits arc in all material respects identical and we here refer to the one concerning Epstein. It is annexed at Tab 2. Be
ed behind Epstein's desk". Clearly omitted from both the Police Report and the Probable Cause Affidavit is the fact that the PBPD, and specifically Detective Recarey, knew about the cameras since the cameras were installed in 2003, with the help of the PBPD, to address the then of cash from Epstein's home. This
een. I'm 19 now this last March." (Sworn Statement of 10/12/05). 4 In addition to giving a sworn statement at the PBPD Station, conversations with Detective Recarey while being transported to and from the station were also recorded, This excerpt is taken from the recording of ;raveling from the station. 08-807
ment via the intemet. See H.R. Conf. Rep. No. 104-458, at 193 (1996), quoted in United States' Searcy, 418 F.3d 1193, 1197 (l Cir. 2005); see also K. Seto, "Note: flow Should Legislation Deal with Children and the Victims and Perpetrators of Cyberstalkingr 9 Cardoso Women's L.J. 67 (2002). In enactin
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
via the Internet. See H.R. Conf. Rep. No. 104-458, at 193 (1996), quoted in United States ' Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005); see also K. Seto, "Note: How Should Legislation Deal with Children and the Victims and Perpetrators of Cyberstalking?" 9 Cardozo Women's L.J. 67 (2002). In enactin
tried to hide something from the reviewers is false. I also take issue with the duplicity of stating that we must accept as true those parts of the Recarey reports and witness statements that you like and we must accept as false those parts that you do not like. You and your co-counsel also impressed u
7, 2007 Page 7 See United Sates v. Searcy 418 F.3d 1193, 1197 (11'h Cir. 2005) (citing H.R. Rep. No. 104.458, at 193 (1996) (Conf.Rep.)). See also K. Seto, Note; How Should Lepislation Deal with Children and the Victims and Perpetrators of Cyberstalking? 9 Cardozo Women's L.J. 67 (2002). In enacting
Entities connected to both Joe Recarey and K. Seto

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSONLeon Black
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Palm Beach Police Department
ORGANIZATION
Joe Biden
PERSONJack Goldberger
PERSONRoy Black
PERSON
Palm Beach
LOCATIONGerald Lefcourt
PERSONJane Doe
PERSON
Prince Andrew
PERSON
Alexander Acosta
PERSON
Barry Krischer
PERSON
Alfredo Rodriguez
PERSON
Palm Beach County
LOCATION
Kenneth Marra
PERSON
Barry Diller
PERSON