Epstein Secrets

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

es1 Sims, 428 F.3d 945, 959 0th Cir. dealing with a minor was sufficient to make out the crime. See United States Root, 296 2005); United States I Helder, 452 F.3d 751 (8Ih Or. 2006); United States I Meek, 366 F.3d 705, 717-20 (0 Cir. 2004). Likewise, the Circuits have rejected void or vagueness, ove

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

me. See United States I Root, 296 F.3d 1222, 1227-32 (11th Cir. 2002); United States I Sims, 428 F.3d 945, 919 (10th Cir. 2005); United States I Helder, 452 F.3d 751 (8th Cir. 2006); United States Meek, 366 F.3d 705, 717-20 (9th Cir. 2004). Likewise, the Circuits have rejected void for vagueness,

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

ee also United States v. Root, 296 F.3d 1222, 1227- 28 (I11° Cir. 2002); United States v. Sims. 428 F.3d 945, 959 (10th Cir. 2005); United States v. Helder, 452 F.3d 751 (8th Cir. 2006); United States v. Meek, 366 F.3d 705, 717- 20 (9th Cir. 2004). There arc approximately two dozen Eleventh Circuit case