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

where sexual mores change over time, complicate the matter even further. See generally Richard A. Posner, Sex and Reason (1992). The history of the Mann Act confirms the caution with which the federal government should approach this entire area. For example, historically, the Act was used by some prosecu

m Gerald Lefcourt (Appendix A), you will see that most of the letter is an attack on the police report and probable cause affidavit drafted by Det. Joe Recarey from PBPD. Neither document is ideal and his interviews of the girls and other investigative steps had some problems (although did an incredibly in-

dn't wait" for her to turn 18 so that he could take them on trips. 52 EFTA00234568 Very early in the investigation, the FBI and I decided to put Recarey's police report and PC Affidavit to the side and to look at the case with fresh eyes. The facts discussed herein are based upon a personal review o

he Mann Act. Sections 2422 and 2423 are more recent additions, which focus on children. All three sections are sometimes jointly referred to as the Mann Act. 5 EFTA00234521 A. Violations of the Mann Act: 18 U.S.C. 8§ 2421-2423 1. Knowledge of Age Is Not Required. The Mann Act criminalizes travelin

of other deceased potential witnesses, including Epstein, Epstein's mother,- talent agent Michael Casey, and Palm Beach Police Department Detective Joseph Recarey. See Dkt. No. 138 at 8-11. The Court has previously considered and rejected the Defendant's claim of prejudice based on these absent witnesses. Maxw

nd Palm Beach Police Department Detective Joseph Recarey. See Dkt. No. 138 at 8-11. The Court has previous

the Defendant argues that testimony resulted in the "ultimate prejudice" because it led to the jury improperly convicting her on three of the four Mann Act counts. Maxwell Br. at 18. For the same reasons noted above, the Defendant was not prejudiced by the Court's response to the jury note because the

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

where sexual mores change over time, complicate the matter even further. See generally Richard A. Posner, Sex and Reason (1992). The history of the Mann Act confirms the caution with which the federal government should approach this entire area. For example, historically, the Act was used by some prosecu