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navailability o fJeffrey Epstein, Epstein 's mother, Michael Casey (the alleged agent of Minor Victim-1), and Palm Beach Police Department Detective Joseph Recarey. She contends that the loss of Epstein demonstrates actual prejudice because Epstein "would have" testified that the defendant did not engage in th
m Beach Police Department even began investigating Epstein in 2005. (Def. Mot. 7, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00100013 2018 respectively,
, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00100013 2018 respectively, would have testified, and that such testimony would have been exculpat
in this Indictment have told the USAO-SDNY. In sum, the defendant has not put "specific evidence" before this Court demonstrating that the loss of Detective Recarey's testimony, even if admissible, has caused her actual prejudice. Scala, 388 F. Supp. 2d at 400. The defendant next contends that had the Government
0, 2018 Email December 6, 2018 Email Feb m deb Transcript of April 22, 2016 Deposition Transcript of July 22, 2016 Deposition Affidavit of Dr. Bernard R. Siskin iv EFTA00099945 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. ofPlayers Computer Inc. v. Sta
unavailability of Jeffrey Epstein, Epstein's mother, Michael Casey (the alleged agent of Minor Victim-1), and Palm Beach Police Department Detective Joseph Recarey. She contends that the loss of Epstein demonstrates actual prejudice because Epstein "would have" testified that the defendant did not engage in th
m Beach Police Department even began investigating Epstein in 2005. (Def. Mot. 7, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00077678 2018 respectively,
, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00077678 2018 respectively, would have testified, and that such testimony would have been exculpat
in this Indictment have told the USAO-SDNY. In sum, the defendant has not put "specific evidence" before this Court demonstrating that the loss of Detective Recarey's testimony, even if admissible, has caused her actual prejudice. Scala, 388 F. Supp. 2d at 400. The defendant next contends that had the Government
dge Netburn Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of July 22, 2016 Deposition Exhibit 12: Affidavit of Dr. Bernard R. Siskin iv EFTA00077610 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. S
unavailability of Jeffrey Epstein, Epstein's mother, Michael Casey (the alleged agent of Minor Victim-1), and Palm Beach Police Department Detective Joseph Recarey. She contends that the loss of Epstein demonstrates actual prejudice because Epstein "would have" testified that the defendant did not engage in th
m Beach Police Department even began investigating Epstein in 2005. (Def. Mot. 7, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00039493 2018 respectively,
, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00039493 2018 respectively, would have testified, and that such testimony would have been exculpat
in this Indictment have told the USAO-SDNY. In sum, the defendant has not put "specific evidence" before this Court demonstrating that the loss of Detective Recarey's testimony, even if admissible, has caused her actual prejudice. Scala, 388 F. Supp. 2d at 400. The defendant next contends that had the Government
dge Netburn Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of July 22, 2016 Deposition Exhibit 12: Affidavit of Dr. Bernard R. Siskin iv EFTA00039425 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer, Inc. v. S
unavailability of Jeffrey Epstein, Epstein's mother, Michael Casey (the alleged agent of Minor Victim-1), and Palm Beach Police Department Detective Joseph Recarey. She contends that the loss of Epstein demonstrates actual prejudice because Epstein "would have" testified that the defendant did not engage in th
m Beach Police Department even began investigating Epstein in 2005. (Def. Mot. 7, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00103071 2018 respectively,
, Ex. D at i). The defendant's claims relating to Michael Casey and Detective Recarey fare no better. She again speculates that Casey and Detective Recarey, who passed away in August 2017 and May 46 EFTA00103071 2018 respectively, would have testified, and that such testimony would have been exculpat
in this Indictment have told the USAO-SDNY. In sum, the defendant has not put "specific evidence" before this Court demonstrating that the loss of Detective Recarey's testimony, even if admissible, has caused her actual prejudice. Scala, 388 F. Supp. 2d at 400. The defendant next contends that had the Government
udge Netbum Exhibit 10: Transcript of April 22, 2016 Deposition Exhibit 11: Transcript of July 22, 2016 Deposition Exhibit 12: Affidavit of Dr. Bernard R. Siskin iv EFTA00103003 TABLE OF AUTHORITIES Cases Albright v. Oliver, 510 U.S. 266 (1993) Andover Data Servs., a Div. of Players Computer; Inc. v. S
Entities connected to both Joe Recarey and Bernard R. Siskin

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
United States
LOCATION
George W. Bush
PERSON
Prince Andrew
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONFBI
ORGANIZATION
Ken Starr
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
Sarah Kellen
PERSON
Virginia Giuffre
PERSONMartin Weinberg
PERSON
Scarlett Johansson
PERSONNadia Marcinkova
PERSON