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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
of limitations for such crimes through the lifetime of the victim. 30 EFTA00099997 the resurrection of time-barred prosecutions, in violation of the Ex Post Facto Clause.14 But that concern is entirely separate from extending the statute of limitations for live claims, which is what Congress did here. Critica
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
Leahy's comments indicate that Congress declined to add language that would allow for the resurrection of time-barred prosecutions, in violation of the Ex Post Facto Clause.14 But that conduct in 2000). Indeed, that is precisely what Congress authorized when it extended the statute of limitations for such crimes
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
Leahy's comments indicate that Congress declined to add language that would allow for the resurrection of time-barred prosecutions, in violation of the Ex Post Facto Clause.14 But that conduct in 2000). Indeed, that is precisely what Congress authorized when it extended the statute of limitations for such crimes
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
of limitations for such crimes through the lifetime of the victim. 30 EFTA00103055 the resurrection of time-barred prosecutions, in violation of the Ex Post Facto Clause.14 But that concern is entirely separate from extending the statute of limitations for live claims, which is what Congress did here. Critica
d of supplement. (Continued) has been turned been taken by ***************************NARRATIIE # 9 *************************** A Reported By: RECAREY, JOSEPH 10/07/05 Entered By.: ALTOMARO, NICKIE A, 10/10/05 On October 4, 2005, I made telephone contact witailigia who had left several messages o
ID # 8807, to accompany us and perform the role of photographing the scene and the items that may be taken into custody by the affiant, Detective Joseph Recarey, ID # 7915. My responsibility was to go through from the reading of the warrant to the final exit from the residence and perform a video recording
n Detective Recarey and I were the last two officers in the house. Upon securing the residence we met with the gentleman who identified himself to Detective Recarey as the lawyer for the defendant and he was informed that the residence was secured and that copies of the inventory return had been left on the fir
14 *******x****************** Reported By: DAWSON, MICHAEL C. 11/07/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 20, 2005, I assisted Defective Recarey in the execution of a search warrant at 358 El Brillo Way, Palm Beach, Florida, 33480. Upon the announcement of the search warrant, immediate conta
Case 9:08-cv-80736-KAM Document 361-39 Entered on FLSD Docket 02/10/2016 Page 4 of 6 so novel as to implicate the so-called "dear statement rule," the Ex Post Facto clause, or the Due Process clause. As with the other legal issues, Mr. =may elect to proceed with the case. Absence of coercion. With respect to 1
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 EFTA00289791 JAY RLEFKOATIZ, ESQ. DECEMBER 13, 2007 PAGE 3 OF 5 already been submitted to the Office on several occas
each Police Department's probable cause affidavit has never been filed with the Court. If, in fact, you are referring to the Ex Parts 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 exports, so no one should hat access to
Much of your letter reiterates the challenges to Detective Recarey's investigation that have EFTA00289791 JAY RLE
be 2 EFTA00289786 06/16/2008 11:16 FAI 06/18/08 FRI 11:09 FAX bliOS/006 1:9004 so novel as to implicate the so-called "clear statement rule," the Ex Post Facto clause, or the Due Process clause. As with the other legal issues, Mr. Acosta may elect to proceed with the case. Absence of coercion. With respect
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
ct future behavior *1039 and that the question is so vague as to be meaning- less. That calls into play the concept our Court of Appeals applied to the Ex Post Facto r Clause (albeit in a different con t from the present one) in United States Sutton, 521 F.2d 1385, 1390- (7th ir.1975) (quoting United State
Entities connected to both Joe Recarey and the Ex Post Facto

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Palm Beach Police Department
ORGANIZATION
George W. Bush
PERSON
Joe Biden
PERSONJack Goldberger
PERSON
Palm Beach
LOCATION
Alexander Acosta
PERSON
Prince Andrew
PERSONRoy Black
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSONGerald Lefcourt
PERSON
Barry Krischer
PERSON
Alfredo Rodriguez
PERSON
Kenneth Marra
PERSON