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Information allegedly occurred. And as made abundantly clear by the attached excerpis rom M.'s November 8, 2005 interview with Palm Beach Detective Joseph Recarey, M. she was certainly 17 by the time events "escalated" from massages to sexual conduct: • Tr. 2:5-15 M . stating that her date of birth is Oct
that her date of birth is October 10, 1987, which would have made her two da s short of 18 ears and one month old when she was interviewed by Det. Recarey on • Tr. 3:15-20 (M. stating that she first heard about Epstein from a friend "about a year ago"). • Tr. 5:14-23 ( . stating that after meeting
bout this matter and your position on the SORA hearing in advance of our scheduled court date on November 9th. Sincerely, Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci JPL/slm Attachments EFTA00723428
Information allegedly occurred. And as made abundantly clear by the attached exce is rom M.'s November 8, 2005 interview with Palm Beach Detective Joseph Recarey,. was certainly 17 by the time events "escalated" from massages to sexual conduct: • Exhibit A, Tr. 2:5-15 . statin that her date of birth is •
♦. stating that after meeting Epstein for the first time, she "didn't go again for about two months or so"). • Exhibit A, Tr. 6:13-22 (♦. telling Recarey that she saw Epstein approximately 15 times in total, and "things escalated" as time went on). Furthermore, the record is undisputed that M. was at
bout this matter and your position on the SORA hearing in advance of our scheduled court date on November 9th. Sincerely, Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci JPL/slm Attachments EFTA00723438
Information allegedly occurred. And as made abundantly clear by the attached exceris rom M.'s November 8, 2005 interview with Palm Beach Detective Joseph Recarey, she-was certainly 17 by the time events "escalated" from massages to sexual conduct: • Exhibit A. Tr. 2:5-15 stating that her date of birth is
"escalated" from massages to sexual conduct: • Exhibit A. Tr. 2:5-15 stating that her date of birth is would have made her interviewed by Det. Recarey on November 8, 2005). when she was which • Exhibit A, Tr. 3:15-20 (Ell. stating that she first heard about Epstein from a friend "about a year
bout this matter and your position on the SORA hearing in advance of our scheduled court date on November 9th. Sincerely, Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci JPL,/slm Attachments EFTA00731241
rior to the SORA hearing, the actual transcripts of the interviews on which the Board materials were purportedly based reveal that Palm Beach Det. Joseph Recarey, the affiant of the Probable Cause Affidavit, inaccurately summarized and repeatedly mischaracterized information that he swore under oath came fro
ear-old victim" in the Probable Cause Affidavit and the Board's Case Summary, the actual transcripts of A.D.'s November 8, 2005 interview with Det. Recarey make clear that A.D. was indisputably 17 by the time events "escalated" from massages to "sexual conduct," as defined under New York's Penal Law:
level should be recalculated in accordance with the law. September 16, 2011 Respectfully submitted, /s/ Jay P. Lefkowitz Jay P. Lefkowitz, P.C. Sandra Lynn Musumeci KIRICLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone Facsimile: Counsel for Defendant-Appellant Jeffrey E. Epstein 4
home. We know that lead state police officers -- Detective Recarey and Police Chief Michael Reiter -- complained th
t, it appears that Epstein was tipped off before the execution of a search warrant at his home. We know that lead state police officers -- Detective Recarey and Police Chief Michael Reiter -- complained that the house was "sanitized" by the time they arrived to serve a search warrant for child pornograp
program (McAfee Enterprise 8.5 Virus Scan, updated as of March 9, 2009) and, according to the program, are free of viruses. Jay P. efkowitz, P.C. Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone; Facsimile: EFTA00232718 SUPREME COURT FOR THE STATE OF NEW YORK
t submitted by police to the Florida prosecutor. See A.65 (Board Recommendation); A.6 (Palm Beach Police Department - Probable Cause Affidavit of J. Recarey, dated May 1, 2006). The allegations, even when aggregated, were not deemed by the Florida prosecutor who reviewed them to constitute sufficient "p
lice Department - Probable Cause Affidavit of J. Recarey, dated May 1, 2006). The allegations, even when
g evidence, to wit, the undisputed conduct encompassed by Appellant's registerable crime of conviction. February 22, 2011 Respectfully submitted, Sandra Lynn Musumeci KIRKLAND & ELLIS LLP 601 Lexington Avenue New York, New York 10022 Telephone: Facsimile: Counsel for Defendant-Appellant Jeffrey E. Epstein E
Entities connected to both Joe Recarey and Sandra Lynn Musumeci

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSONLeon Black
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
George W. Bush
PERSON
United States
LOCATIONRoy Black
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Palm Beach County
LOCATION
Department of Justice
ORGANIZATION
Kenneth Marra
PERSONFBI
ORGANIZATION
New York
LOCATION
Jay Lefkowitz
PERSON
Ken Starr
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATIONMartin Weinberg
PERSON