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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
gainst strict liability, especially since it applies in eases whcre there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's decision in United States Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language"
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
gainst strict liability, especially since it applies in cases where there is no sexual contact at all with any person, let alone with a real minor. The Eleventh Circuit's' decision in United States Murrell, supra, reflects this same understanding of the statute. The Murrell court wrote that, under the "plain language"
taped interviews conducted largely by Detective Recarey of the Palm Beach police. These transcripts were
scripts of taped interviews conducted largely by Detective Recarey of the Palm Beach police. These transcripts were
nduce criminal sexual activity at some point after such use, or if the defendant does not actually induce during the use, § 2422(b) does not apply. The Eleventh Circuit's Pattern Jury Instructions recognize as much. According to those Instructions, the Government must prove beyond a reasonable doubt: First: That the
Entities connected to both Joe Recarey and The Eleventh Circuit's

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSONLeon Black
PERSON
George W. Bush
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Palm Beach Police Department
ORGANIZATIONJack Goldberger
PERSONRoy Black
PERSON
Palm Beach
LOCATION
Prince Andrew
PERSONJane Doe
PERSON
Michael Reiter
PERSONGerald Lefcourt
PERSON
Alexander Acosta
PERSON
Alfredo Rodriguez
PERSON
Barry Krischer
PERSON
Department of Justice
ORGANIZATION
Palm Beach County
LOCATION
Kenneth Marra
PERSON