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live) 2. (video) 3. (live) 4. Rinaldo Rizzo (live) 5. Tony Figueroa (video) 6. (live) 7. (live) 8. (video) 9. (video) 10. Detective Recarey (video) 11. Alexander Hall (voice recording) 12. Jean Luc Brunel (live) 13. Jeffrey Epstein (video) 14. (live) 15. Alfredo Rodriquez (video
iller (video) 27. Frederick M. Miller, M.D. (live) 4800 Cherry Creek South Drive Denver, CO 80246 28. Dr. Steven Olson (video) 29. (video) 30. Joseph Recarey (video) 31. Sky Roberts (video) 32. David Rodgers (video) 16 EFTA00792771 33. Gregory B. Taylor (live) Kyle D. Jacobson Taylor, Jacobson & As
live) 7. (live) 8. (video) 9. (video) 10. Detective Recarey (video) 11. Alexander Hall (voice recording) 1
d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of
28. Dr. Steven Olson (video) 29. IM 30. Joseph Recarey (video) 31. Sky Roberts (video) 32. David Rodge
24. Peter Kent live 25. Guy Louthan (live) 26. Lynn Miller (video) 27. Frederick M. Miller, M.D. (live) 28. Dr. Steven Olson (video) 29. IM 30. Joseph Recarey (video) 31. Sky Roberts (video) 32. David Rodgers (video) 16 EFTA00617411 35. Katie Vaughan-Edwards (live) Orchard End Fittleton 36. Vicky W
d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of
I think in 7 2005 and going through 2006. The detective initially assigned 8 to the case was a woman named Michelle Pagan, and then 9 Detective Recarey took over the investigation from Ms. Pagan. 10 There were a number of things, according to the reports -- 11 although we don't really have any act
ive you that as the backdrop, your Honor, because 17 then next what seems to happen is very curious, in my 18 experience, and was testified to by Detective Recarey. The 19 police get crossways with the state attorney's office in 20 Florida, and there is a complete distrust between the two 21 agencies. As a
fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the
nning I think in 7 2005 and going through 2006. The detective initially assigned 8 to the case was a woman named Michelle Pagan, and then 9 Detective Recarey took over the investigation from Ms. Pagan. 1) There were a number of things, according to the reports -- ai although we don't really have any actual
I give you that as the backdrop, your Honor, because Ly then next what seems to happen is very curious, in my 18 experience, and was testified to by Detective Recarey. The 19 police get crossways with the state attorney's office in 20 Florida, and there is a complete distrust between the two 21. agencies. As a resu
ing offered for the truth of the matter asserted, we want to offer it to show Ms. Maxwell's state of mind when she issued her statement through Mr. Barden and Mr. Gow. So the huge problem with that, your Honor, which Ww ' ve already dealt with, is, Ms. Maxwell has no knowledge of what's in these poli
his case. There is zero evidence that will be produced at trial to put Ms. Maxwell in any of this, in any of the investigation. The lead detective, Recarey, never spoke to her, never tried to call her. And when I asked him questions about, you know, what did you know about Ms. Maxwell when you were do
hey have the burden of proving that what Ms. Maxwell said was false. That's what is at issue. We have to look at Ms. Maxwell's statement issued by Barden and Gow and then go backwards from there. And the burden on the plaintiff is proving falsity of that statement. It is not the situation where -- wh
se. There is zero evidence that will be 3 produced at trial to put Ms. Maxwell in any of this, in any of 4 the investigation. The lead detective, Recarey, never spoke to 5 her, never tried to call her. And when I asked him questions 6 about, you know, what did you know about Ms. Maxwell when you 7
the burden of proving that what Ms. Maxwell said was false. 16 That's what is at issue. We have to look at Ms. Maxwell's 17 statement issued by Barden and Gow and then go backwards from 18 there. And the burden on the plaintiff is proving falsity of 19 that statement. It is not the situation whe
Entities connected to both Joe Recarey and Barden

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
United States
LOCATIONJack Goldberger
PERSON
Prince Andrew
PERSON
Alexander Acosta
PERSONMaria Farmer
PERSON
Alfredo Rodriguez
PERSON
Kenneth Marra
PERSON
Juan Alessi
PERSON
Virginia Giuffre
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
Jean-Luc Brunel
PERSONMartin Weinberg
PERSON
The Palm Beach Post
ORGANIZATION
David Rodgers
PERSON