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that it captured images of :: others. (See probable cause affidavit at page 18). In particular, the probable cause affidavit notes that “on the first floor of the Epstein residence . . . [was] found two covert cameras hidden in clocks. One was located in the garage and the other located in the library area behind Epstein’s computer. . . . the computer’s hard drive was reviewed which showed several images of J and other witnesses interviewed. All of these images appeared to come from the camera positioned behind Epstein’s desk”. (/d.) Omitted from the Police Report and the probable cause affidavit is the fact that the PBPD had known since 2003 about the presence of the cameras, and the specific reason for their installation. The cameras were installed in 2003 after Epstein discovered that large sums of cash were missing from his home. Indeed, not only were the cameras installed at the suggestion of the PBPD, but the PBPD initially provided equipment that did not work and thereafter assisted in the installation of the equipment Epstein purchased. The cameras ultimately served their purpose and captured the image of former employee Juan Alessi, removing cash from Epstein’s briefcase after unlawfully entering the house. The recording of Alessi was turned over to the PBPD — indeed, to Det. Recarey himself. The characterization of the video equipment either as a surprise to the PBPD or as playing a part in the alleged sexual activity in Epstein’s home (even though none of the complainants ever made any mention of such equipment, or ever placed any activity in the locations of the cameras), is false and misleading and suggests an intention to portray the facts to suit a particular goal. Broken “Sex Toys” in Epstein’s Trash. The Police Report details police finding in Epstein’s trash what is described as pieces of “sex toys” and that these “discoveries” purportedly corroborate witness statements. Omitted from both the Police Report and the probable cause affidavit is the fact that during the course of executing the search warrant on Epstein’s home, the police realized that a key “sex toy” was in fact the broken handle of a salad server. Though the “sex toys” play a prominent role in the Police Report and probable cause affidavit, the Police Report was never amended to reflect the discovery of this new and highly relevant evidence. Failure to Consider Exculpatory or Impeaching Evidence. Other exculpatory and impeaching evidence known by the PBPD was omitted from the Police Report and probable cause affidavit by, in our view, manipulating the date the investigation was allegedly closed. According to the Police Report (at page 85), Det. Recarey “explained [to ASA Belohlavek] that the PBPD had concluded its case in December of 2005”. That assertion, which is false, conveniently resulted in the omission of all information adduced subsequent to that date. Thus, though the Police Report in fact contains information obtained after December 2005, the PBPD escaped having to consider, or even to include in the Police Report, the probable cause affidavit, or what it released to the public, all the exculpatory and impeaching evidence presented on behalf of Epstein, most of which was provided after December 2005. That evidence is listed below. 3 Public Records Request No. 19-372 DOJ-OGR-00033210