EFTA00298214

Page 320 Page 322 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 1 APPEARANCES: INAND FORPALMBEACHCOUNTY,FLORIDA 2 On behalf°flaw Dora 1 through 8: 3 JESSICA ARBOURESQUIRE 2 CASE No.50200SCA0373193000CMB AB utatmusitirt & P.A. 3 1820513ismne Boulevard B.B. Susie 2218 4 Miami, Plaintiff Phone S 1, 7 Oa behalf of the Plaintiff, Jame Doe No. IL 6 ws- VOLUME al OF IV 8 ISIDRO MAKIJEI.GARCIA, ESQUIRE GARCIA, MAINS& BOO-RINGER 9 224 Dan Awnuo Suite 90) West tilde 33401 Dcfaxlinta. 10 Phan( 9 11 ind 10 12 TARA A. MORGAN. ESQUIRE. TARA A. P124141GAN. PA 11 13 224 Datum SEM 12 DEPOSITION OF SAW 900 DETECTIVE JOSEPH RECAREY 14 West ids 33401 13 Plan. 14 Tuesday, April 27, 2010 Is 16 Oo bd./gelthe De /W. Setiney Epsiesn: 15 1003 - 5:23 p.m. 17 MEIIAN PIKE. 18QUIRE 16 505 South Hagler Drive BURMAN, CRUTCH, Lunrout COLEMAN, LIP Suite 1100 14 303 Rearm nadorsrel 17 West Palm Beach, Florida 33401 Sage 400 18 19 West Pligarida 33401 19 Phone 20 20 and 21 21 22 Reported By: mTI:PON 0. WITINRF.R.G. mot BRE Jena Riociuti, RPR, PPR, CLR 22 LAW OFFICE OF MILTON G. WEINBERG 23 Notary Public. Siam of Florida 20 Park Plant 23 Suite 1008. Prose CourtReporting 02116 Bea Mir 24 Job No.: 1509 24 Thaw 25 25 Page 321 Page 323 1 1 Appearances continued... 2 UNITED STATES DISTRICT COURT 2 On behalfof the Witness: SOUTHERNDISTRICT OP FLORIDA 3 3 JOANNE M. O'CONNOR, ESQUIRE CASENO. 10-80309 JONES, FOSTER, JOHNSON & STUBBS, P.A. 4 505 South Flagler Drive, Suite 1100 5 JANE DOENO. 103. West Pa rida 33401 Pkbdiff; Phone: 7 VOLUMEDI OFIV JEFFREY EPSTEIN, 9 Degltlallt 7 Also Present: Jeffrey Epstein 8 10 9 11 10 12 DEPOSITION OP 11 DETECTIVE JOSEPH RECAREY 12 13 13 14 Tuesday, April 27,2010 15 10:03 - 5:23 p.m. 14 16 505 South Hagler Drive 15 Suite 1100 16 17 West Palm Beach, Florida 33401 17 18 18 19 20. 19 ,21 20 22 Reported By. 21 Jeana Rkciuti, RPR, IFPR, CLR 22 23 Notary Public, State of Florida 23 Prose Court Reporting 24 24 25 25 2 (Pages 320 to 323) • PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricclutl Electronically signed by Jeana Ricciutl (4082837-abal-482e4836-be014441447a EFTA00298214 Page 324 Page 326 1 PROCEEDINGS 1 Q. And you would type the report into a computer? 2 2 A. Yes. 3 Deposition taken before Jeana Ricciuti, Registered 3 Q. And that would be essentially signed by you, 4 Professional Reporter and Notary Public in and for the 4 that would be your personal summary of the interview 5 State ofI•lorida at Large, in the above cause. 5 that you were conducting with one of the many people 6 6 that gave you information about Mr. Epstein? 7 Thereupon, A. Correct. 8 (JOSEPH RECAREY) 8 Q. And it was always your practice in this case 9 having been fast duly sworn or affirmed, was examined 9 to then destroy the notes that you used as a basis for 10 and testified as follows: 10 that typed summary; is that correct? 11 THE WITNESS: I do. A. Correct. 12 CROSS (JOSEPH RECAREY) 12 Q. And on other cases, is it always your practice 13 BY MR. WEINBERG: 13 to destroy the notes that you would take during the 14 Q. Good morning, Detective. 14 interviews? 15 A. Good morning. 15 A. Correct. 16 Q. You've been a detective for the Palm Beach 16 Q. So you have no notes of any case that you've 17 Police Department for how long? 17 ever memorialized into a computer or a typed summary; is 18 A. Approximately, 15 years. 18 that correct? 19 Q. Some ofit is as a detective and some of it in 19 A. That is correct. 20 another capacity, or always as a detective? 20 Q. And is that a practice that you've discussed 21 A. I've been with the Town for 19 yews, but I 21 with other detectives in the Palm Beach Police 22 did time on the road and then moved up to the detective 22 Department? 23 bureau. 23 A. Ifs just a practice that I've done all along. 24 Q. And do they have a written practice in teams 24 Q. And what is the purpose of your destroying the 25 of whether or not you're required to preserve rough 25 rough notes? Page 325 Page 327 1 notes or interview notes of different witnesses? 1 A. There's no need to keep them once you've 2 A. No policies, no practice. 2 transcribed than into your supplemental. 3 Q. Do you have personal practice as to whether or 3 Q. And again, the transcription into the 4 not you would retain rough notes that you are 4' supplemental is done X number of days after the 5 contemporaneously taking of interviews with the 5. interview? 6 witnesses? 6 A. If not the same day. 7 A. I take my notes, transcribe them into my 7 Q. Sometimes a week after, sometimes the same 8 supplements and then shred them. 8 day? 9 Q. So that you have no rough notes or no 9 A. I wouldn't say a week after. I would say 10 handwritten notes — 10 either the same day or the day after. 11 A. Correct. 11 Q. So within 24 hours, you would have a typed 12 Q. ofany of the many interviews you took 12 summary of the interview, is that correct? 13 during your investigation of Jeffrey Epstein? 13 A. Approximately. 14 A. Correct. 14 Q. And would you just type your rough notes or 15 Q. It was your practice to take notes while you 15 would you summarize from your rough notes when you 16 were interviewing people? 16 • engaged in the process of — 17 A. On occasion,1did, yes. 17 A. Summarize. 18 Q. Would you take notes even if you were tape 18. Q. — your report? 19 recording the people with whom you were conducting an 19 So the notes would have more than a summary? 20 interview? 20 A. Obviously, if it was taped, everything would 21 A. On occasion. 21 be on the tape recorder. As fir as my note-taking 22 Q. And at some point thereafter, you would use 22 concerns, I would jot down things that sparked my 23 those notes as a basis of writing a report; is that 23 curiosity or things I wanted to go back and reinterview 24 correct? 24 the person - and go back and reinterview the person. 25 A. Correct. 25 Q. So the summary that you typed into a computer 3 (Pages 324 to 327) PROSE COURT REPORTING. AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricciuti (601 c6062637-abel-452c-a836-bc614e314d7a EFTA00298215 Page 328 Page 330 1 would be, in part, your notes, part in memory of 1 surveillances of Mr. Epstein's residence as El Brillo on 2 different statements made to you based on the jottings 2 Palm Beach, correct? 3 in your notes? 3 A. Correct 4 A. I would basically go over what the interview 4 Q. And who made that assignment, if you know? 5 transcribed, you know, into my supplement. S A. I can't recalL That was back when 6 Q. But the basis of the supplemental, and I don't 6 Officer Pagan had the case. But they were also 7 mean to torture the subject, but the basis of the 7 utilizing it for various functions. They were primarily 8 supplement would be, in part, your memory, correct? 8 the surveillance units used. 9 A. Correct 9 Q. And did they surveille residences to try to 10 Q. And then, in part, what your notes refreshed 10 stop burglaries as well as stuveilling Mr. Epstein, 11 your memory into recalling from the interview that was 11 right? 12 conducted either at that time, the same day or the day 12 A. And other fractions as well. 13 before? 13 Q. Sure. And in 2005, there was not any kind of 14 A. Correct 14 burglary investigation dealing with his residence; is 15 Q. Did you listen to the tape before you wrote a 15 that correct? 16 supplemental report into a computer? 16 A. Correct. 17 A. Are you saying every time or arc you just 17 Q. So to the extent the Burglary Task Force was 18 saying — 18 involved in investigating Mr. Epstein prior to your 19 Q. Asa regular practice, would you, at the time 19 first involvement in September, it was simply an 20 that you typed in your supplemental report into a 20 assignment made of them to assist Officer Pagan, 21 computer, have the tape recording going? 21 correct? 22 A. See, I have done that on other cases, 22 A. Correct. 23 especially lengthy interviews, interviews that last 23 Q. And if you know, did the Burglary Task Force 24 several hours. 24 use video surveillance in investigating Mr. Epstein? 25 Q. But it's not a standard practice, it's 25 A. I know that there were some videos taken, but Page 329 Page 331 1 something you would do on an occasional basis; is that 1 I don't believe from the video — from the Burglary 2 correct? 2 Strike Force. 3 A. Correct 3 Q. Was there videos taken by others in the Palm 4 Q. Now, let me ask you in particular, on your 4 BeachPolice Department ofMr. Epstein's residence? 5 incident report, in essence, is a combination of all the 5 A. There was. There were several tapes. Yes, 6 different supplemental reports that you typed; is that 6 there was. 7 correct? 7 Q. Did you ever direct video surveillance of 8 A. I typed, and other officers as well. 8 Mr. Epstein's residence? 9 Q. Because you came to this investigation at 9 A. What do you mean "direct"? 10 least six months after it began; is that right? 10 Q. In other words, was there any video 11 A. Approximately, yes. 11 surveillance ofMr. Epstein's residence on or after the 12 Q. Again, March of 2005? 12 time that you became the ease agent in the 2005 13 A. Yes. 13 investigation? 14 Q. And it began with Officer Michele Pagan being 14 A. I can't recall. If I did, it would be in the 15 the case agent, if I could call her that? 15 incident report. 16 A. Correct. 16 • Q. But you know that there was such video 17 Q. And it began with surveillances that were 17 surveillance of Mr. Epstein's residence before you 18 conducted by the Burglary Task Force? 18 became the case agent in charge of the investigation? 19 A. Correct 19 ' A. I can't recall if it was before I took over 20 Q. And the Burglary Task Force was a component of 20 the case or after I took over the case. I know that 21 the Palm Beach Police Department designed to try to 21 there was tapes, but i don't know the exact time frame. 22 prevent citizens from being the victims of burglaries; 22 Q. Let me ask you and — let me ask Mr. Pike for 23 . is that correct? 23 one second. 24 A. Correct. 24 MR. WEINBERG: Do we need to use the real 25 Q. And yet, they were assigned the task of doing 25 names? 4 (Pages 328 to 331) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RIcciuti (801 Electronically signed by Jeana Ricciuti (801 c6062637-abol-462c-a836-bc614.314d7a EFTA00298216 Page 332 Page 334 1 MR. PIKE: Yes, pursuant to the agreement that 1 yoinself? 2 was entered last time, the real names can be used. 2 A. NO, sir. 3 MR. WEINBERG: Chuck is not going to be in 3 Q. Did you ever discuss with anyone the fact that 4 agreement, but i can use the real names, and then 4 there was such a victim list that had been generated out 5 they will be convened in the transcript to the 5 of the United States Attorneys Office? 6 applicable abbreviations. 6 A. There was a list, I believe, that was given to 7 BY MR. WEINBERG: 7 chief — former ChiefReiter. I never got to actually 8 Q. Jane Doe, do you know that name? 8 physically hold it and look at it i mean, it was one 9 A. Not that I recall. 9 of those things where he showed me the list, but I never 10 Q. So that it's fair that as you sit here today, 10 got a chance to... 11 in 2010, you have no recollection ofever interviewing a 11 Q. Did the Chief represent to you that that list 1.2 woman, a young woman at the time named Jane Doe? 12 originated with the United States Attorneys Office? 13 A. i don't recall, no. 13 A. I believe so. 14 15 Q. n, interviewingM.? d:r eciu have any recollection ofever 14 15 Q. Did he explain that he had received it from them? 16 A. I went to her home. 16 A. I believe so. 17 Q. And what do you recall of going to her home? 17 Q. And did he explain ho received it from them 18 A. She did not ward to speak to me. 18 with the directive that it should be reviewed and then 19 Q. And did she tell you why she didn't want to 19 destroyed? 20 speak to you? 20 A. I recall the destroying part I'm sure he 21 A. She was in love with Mr. Epstein and she was 21 reviewed it 22 not going to speak to me. 22 Q. What do you recall of the destroying part? 23 Q. And how did you come to go to her home? Do 23 A. I remember him telling me that he was given 24 you wall, you lawny, what led you to M.? 24 the copy but it must be destroyed immediately 25 A. Her name came up in the investigation either 25 thereafter. Page 333 Page 335 1 by interviews or — I believe it was interviews. 1 Q. And did he tell you who directed him to 2 Q. And do you recall who was interviewed, who 2 destroy it? 3 would have given you for the first time the name of 3 A. No. 4 M.? 4 Q. Did he tell you whether or not that directive 5 A. There were so many interviews then. I would 5 was in writing or verbal? 6 have documented it in the incident of who supplied what 6 A. No. 7 name. 7 Q. Have you ever seen — other than seeing him in 8 Q. So independent of what's documented in an 8 the physical possession of the list, have you ever seen 9 incident report that was largely authored, what's now 9 it again? 10 five years ago, you have no otrecollection of who 10 A. No. 11 would have first toM you about ? 11 Q. Do you have any reason to believe that he 12 A. Lilco I said, it would be documented in the 12 didn't destroy it? 13 incident report You know, we're talking five years 13 A. No. If he says he was going to destroy it, he 14 ago. You know, tons of interviews. 14 would destroy it. 15 Q. And with Jane Doe, similarly, do you you 15 Q. And do you recall when that was in terms of 16 don't remember interviewing her. Do you remember 16 the evolution of the State case? 17 interviewing anybody else about Jane Doe? 17 A. It would have been around December or January 18 A. Jane Doe does not ring a bell. 18 time Same of like '06, 107. 19 Q. Did you ever see her name on any report? 19 Q. So either the end of '06, beginning of '07? 20 A. No, I don't remember. 20 A. I believe so. 21 Q. Did you ever see her name on any list of 21 Q. Or at the time period that would be after the 22 different complainants, victims, witnesses? 22 State grand jury met and returned charges against 23 A. No. 23 Mr. Epstein? 24 Q. Did you eva sec a list of victims or 24 A. It would have been, yes, much after. 25 witnesses that was prepared by someone other than 25 Q. Would it have bear before there was 5 (Pages 332 to 335) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana FtIcclutl (601 Electronically signed by Jeana Moduli (601 c6062637-abel-452c-a836-bc6144/314d7a EFTA00298217 Page 336 Page 338 1 sum-ceding information that brought in the charges? 1 Q. And you certainly don't recall him ever saying 2 A. It would have been — again, I'm going off of 2. that on any other occasion that he had been directed by recollection here. 3 any Federal or State prosecutor - 4 Q. And again, I understand this is four years ago 4. A. Not with me, no. 5 and we're just trying to get your best unrefreshed 5 Q. — to destroy a document? recollection. 6 A. Not with me. 7 A I'm trying to think back. It would have 7 Q. And just so we're clear, this docwnent was 8 been — it would have been — see, I would be guessing. 8 being destroyed, not in the regular course of business, 9 Q. We don't want you to guess. 9 but as a result of the directive from the Federal 10 A That's the thing, I would be guessing. 10 prosecutor, correct, according to — 11 Q. Did the Chief ask you to come to his office? 11 A. I would assume so, yeah. 12 A Yes, he did ask me. He said the — the list 12 Q. And there was no other copy that you knew of 13 was not going to leave his office, most assured, and 13 this document? 14 I — at that point, I was like, you know, don't even 14 A. No. 15 show me. Liman, it was for your eyes only, that's 15 Q. And you have never seen one thereafter? 16 fine. 16 A. N sir. 17 Q. And did he explain to you why he was directed 17 Q. M. , you went to ha house; is that correct? 18 to destroy the list? 18 A. Correct 19 A. No. 19 Q. Did you speak to either ofher parents? 20 Q. Has the Chief ever before invited you to his 20 A. No, I did not. 21 office to discuss a document that he thereafter told you 21 Q. Was she 18 at the time you went to her house? 22 he was directed to destroy? 22 A. I believe so. 23 A. I mean, I've been many times at the Chiefs 23 Q. Was your practice that when somebody was over 24 office — 24 18, you would feel Otte it was appropriate to interview 25 Q. Sure. 25 them directly, but if somebody was under It, you would Page 337 Page 339 1 A. — but not — leant recall if there was ever 1 try to give some parental notification? 2 a time that he showed me a document that he must 2 A. Correct. 3 destroy. 3 Q. And your best recollection with is she 4 Q. And have you ever been, yourself, directed by 4 was over 18 and, therefore, you went directly to her? 5 either a State attorney or a US attorney to destroy your 5 A. Correct 6 document? 6 Q. What would you have told her when you rang on 7 A. No. 7 her doorbell and she answered the door? 8 Q. And has the Chief ever told you, on any other 8 A. I would have identified who I am, my purpose 9 occasion that you currently recall, that he was directed 9 for being there. 10 by a Federal or State prosecutor to destroy a document? 10 Q. And what would you have said your purpose for 11• A. I don't know. 11. . being there was? 12 Q. And other than destroying documents in the. 12 A. I was conducting an investigation. 13 regular course of business, you don't recall the Chief 13 Q. And wonld.you tell her of who? 14 ever before or ever after saying he had been directed by 14 A. Yes. 15 any third party to destroy a document that was relevant 3.5 Q. And would you tell her the subject matter of 16 to the investigation, correct? 16 the investigation? 17 A. Fro sorry, can you ask the question again? 17 A. Yes, absolutely. 18 Q. Oh, sure. Fm sorry. Other than this 18 Q. And her answer was that she did not wish to 19 occasion when the Chiefinvited you to his office and 19 cooperate with you? 20 specifically said that he was in possession of a 20 A. I never got to the point to explain to her my 21 document, relevant to the Epstein investigation that he 21' purpose of being there. Obviously, she knew why I was 22 had been directed to destroy, do you recall any other 22 .- . there. Once I identified myself, l told her I was a . • 23 occasion where the Chief told you that he was destroying 23 police officer from Palm Beach and I was here to speak 24 a document relevant to an investigation? 24- to her in regards to Jeffrey Epstein. At that point, 25- A. No. 25. • . she stopped me and said, I have nothing to say about 6 (Pages 336 to 339) PROSE COURT REPORTING AGENCY,..INC. Electronically signed by Jeana Fticciuti (601 Electronically signed by Jeana Ricciuti (601 c5062637-abol-452c-a836-bc6140140a EFTA00298218 Page 34C Page 342 1 him, nothing negative to say about him. She is in love 1 Q. Do you recall who that was? 2 with the man, and... 2. • A. Yes, I do. 3 Q. So that was literally a 30-second 3 Q. Who was that? 4 conversation? 4 A. 5. A. Pretty much. Pretty much. 5 Q. And tell me what you remember of that 6 Q. Were you with anyone? 6 attempted interview. 7 A. Yes, I was. 7 A. I went up to interview her with Detective •8 Q. Who were you with? 8 Caristo, at her boyfriend's place of employment was 9 A. I want to say either Sergeant Dawson, who was 9 where she was at. And she didn't wish to speak to me at 10 a detective at the time. 10 that point. 11 Q. Did you follow that tip at all by attempting to 11 Q. And did she tell you why? 1.2 reinterview her on any other occasion? 12 - A. If l can refer to it. 13 A. No. 13 Q. Sure, go ahead. 14 Q. So your sum total experience with was 14 A. She said that she knew there was an 15 essentially a 30-second conversation at her house where 15 investigation and that 1had spoken to other people and, 16 she declined your invitation to disciKS Jeffrey Epstein 16 therefore, I should know what had happened at 17 with her? 17 Mr. Epstein's house. 18 A. Correct. 18 Q. And did she make any other further explanation 19 Q. Okay. And you do recall her saying, "fin in 19 for her declining your request for an interview? 20 love with him*? 20 A. No. 21 A. Yes. 21 Q. Did she tell you that she, likeM., had 22 Q. And you're assuming but don't know that she 22 positive regard for Mr. Epstein? 23 • had been essentially tipped off that this investigation 23 A. I don't recall any positive regard. 24 was ongoing; is that correct? 24 ti.3icylou take notes ofyour conversation with 25 A. Pretty much. I mean, she didn't know why I — 25 Ms. Page 341 Page 343 1 allegedly why 1was there, but yet she... 1 A. No. 2 Q. Well, you told her why you were there, and she 2 O fild you take notes of your conversation with 3 then said, I'm in love with Jeffrey Epstein and have 3 Ms. M.? 4 nothing negative to say about him? 4 A. No. A. Correct. 5 Q. Did you write any supplemental report 6 7 Q. And so am I correct that she didn't say that she knew why you were there, that you're assuming that, 6 7 regarding your interview attempts with Ms. A. I believe I did. • 5? 8 because of the timing of that interview, that she had 8 Q. And likewise, you have before you a 9 discussed the investigation with others? 9 supplemental 1.1 that reflects your attempts to 10 A. It's possible. 10 interview Ms. 11 Q. You don't recall anybody telling you — 11 A. Yes. 12 . A. No. 12. Q. Did you ever attempt to interview a woman 13 Q. — at this time, that they had talked toM. 13 nulleda? 14 about your investigation? 14 A. Yes, I did? 15 A. No. 15 Q. What do you recall of that interview? 16 Q. Was there more than one such person, meaning 16 A. She was a masseuse. I remember going to her 17 did anybody else that you attempted to interview about . 17 home and interviewing her at her home. And If I recall 18. Jeffrey Epstein decline to be interviewed, to your 18 correctly, she stated that what happened betwom her and 19 current recollection? 19 Mr. Epstein were between consenting adults, that she was 20 A. No. I believe she's the only one. 20 over 18 at that time. 21 Q. Can I ask you to look at page 81, paragraph 1 21 Q. And did you write a report on that inns-view 22 ofyour incident report, and ask whether or not that • . 22 attempt? • 23 refreshes your recollection about the events of • . 23 A. I believe so. 24 February 15, 2006. 24. Q. And in fact, you interviewed a writs of women 25 A. Yes. 25 - who were over 18 years old,not only at the time of the 7 (Pages 390 to 343) PROSE COURT 'REPORTING. AGENCY, ,INC. . . • (- Electronically signed by Jeana Ricclutl (601 Electronically signed by Jeana Ricciu0 (601 a062637-abel-452c-a836-13c614e314d7a EFTA00298219 Page 344 Page 346 1 interview, but also at the time of the events between THE WITNESS: Right. Some girls wart under n 2 them and Mr. Epstein, correct? 2 different ruse. They thought they were going to 3 A. Correct. 3 either model or get a chance to be in Victoria Q. And you would incorporate those interviews 4 Secrets or that kind of thing, but... within the overall 87-page incident report is that 5 BY MR. WEINBERG: correct? 6 Q. That was the exception to the rule. A Correct A. Nobody was bound and gagged to go to the 8 Q. So that the focus of this broad investigation 8 house. 9 was not restricted to women under 18 and also included 9 Q. And those that told you that they thought they 10 women who were over IS; is that correct? 10 were going there for some other purpose were the 11 A. Correct 11 exception to the rule that was disclosure by whoever 12 Q. Now, some of the girls that you interviewed, I 12 invited them, correct? 13 don't mean to be disrespectful, but some of the minors 13 MS. ARBOUR: Object to the fonn. 14' you interviewed were emotional at the time of your 14 THE WITNESS: Some girls, again, told me that 15 interview, is that correct? 15 they were going there to give massages, and some 16 A. Correct 16 girls went there for other reasons. 17 Q. And if they were under 18 at the time of their 17 BY MR. WEINBERG: 18 interview, it WAS your practice to precede that 18 Q. Well, let's take one of them who claimed to 19 • interview with some notification to their parents; is 19 have gone there for another reason. Do recall 20 that correct? 20 interviewing n young woman namedM.? 21 A. Correct 21 A. Yes. 22 Q. And what would that notification be? In other 22 Q. And when did you interview her? Would the 23 words, what would you tell the mother or father of a 23 date of January 9, 2006 be consistent with your memory 24 minor? 24 as to when you interviewed 25 A. That their daughter was a possible victim 25 A. It would have been, yeah, about that time. 1 Page 345 Page 347 1 and/or witness in a police investigation involving a 1 know 1attempted it once before and she was emotional gentleman that lives in the Town of Palm Beach. 2 and, plus, I needed to get her father's consent because 3 Q. And had you, at the time ofsay by October of 3 she was still underage. 4 2005, within 30 days of your commencing of your 4 Q. When you went to visit with her father, her responsibilities in this investigation, concluded that, S father talked to you, did he not? as to these minors, that they would not be prosecuted; 6 A. Either 1telephoned him or spoke to him 7 that they were either victims or witnesses but not 7 directly. I believe I might have tel oned him. 8 targets? 8 Q. And the father told you that M. had told him 9 A. Rephrase your question one more time, Tm 9 that she had been hired to model lingerie; is that 10 sorry. 10 correct? 11 Q. Sure. Let me give you a predicate. Many, if 11 A. 1believe so. Pm not 100 percent certain on 12 not all, of the people you interviewed were paid sums of 12 that one. I know I recall the modeling part. I don't 13 money to give Mr. Epstein a massage at the bottom level, 13 know if it was exactly lingerie or... 14 correct? 14 Q. Okay. The father had communicated to you that 15 A. Correct 15 his daughter had told him that her connection to Jeffrey 16 Q. And that they went to his house, correct? 16 Epstein was that she went to see him as a model? -17 A. Yes. 17 A. Yes. 18 Q. And that they went to his house voluntarily; 18 Q. In other words, what you took from talking to 19 is that era met? 19 the father is that M. had likely lied to him regarding 20 MS. ARBOUR Object to the form. 20 her experiences with Mr. Epstein, correct? 21 311E WITNESS: Yes. 21 A. I wouldn't say "lied to him," because that's 22 BY MR. WEINBERG: 22 what she claimed to me, that that was the purpose ofher 23 Q. In other words, they weren't kidnapped or . 23 going to the house. 24 coerced into going to his house. 24 Q. But the father said that that's what she said 25. MS. ARBOUR: Object to the form. 25 was the relationship between him [sic] and Mr. Epstein, 8 (Pages 344 to 347) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RIccluti (601 Electronically signed by Jeana Ricciuti (601 c6062637-abo1-452c-a836-bc6141,314d7a EFTA00298220 Page 348 Page 350 1 that she went there as a model. 1 came tome and said that something bad happened to her 2 A I recall that that's what the father knew of 2 in relation to Jeffrey Epstein. 3 her going over there. 3 A. No. 4 Q. Sure. And this isn't the first parent that 4 Q. And no teacher ever came to you and said, my 5 you interviewed that didn't know what his daughter would God, I have a student who is saying that something bad 6 later claim occurred to you; is that right? 6 or improper happened in relation to her and Jeffrey 7 A. What do you mem? 7 Epstein, correct? 8 Q. In other words, many of the parents that you 8 A. Correct. 9 sought permission to interview their daughters did not 9 Q. And no religious figure ever came to you and 10 know the details of what had transpired between their 10 asked you to investigate Mr. Epstein as a result of some 11 daughters and Mr. Epstein, correct? 11 confessional or some complaint that he received from 12 A. Correct. 12 either a minor or from a parent of a minor? 13 Q. And in fact, no parent called you up 13 A. Correct. 14 uninvited, uninitiated and said, I want to complain 14 Q. And from that, you concluded that — strike 15 about something that's happening in Palm Beach regarding 15 that. 16 Mr. Epstein? 16 No doctor ever came to you and said that they 17 A. That's how the case first became originated, 17 had a patient that had been harmed by Jeffrey Epstein 18 but not me directly. 18 during the time period of your 2005/'6 investigation, 19 Q. Not you. 19 correct? 20 A. Not me directly. 20 A. Correct. 21 Q. So of all of the witnesses that you 21 Q. No psychiatrist or social worker or mental 22 interviewed, there wasn't a single parent that came to 22 health professional ever came to you and said, I have a 23 you as contrasted to you going to them? 23 patient or client that claims to have been banned by 24 A. No, not tome. I know that 24 Mr. Epstein? 25 Q. I understand and — 25 A. Correct Page 349 Page 351 1 A. -- Officer Pagan — 1 Q. And no minor ever came herself to the Palm 2 Q. -- we'll get there. Because you never 2 Beach Policy Department and claimed to have been alnico(' 3 yourself interviewed.., is that correct? 3 or harmed by Jeffrey Epstein? 4 A. No, I did not 4 A. Well, after the arrest ofMr. Epstein, we did 5 Q. So any testimony that you have given about 5 have people telephone In, but... 6 was derived from your reading reports that were 6 Q. But not before the arrest and in fact, the -- 7 authored by Officer Pagan and others, correct? 7 not before the grand jury returned its charge in the 8 A. Correct. 8 summa of 2006, correct? Q. And amongst those reports was some indication 9 A. Correct. 10 that one of the parental figures in life had made 10 Q. And then you had occasional calls from people 11 a proactive phone call to the Palm Beach Police 11 who you reported their allegations, correct? 12 Department in March of 2005, correct? 12 A. Correct. Actually, it's Dawson — 13 A. Coned. • • 13 Q. One was from New York and California — 14 Q. And they had overheard some conversation about 14 A. — Sergeant Dawson, right. 15 what.. claimed to have done at Jeffrey Epstein's 15 Q. — and they had — they were kind ofjumping 16 house, correct? • 16 on the Internet train that resulted from the publicity 17 A. Correct. 17 ofMr. Epstein's charge. 18 Q. And that they were not saying, my daughter 18 MS. ARBOUR: Object to form. 19 came to me and said, please call the police, something 19 THE WITNESS: I don't know if you want to call 20 happened to me; they were claiming that they had 20 that as a publicity train, but some of these 21 overheard a conversation, correct? 21 victims were legitimate, you know. I mean, we did 22 A. I believe so, yes. 22 have people call in as adults, but we had 23 Q. So no parent said to you or — and there's no 23 legitimate victims calling in. 24 report that reflects a parent saying to Officer Pagan or 24 . BY MR. WEINBERG: .25 anyone else in the Palm Beach Police Department, my kid 25 Q. And you call them legitimate victims, but just -1"1""•- ', " 9 (Pages 348 to 351) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana !Melon (601 Electronically signed by Joana Ricciutl (601 c5062637-aba1.462c.a8341-bc6144414d7a EFTA00298221 Page 352 Page 354 so the record is clear, you were not present at trying to initiate an investigation against Mr. Epstein 7 Mr. Epstein's home on any occasion when he had a with the sole exception of the n. broad family and the 3 one-to-one or contact with any of the so-called phone call that came into the police department six 1 complainants, correct? , months before you became case agent, correct? 5 A. No. 5 MS. ARBOUR: Object to form. 6 Q. So this is not something you — you were not 6 THE WITNESS: Coned. / an eyewitness to any of the events, correct? 7 BY MR. WEINBERG: 8 A. Correct. 8 Q. So let's, if we can, go back to and try 9 Q. There was no video surveillance of what did or 9 to at least focus on one of the interviewees. 10 did not occur in the massage room on the second floor on 10 She told you that she had originally gone to 11 El Brillo; is that correct? 11 the house believing that she was going there for the 12 ' A. 'Correct. 12 purpose ofmodeling; is that comet? 13 Q. There was no audio surveillance ofany 13 A. Correct. 14 conversations that Mr. Epstein participated in with any 14 Q. And somebody must have told her that, correct? 15 of the witnesses or complainants; is that correct? 15 A. I believe the person that took her. 16 MS. ARBOUR: Object to form. 16 Q. And do you recall who took her? Would. 17 THE WITNESS: Correct. 17 ring a bell? 18 BY ta NVIIIIIBBRO: 18 A. I believe, yes, I believe it was M. that 19 Q. You're relying on, A, what you were told and, 19 took her. 20 B, what your investigation derived? 20 Q. Do you recall writing — and this comes from, 21 A. During the sworn taped statement. 21 what I believe, is Exhibit 1 of the Palm Beach Police 22 Q. So going back to the period before he was 22 Department affidavit that "On January 9.1_20306,1 23 arrested and before there was this kind of outflow of 23 located and interviewed another victim, s date of 24 media or attention, there was not any of the different 24 birth April 29, 1988. was identified as a potent .1 25 minors that, who reside in Palm Beach, ever came to 25 victim witness from infonnation obtained during tia.‘,1 Page 353 Page 355 1 their local police department or to the Palm Beach 1 pulls from Epstein's residence." 2 Police Department and made a complaint against 2 And I represent to you I'm reading this 3 Jeffrey Epstein; is that correct? 3 accurate. 4 MS. ARBOUR: Object to form. 4 Does that refresh your memory about the going 5 TIM WITNESS: Are you limiting your 5 ton.? 6 questioning to just the persons that lived within 6 A. Yes. 7 the Town ofPalm Beach limits? 7 Q. And during what period of time would they have 8 BY MR. WEIN13ERO: • a these trash pulls? 9 Q. Let me start with the people within this 9 A. That would have been documented in the report. 10 region. Did any minor ever initiate a complaint with 10 Q. Any of them after the search ofOctober 20th? 11 you against Mr. Epstein before you had gone to them? 11 A. It might have been. 12 A. Not that I can recall, no. 12 Q. And by trash pull, we're referencing the 13 Q. And likewise, you don't know that any minor in 13 attempts by the Palm Beach Police Department to derive 14 this region, before the publicity, ever went to their 14 investigatory material by searching the garbage that 15 local police department, be it in West Palm Beach or 15 came from Mr. Epstein's residence; is that correct? 16 • Daytona Beach or wherever, and said, I want to report 16 A. That is correct. 17 that I have been injured, harmed, compromised by 17 Q. And the conversations engaged in between you 18 Jeffrey Epstein. 18 and others working for you and different representatives 19 MS. ARBOUR: Object to form. 19 of the Palm Beach Sanitation Department? 20 THE WITNESS: If there was, I wouldn't be . 20 A. The Sanitation Department didn't go through 21 aware of it. ' 21 the trash; all they did was pull it for us. 22 BY Mit. WEINBERG: 22 Q. But there were conversations between the 23 Q. Your 87-page report does not reflect any 23 - police and Sanitation asking Sanitation to have a clean 24 initiative taken by any minor or any parent ofa minor 24 and empty truck; is that correct? 25 ' or any professional who is associated with a minor in 25 A. Correct 10 (Pages 352 to 355) 'PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (801 Electronically signed by Jeana Ricciuti (801 C6062637-abol-452c-a336-bc614•314eila EFTA00298222 Page 356 Page 358 1 Q. To drive the truck to a certain location, 1 A. Correct 2 correct? 2 Q. And that they would go in and you would 3 A. Correct 3 surveille them going in? Q. To collect the trash on certain days from 4 A. Correct. 5 Mr. Epstein's house, correct? 5 Q. They would come out with the trash, correct? 6 A. Correct. 6 A. Correct Q. You knew that Mr. Epstein's house was enclosed 7 Q. They would put it in their truck, correct? 8 by security gates from your surveillances there, did you 8 A. Correct. 9 not? 9 Q. They wouldn't open it and mix it with the 10 A. Correct 10. trash? 11 Q. And that one would need to buzz in to come in? 11 A. No. 12 A. Not necessarily. I mean, the gates leading to 12 Q. They would take special care of it — 13 the garage were always left unsecured, opened. 13 A. Absolutely. 14 Q. Did you not know that the Sanitation people 14 Q. - so that it was preserved for search? 15 . would buzz in and ask — tell them that they were there 15 A. Absolutely. 16 to get the trash? 16 Q. They would drive it to a place where the 17 A. In the many, many times that I've driven by, 17 target wouldn't observe the transfer? 18 I've always seen that gate open to the garage. 18 • A. Correct. 19 Q. But when the Sanitation people went to 19. • Q. They would hand over the trash to the polio 20 Mr. Epstein's house, they were there pursuant to an 20 officer, correct? 21 agreement with you, that they would bring the trash to a 21 A. Correct. 22 predestined location where it would be made available to 22 Q. And the purpose of this trash seizure would be 23 Palm Beach -- 23 to search the trash for investigative evidence, correct? 24 A. Well, they were watched. 24 A. Correct. 25 Q. They were watched? 25 Q. And to your understanding, that was done Page 357 Page 359 1 A. They were watched. 1 before you commenced your responsibilities m this 2 Q. So you knew when they were going? 2 investigation? 3 A. Correct. 3 A. Before and during. 4 Q. There was a predestined time tlx:? they worn• 4 Q. And there was always cooperation by the Palm 5 going to go; is that correct? 5 Beach Sanitation Department, correct? 6 A. Correct. Correct. 6 A. Correct 7 Q. And you saw them go onto Mr. Epstein's 7 Q. They were, in fact, directed not to disclose a property. 8 to Mr. Epstein that they were seizing his trash, not 9 A. Correct. 9 just to bring it to the dump, but to bring it to the 10 Q. You saw them walk into, through the gates, 10 officers, correct? 11 • whether they were opened or whether they were opened for 11 A. Correct. 12 the people; is that correct? 12 Q. And again, this was done not under your watch, 13 A. Correct. 13 but under your supervision while you were case agent on 14 Q. You'd see them walk through the driveway 14 the 2005 fall Epstein investigation, correct? 15 area — 15 A. Correct. 16 A. Correct 16 Q. And from the trash, different leads were 17 Q. — Into the garage or near the garage, or was 17 found; is that right? 18 there a point in which they disappeared from your sight? 38 A. Correct. 19 A. I wasn't the one that was watching them. 19 Q. Leads that might not have been found had you 20 There was other representatives of the Police 20 not gone through the trash? 21 Department. I'm just telling you how I have always done 21 MS. ARBOUR: Object to form. 22 my trash pulls. 22 THE WITNESS: I would say some, but not all. 23 Q. So standard practice would be to have an 23 BY MR. WEINBERG: 24 agreement on a time that you would meet the trash people 24 • Q. And you saw some message pads? 25 outside the target's residence. • • 25 • A. Copies of the messages, yes. 1 11 (Pages 356 to 359) • PROSE COURT 'REPORTING AGENCY INC.. ( Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricciuti (601 c6062637-abo1462c-a836-bc614.314d7a EFTA00298223 Page 360 Page 362 1 Q. And you later teamed what they were as a 1 Q. Was it your understanding that Ms. M. had 2 result of your having gone to Mr. Epstein's home on 2 been there months before January 9, '06 as contrasted October 20th, pursuant to a warrant, and seized large 3 two years? 4 numbers of message pads, correct? 4 A. As far as, I'm sorry? 5 A. Correct 5 Q. When you interviewed her on January 9,'06 6 Q. And there were also notes that weren't on 6 A. Right. 7 message pads, correct, that were seized from the 7 Q. — was she telling you of events that occurred 8 garbage? 8 years before or months before, if you recall? A. Correct 9 A. I can't recall. 10 Q. Notes that were on Mr. Epstein's own pad with 10 Q. But you do meal! M. was her contact; she 11 his own name on it, correct? 11 was the person who invited her to go to Mr. Epstein's 12 A. Correct 12 home? 13 Q. And some of those notes related to his 13 A. I believe so. 14 business, if you know? 14 Q. And M. was currently in love with 15 • A. I don't believe so. 15 Mr. Epstein in or around the same time period? 16 Q. But some of the messages led you to phone 16 A. That's what she claimed to me. 17 numbers and the names of different people, such as 17 Q. And did your investigation disclose whether 18 correct? 18 Ms. M. was currently seeing Mr. Epstein in the fall of 19 A. Correct. 19 2005 into the early 2006? 20 Q. And since Ms. M. was first interviewed on 20 A. I can't recall if she was still going to the 21 January 9,2006, is it fair to say that the trash pull 21 residence. 22 from which her identity was first revealed, occurred in 22 Q. Ms. ■ told you she was originally told she 23 the fall 2005 period while you were case agent? 23 would be able to model lingerie for a wealthy Palm 24 A. I don't know. Without seeing the actual • 24 Beecher, is that correct? 25 message, I can't commit to that kind of answer. 25 A. That's what I documented. That's what she Page 361 Page 363 1 Q. Did Ms... tell you when, in relation to 1 told me. 2 January 9, 2006, she had last been to Mr. Epstein's 2 Q. And that she was taken to Mr. Epstein's home 3 home? 3 at El Brillo Way by Ms. M.; is that consistent with 4 A. I can't recall. 4 your memory? 5 Q. Did you ask these witnesses, whom you were 5 A. Yes. 6 interviewing, what time period they recall being at his 6 Q. And Ms... introduced her to Mr. Epstein; is 7 house? 7 that correct? 8 A. Yes. 8 A. Yes. 9 Q. And if there is nothing in the report, would 9 lIl And you have no independent memory that 10 that reflect — 10. Ms. M. ever said that she had any conversation with II A. Well, you're looking at the probable cause 11 Mr. ein prior to her being introduced to him by 12 affidavit The report will reflect more. 12 Ms. M.; is that correct? 13 .Q. The incident report was — the probable cause 13 . A. If she had prior conversations with — 14 affidavit was a subset of the affidavit — strike that. 14 Q. Yes, with Mr. Epstein before sbe was brought 15 The affidavit is a subset of the incident 15 to the house and introduced — 16 teport. 16 A. I can't recall whether she said that or not. 17 A. Correct 17 I don't believe so. 18 Q. If it's not in the incident report, then does 18 Q. Let me broaden it. Most of the people, if not 19 that reflect that you did not ask that question of .? 19 all of people who you interviewed, were introduced to 20 A. I would have asked regardless. 20 Mr. Epstein by some other young woman; is that correct? 21 Q. Did it inflect that she didn't give you an • 21 MS. ARBOUR: Object to form. 22 answer? 22 THE WITNESS: Correct. 23 A. Some witnesses were able to recall specifics; 23 BY MR. WE114BERO: 24 others were not able to recall exactly when, pinpoint 24 . Q. Whether Ms... was one,.., correct? 25 what time. 25 • A. Right. • 12 (Pages 360 Lo 363) PROSE COURT REPORTING AGENCY INC. ( Electronically signed by Jeana Rlcciuti (601 Electronically signed by Jeana Rlcciuti (601 c5062637abe1.452c-aS3Sbe814a314d/a EFTA00298224 Page 364 Page 366 '1 Q. M. was the second; is that correct, that 1 BY MR. WEINBERG: 2 brought people to his house? 2 Q. Or make phone calls to people that she was not 3 A. (Non-verbal response). 3 introduced to, correct? 4 Q. The routine and practice was for the pimple 4 MS. ARBOUR: Object to fonn. 5 that were introduced to him not to have had any prior 5 THE WITNESS: I knew she made several phone 6 conversations with him until they were introduced by an 6 calls, but it was to people that she knew that had 7 intermediary lace Ms. ■ or Ms. M.; is that correct? 7 been to the house previously. 8 MS. ARBOUR: Object to form. 8 BY MR. WEINBERG: 9 THE WITNESS: I believe so. 9 Q. Sure. So let me take it one step back then. 10 BY MR. WEINBERG: 10 The routine and practice was for one — let's focus on 11 Q. And in fact, there were no exceptions to that 11 — for a woman such as Ms. M., to introduce 12 rule as fares you currently remember? 12 Mr. Epstein to people that she had met or who were her 13 MS. ARBOUR: Object to form. 13 friends, correct? 14 THE WITNESS: As far as I can recall. 14 A. Uh-huh. 15 BY MR. WEINBERG: 15 MS. ARBOUR: Object to form. 16 Q. I mean, you have no — you don't recall any 16 BY MR. WEINBERG: 17 information that Mr. Epstein was out himself personally 17 Q. And likewise, the.. introduction of.. 18 trying to connect with young strange women. 18 fa that standard practice of one woman taking a second 19 A. No. 19 woman to Mr. Epstein and introducing them, correct? 20 Q. And likewise, you have no evidence that 20 MS. ARBOUR Object to form. 21 Mr. Epstein was e-mailing people that he didn't know 21 THE WITNESS: Correct. 22 attempting to ask than or invite than or recruit than to 22 BY MR. WEINBERG: 23 come to his home. 23 Q. And Ms. IIR, at least, told you during your 24 A. No. 24 interview with her in the first week of October 2005, 25 Q. And you have no evidence that Mr. Epstein, 25 that all of the young women that she introduced to Page 365 Page 367 1 himself; personally was on a telephone trying to connect 1 Jeffrey Epstein knew exactly why they were going to 2 with people to whom he had not previously been 2 . Mr. Epstein's home. 3 introduced, correct? 3 MS. ARBOUR: Object to form. 4 A. People not known to him? 4 MS. FINNIGAN: Joined. 5 Q. Yes. 5 THE WITNESS: That is what I recall during the 6 A. No, not that I'm aware of. 6 interview. Q. And so that an one — let me ask the same 7 BY MR. WEINBERG: 8 questions for Ms. You're familiar with 8 Q. And that was corroborated by your reading the 9 her, are you not? 9 report that M. said that she knew what she was doing 10 A. Yes. 10 before she went to Mr. Epstein's home, correct? 11 Q. And you have no evidence that she was out 11 MS. ARBOUR: Object to form. 12 driving around the Palm Beach area looking to meet some 12 • TIME WITNESS: I believe so, yes. 13 young woman who she, herself, could go and introduce to 13 BY MR. WEINBERG: 14 Mr. Epstein, correct? 14 Q. It was corroborated by others who were 15 MS. ARBOUR: Object to form. 15 identified by M. and thereafter interviewed by you and 16 BY MR.. WEINBERG: 16 others working with you, correct? 17 Q. People that she had never previously met? 17 • MS. ARBOUR: Fenn. 18 MS. ARBOUR: Same objection. .18 THE WITNESS: I believe so. 19 THE WITNESS: Not that I'm aware of. 19 BY MR. WEINBERG: 20 BY MR. WEINBERG: 20 • Q. So that at least for the.. group, if I can 21 Q. And likewise, no evidence that she would 21 • • confine than to by definition the people introduced to 22 e-mail people who she was not introduced to? 22 Mr. Epstein by Ms. M., none of them ever informed you 23 MS. ARBOUR: Object to form. 23 that they had gone there under a misapprehension as to 24 THE WITNESS: Not that Im aware of. 24 what was expected of them, correct? 25 25 • MS. ARBOUR: Object to form. 13 (Pages 364 to 367) PROSE COURT REPORTING AGENCY, INC. . • Electronically signed by Jeans RIccliM (601 Electronically signed by Jeana Ricciuti (601 c60626374b01412c4836-bc614•3144ffis EFTA00298225 Page 368 Recto 370 1 TIM WITNESS: Under the ■ group we're 1 BY MR. WEINBERG: 2 taring about? 2 Q. And they came from her pool of friends or 3 BY MR. WEINBERG: 3 associates or people that she made an independent 4 Q. Yes. Let me break it down. Ms... 4 decision to sec whether or not they wanted to go and 5 identified approximately six people that she had 5 meet Mr. Epstein, correct? 6 introduced to Mr. Epstein. 6 MS. ARBOUR: Form. 7 A. Correct. 7 ME WITNESS: Correct 8 Q. And each of them was invited by Ms... to go 8 BY MR. WEINBERG: 9 to Mr. Epstein's residence, correct? 9 Q. And the people that she invited to 10 A. Correct. 10 Mr. Epstein's house had a choice; they could go to 11 Q. And Mr. Epstein did not know any of these six 11 Mr. Epstein's house, give him a massage and be paid or 12 yotmnvomen prior to being introduced to them by 12 decline to go to Mr. Epstein's house and not give him a 13 Ms. M., correct? 13 massage and not be paid, correct? 14 MS. ARBOUR: Fonn. 14 MS. ARBOUR: FORM 15 THE WITNESS: As far as I 'mow, yes. 15 THE WITNESS: Correct 16 BY MR. WEINBERG: 16 BY MR. WEINBERG: 17 Q. And you have no knowledge that IMI=, 17 Q. And did Ms... tell you there wine people 18 or anyone else that resided at Mr. Epstein's home on 18 that she talked to who decided they didn't want to go to 19 El Brillo had any prior or independent relation with any 19 Mr. Epstein's home? 20 of the six girls that was being introduced to 20 A. I can't recall if she actually gave me names 21 Mr. Epstein by Ms. M.; is that correct? 21 ofpeople that she offered to take there and declined. 22 MS. ARBOUR: Form. 22 Q. But if you take age out of the equation, 23 THE WITNESS: As far as I know. 23 you'll agree there arc other residents in Palm Beach 24 BY MR. WEINBERG: 24 that invite people to their homes to engage in paid 25 Q. Ms. H.R. was asked by you and told you that 25 massages? Page 369 Page 371 1 she had a practice of telling each and every one of the 1 MS. ARBOUR: Object to form. 2 people she invited to Mr. Epstein's home, that they were 2 THE WITNESS: What do you mean? 3 to give Mr. Epstein a massage? 3 BY MR. WEINBERG: 4 A. Correct. 4 Q. I mean, in your history with the Palm Beach 5 Q. And that they could set their own limits while 5 Police Department, that have been residents of Palm 6 giving Mr. Epstein a massage? 6 Beach that have called massage services or escort 7 MS. ARBOUR: Form. 7 services and utilized their services, correct? THE WITNESS: I recall her saying the more you 8 MS. ARBOUR: Same objection. 9 do, the more you get paid. 9 THE WITNESS: I know there are legitimate 10 BY MR. WEINBERG: 10 masseuses that come to the residences and provide 11 Q. But do you recall her also saying that you 11 massages, if that's what you're trying to claim, 12 don't have to do anything you don't want to do? 12 yes. 13 MS. ARBOUR: Form. 13 BY MR. WEINBERG: 14 THE WITNESS: I believe so. 14 Q. I'm not trying to claim anything. 15 BY MR. WEINBERG: 15 A. No, no, no. But I mean, if that's what you're 16 Q. And she told each and every one of the people 16 trying to get at, absolutely, if that was your question. 17 she invited that they would be paid for the massage, 17 Q. And there were also, to your knowledge as an 18 correct? 18 experienced professional officer, there are some not so 19 MS. ARBOUR: Form. 19 legitimate escort and massage services that have clients 20 THE WITNESS: Correct 20 in the Palm Beach area, correct? 21 BY MR. WEINBERG: 21 A. Oh, I'm sure, yeah. 22 Q. And she chose the people that she invited to 22 Q. And that this is not a prosecutorial target 23 introduce to Mr. Epstein, coned? 23 for the Palm Beach Police to go and target at least 24 MS. ARBOUR: Font 24 adult massages, even if they include a sexual element; 25 THE WITNESS: As far as I know, yes. 25 is that correct? 14 (Pages 368 Lo 371) PROSE COURT. REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601M Electronically signed by Jeana Ricciuti (601 c5062637-abet452c-a836-bc614e314d7a EFTA00298226 Page 372 Page 374 1 MS. ARBOUR: Form. 1 an escort or a masseuse into their own private 2 THE WITNESS: If there is a crime that's being 2 residence, at least over the last five years, correct? 3 committedin the Town ofPalm Beach, we'll follow 3 A. I'm trying to think back I know we did make 4 upon it. 4 an arrest off an escort service whae a subject 5 BY MILWEINBERG: 5 telephoned an escort service for sexual favors, and we 6 Q. But you don't go and look for it 6 ended up soliciting an arrest warrant for the individual 7 MS. ARBOUR: Form. 7 for solicitation of prostitution. 8 THE WITNESS: When I say that we would solicit 8 Q. And that resulted from your investigation of 9 it? 9 the escort service, correct? 10 BY MR. WEINBERG: 10 A. Based on the interview conducted with him and 11 Q. Yes. 11 believe the escort herself. . 12 A. Probably not. Once we start to see a pattern, 12 Q. So one in five years? This is not an everyday 13 especially in the hotels, yes, we would because we have 13 investigatory priority of the Palm Beach Police, 14 done stings in the past 14 correct? 15 Q. Can you recall in the last fwe years any 15 A. No. We have other cases that we follow up on, 16 resident ofPalm Beach, a person with a house there, 16 but.. 17 getting arrested for having the paid services of 17 Q. And as you sit here now, you remember one 18 masseuse in their home? 18 'event, one such arrest in five years? 19 A. Are you talking a legitimate masseuse? 19 A. That I can recall. I man... 20 Q. Any masseuse, legitimate or illegitimate. 20 Q. Fair enough. Let's go back toII. 21 A. I mean, there's no crime against having a 21 THE WITNESS: Can we take a five-minute break? 22 massage at your house. 22 MS. O'CONNOlt: Sure. We need a five-minute 23 Q. I low about a paid massage that you had a basis 23 break. 24 to believe was sexual as well as pwfiasional, is there 24 (A briefrecess was taken.) 25 any resident of that island that's — 25 BY MR. WEINBERG: Page 373 Page 375 1 A. We have followed up on eases. 1 Q. Go back to several areas that we didn't 2 Q. Is there anyone that you remember in the lest 2 complete. Back to this witness list that you saw in 3 five years that lives in Palm Beach, owns a house on 3 Chief Reiter's office and that Chief Reiter represented 4 Palm Beach, had a escort or masseuse come to their home 4 to you he was under a directive to destroy, do you know 5 and got prosecuted? 5 whether or not a copy of that list was made so that it 6 MS. ARBOUR: Fenn. 6 would be available in the event there was a public 7 THE WIINESS: We have had instances where 7 records request? 8 officers have encountered escorts leaving the 8 A. I don't believe so. 9 residences of certain residents in the Town ofPalm 9 Q. Do you know whether or not the directive to 10 Beach. They were documented on an intelligence 10 destroy was given in anticipation of the public records 11 report and we would follow up on it the following 11: request? 12 day or the day after. We go to their house and 12 A. That, I don't 'mow. 13 identify what escort services, and we have done 13 Q. Would that document have been within the 14 stings, reverse stings where we contact the escort 14 response to a public records request? 15 services. 15 MS. ARBOUR: Object to form. 16 BY MR. WEINBERG: 16 BY MR. WEINBERG: 17 Q. But in those cases, you would be investigating 17 Q. If you know. 18 the escorts, not the escortee or not the john? I'm not 18 A. I have no idea. 19 trying to be difficult 19 Q. And if that document became part of the case 20 A. No, no, no. Pm just — 20 file of the investigation or prosecution of Epstein, it 21 Q. The fact is that in the last five years — 21 would be suhjcct to a public records request, at least 22 A. Pm eying to give you, you 'mow, examples. 22 according to what you know about public records, 23 Q. You've investigated for businesses that have 23 correct? 24 engaged in prostitution, but you have not, to your 24 MS. ARBOUR: Form. 25 memory, arrested any citizen of Palm Beach for inviting 25 THE WITNESS: If it was submitted into AC•••••.• 15 (Pages 372 to 375) PROSE COURT REPORTING AGENCY,' INC. Electronically signed by Jeana Ftictletl (601 Electronically signed by Jeana Ricciutl (601 c60626374130-46264130-bc814•314d7a EFTA00298227 , Page 376 Page 378 I evidence or the attachment file. 1 Q. Yes, for sexual conduct occurring between two 2 BY MR. WEINBERG: • 2 consenting human beings at a restaurant — at a 3 Q In terms ofyour memory dating back five 3. residence. • 4 years, I asked you about whether you recalled any 4 MS. ARBOUR: Fenn. 5 resident ofPalm Beach being arrested for the we or the 5 THE WITNESS: That I can recall. 6 misuse ofan escort or massage service, correct? 6 BY MR. WEINBERG: 7 A. Correct. 7 . Back to Ms... She was invited there by 8 Q. And your best manory was that you recall there 8 M., correct? 9 was one such incident, correct? 9 A. I believe so, yes. 10 A. Correct. 10 Q. If you believe Ms..., Ms... deceived her 11 Q. And you do recall investigations of 11 as to the purpose ofher going there, correct? 12 prostitution businesses, do you not? 12 A. She was going to go there to model is what I 13 A. Yes. 13 recall. 14 Q. And investigations and escort or massage 14 Q. And.., to your knowledge, had previously 15 businesses that you expected or had reason to believe 15 gone to Mr. Epstein's residence with other people? 16 were prostitution businesses, correct? 16 A. I believe so. 17 A. Correct. 17 Q. And those other people ended up giving a 18 Q. AM those investigations would be oriented 18 massage to Mr. Epstein? 19 towards targeting the people that made money from the 19 A. I believe so. 20 sale of sex, correct? 20 Q. And none of those people that M. brought to 21 A. Correct 21 Mr. Epstein's residence later represented to you that 22 Q. On the flip side, when I asked you about 22 M. said that the only object of the visit was to 23 residents ofPalm Beach, twos asking you about people 23 model; is that correct? 24 that would be known as johns, correct? In other 24 A. Repeat that one more time. 25 words — 25 Q. The other people that you interviewed who said Page 377 Page 379 1 MS. ARBOUR: Form. 1 that Ms... brought them to Mr. Epstein's residence, 2 BY MR. WEINBERG: 2 did not also tell you that they had gone there under a 3 Q. — the customers of a prostitution business. 3 false impression, correct? 4 MS. ARBOUR: Same. 4 A. Ica& recall. 5 771E WITNESS: Correct. 5 Q. If it's in your incident report — 6 BY MR. WEINBERG: 6 A. It would be in there. 7 Q. And the same question, you recall only one 7 Q. — they told you, and if its not in there, 8 person who resides in Palm Beach who was prosecuted for 8 then these different individuals were representing to 9 being a customer of a prostitution business using them 9 you that they knew that they were going there to give 10 to come to his borne, correct? 10 Mr. Epstein a massage? 11 A. I believe so. 11 A. Right, it would have been in the re 12 Q. Do you recall the name of that person? 12 Q. Now, none of the women that Ms.M. invited 13 A. Not off the top of my head. 13 to meet Mr. Epstein ever told you that they went there 14 Q. Take it back ten years, do you recall any 14 for any purpose other than to give him a massage, 15 second such prosecution of a residence ofPalm Beach for 15 correct? 16 ming the services of a prostitution or massage or 16 MS. ARBOUR: Object to form. 17 escort business? 17 THE WITNESS: I believe so. 18 A. Again, we do hold stings in certain hotels, 18 BY MR. WEINBERG: 19 the Breakers, the Four Seasons, the Marriott, where 19 Q. And Ms. %introducedEl. to Mr. Epstein 20 women and men both go to the bars and solicit. 20. according to what told you on January 9, 2006, 21 Q. But in terms of private residences, in your 21 correct? 22 entire professional life on the Palm Beach Police 22 • A. Correct 23 Department, you only recall one such arrest and 23 lil?And Ms. • told that Mr. Epstein, 24 prosecution, correct? 24 Ms. M. and Mr. [sic] M. had a conversation at 25 A. At a residence? 25. ' Mr. Epstein's house, correct?. 16 (Pages 376 to 379) PROSE COURT REPORTING AGENCY, 'INC. Electronically signed by Jeana Riccluti (601 Electronically signed by Jeans Riccluti (601 65012637-abel-4624-4834-bc014•314474 EFTA00298228 Page 380 Page 382 1 A. I believe so. 1 A. Yes. 2 Q. And then Ms... told you that both Ms. 2 Q. And Ms... removed her pants and blouse, 3 and Mr. Epstein brought her upstairs into a master 3 correct? 4 bedroom area, correct? 4 A. Correct. 5 A. Yes, if it's in the report, that's... 5 Q. And she didn't say that she tried to run out 6 Q. And then Ms.M. observed a large massage 6 and couldn't get away or anything like that; is that 7 table with a sheet on it; is that your memory that 7 right? 8 Ms. M. told you that she, after meeting Mr. Epstein, A. Correct. 9 she went upstairs to an area ofMr. Epstein's home where Q. Otherwise, those kind of statements would be 10 there was a massage table? 10 clearly incorporated into this probable cause affidavit, 11 A. I believe so. 11 right? 12 Q. And did she tell you that Mr. Epstein came 12 A. Correct. 13 into that area wearing a towel, and that Ms. 13 Q. Because the affidavit was designed to persuade 14 informed Ms.M. they were going to provide Mr. Epstein 14 a judge that there was sufficient evidence to charge 15 with a massage? 15 Mr. Epstein and others with criminal offenses against 16 A. I believe so. 16 the State ofFlorida. 17 Q. And that when askedM. why they were 17 A. I wouldn't say persuade, but I would state the 18 doing this, explained to that they were going 18 facts. 19 to rub Ins calves and feet? 19 Q. And the purpose of stating the facts was to 20 A. I believe so. 20 fill out what you concluded was probable cause to 21 Q. And that Ms. M. didn't leave the massage 21 warrant the State Attorney from prosecuting Mr. Epstein 22. area at this time, according to her statement to you; is .22 fora criminal offense? 23 that right? 23 A. Correct. 24 A. Right. 24 Q. And this was done by you on May I, 2006, 25 Q. Then Ms. M. told you that she began to 25 correct? Page 381 Page 383 1 partiate in this massage with Mr. Epstein and 1 A. Correct. 2 Ms.MI, correct? 2 Q. When matters were relatively fresh as 3 A. I believe so. 3 contrasted to how they are in April of2010? 4 Q. And that Mr. Epstein asked her to get 4 A. Yes. 5 comfortable, do you recall that? 5 Q. And when you prepared this problem cause 6 A. I believe so. 6 affidavit, you were largely relying on your supplemental 7 Q. And that Nis... elected to take off her 7- reports in the omnibus Palm Beach incident report, clothes leaving on only her pants; is that correct or 8 correct? 9 panties? 9 A. Correct 10 Do you want to read this? 10 Q. And you were not relying to your current 11 A. If you don't mint 11 memory on any tape recording of this statement on 12 Q. This is page 20 of E:dtibit I, which is 12 January 9th with Ms. M., were you? 13 DetectiveReearey's — 13 A. A tape recording? 14 MR. PIKE: If you would, could you please turn 14 Q. Yes. 15 to that page because there's some writing on this 15 A. Like I said, I have reviewed tape recordings 16 one and I don't want to — 16 that I've conducted on interviews. 17 MR. WEINBERG: This is not the incident 17 Q. Which ones did you listen to before you 18 report This is the probable cause affidavit 18 executed an affidavit on May I st? 19 MS. ARBOUR: I have an extra one, I think. 19. A. I couldn't tell you. 20 MR. WEINBERG: Thank you. 20 Q. Would you have a note, record, diary, 21 BY MR. WEINBERG: 21 reference — 22 Q. Were on page 20, about five or six lines 22 A. No. 23 down. In paragraph I, Epstein told Ms. M. to get 23 Q. — any way to construct which ones you 24 comfortable. Actually, its seven lines down on the 24 listened to? 25 left side, page 20. 25 A. No. 17 (Pages 380 to 383) ( 561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Medea (601 Electronically signed by Jeana Ricciuti (601 c50626374the1452e-0364n6144414d7a EFTA00298229 Page 384 Page 386 1 Q. Tape recordings would, ofcourse, be the most A. I may have listened to Ms. Jane Doc 103's 2 reliable predicate for what, in fact, a witness told 2 interview while I was doing the supplement. 3 you, correct? 3 Q. But you have no memory as you sit here now 4 MS. ARBOUR: Object to form. 4 that you listened to it in the last days of April or 5 BY MR. WEINBERG: 5 around May 1, 2006, before summarizing the recitation by 6 Q. But they are also longest to wade through. 6 Ms. Jane Doe 103 into this probable cause affidavit, correct? 7 correct? MS. ARBOUR: Form 8 A. If I listened to it prior to writing the PC? 9 BY MR. WEINBERG: 9 is that what you're asking me — 10 Q. In other words, they take more time to hear 10 Q. Yes. Yes. 11 than reading a summary would take to read? 11 A. — if I listened to it prior to writing the 12 MS. ARBOUR: Same objection. 12 13 THE WITNESS: As far as, like, if you heard 13 Q. Yes, prior to. 14 it? 14 A. No, I can't recall if I did or didn't. 15 BY MR. WEINBERG: 15 Q. And I'll ask the same questions regarding your 16 Q. Yes. It would take you however many hours — 16 preparation of the search warrant affidavit. You had 17 A. Right, depending on the length of the 17 tape recordings available to you, did you not? 18 interview. I mean, some could have been an hour, some 18 A. Yes, I did. 19 couldhave been two hours. 19 Q. This investigation generated approximately 22 20 Q. How long was the lengthy one, if you remember?. 20 tapes? 21 A. I believe it was — it would have been over an 21 A. Approximately. 22 hour. She was still inhigh school and she had to get 22 Q. Most of which were generated before 23 back. 23 October 18, 2005 when you authored an affidavit setting 24 Q. But you have no memory that you, in fact, 24 to search Mr. Epstein's private residence, correct? 25 listened to Ms. tape at or before the time you 25 A. Correct Page 385 Page 387 1 summarized your memory of your conversations with her 1 Q Did you listen to all of those tape recordings 2 into this affidavit on May 1st, correct? 2 prior to drafting an affidavit that was intended to 3 A. I can't say if I did or didn't. 3 result in the judicial authorization of a search and 4 Q. And the same thing with do you recall 4 seizure of Mr. Epstein's residence? 5 whether or not that was one of the tapes you listened to A. I may have, as I was doing my supplements. 6 before summarizing what she had said to you in October 6 Q. Pm directing myself towards the time period 7 of2005 into this probable cause affidavit? 7 when you were drafting the affidavit that was going to 8 A. M.'s was different. M.'s was a videotape 8 be filed with the judge to ask for permission to search 9 conducted at the Palm Beach Police Department. 9 Mr. Epstein's residence. 10 02Did you watch and listen to the videotape of 10 Did you listen to those tapes contemporaneous 11 the M. interview? 11 • with your authoring the search warrant affidavit? 12 A. I may have. 12 A. I can't recall if f did or didn't. 13 . Q. But you don't recall which ones you didn't or • 13 Q. If you did, would there be any note, report, 14 did, correct? 14 log entry that you did? 15. A. Correct. 15 A. Not that I've kept am, no. 16 Q. And same with Jane Doe 103, October II, 2005, 16 Q. You don't have a current memory of being at a 17 interview in Tallahassee, that was tape recorded, was it 17 typewriter typing in your affidavit fora search 16 not? 18 warrant -- 19 A. Yes, it was. 19 A. We don't utilize a typewriter, but — 20 Q. The telephone call the day before was not tape 20 Q. A computer? 21 recorded; is that correct? ' 21 A. A computer. 22 A. I may have recorded that one. 22 Q. It shows my age. .23 . Q. .Do you recall whedier.you listened to either • 23 You typed into a computer the affidavit that 24. • or both of those tape recordings prior to executing the 24 ultimately went to a judge to -- 25 May 1, 2006 affidavit? 25 A. Correct 18 (Pages 384 to 387) (561)—832-7.500 PROSE COURT REPORTING AGENCY,'INC. •S Electronically signed by Jeana Rice-lug (601 Electronically signed by Jeana Riccluti (601 c5062637-abet -452c-a836-bc614e314d7a EFTA00298230 Page 388 Page 390 1 Q. seek authority to search Mr. Epstein's 1 Q. And Ms. M. said she started to nib 2 home? 2 Mr. Epstein's 'chest; is that correct? 3 A. Correct. 3 A. Yes. 4 Q. And you did that in your office? 4 Q. AM that's in addition to what she had been . 5 A. Yes. 5 told, which is that she and Ms. M. were going to rub 6 Q. And in your office, is there a tape recorder? 6. his calls and feet; is that right? 7 A. Yes, we do have tape recorders. We have — 7 A. Correct. 8 Q. And you had access to the tape recordings of 8 Q. And she didn't say at this time that she in 9 the witness interviews, did you not, at the time? 9 any way was being forced or coerced into giving 10 A. Yes. 10 Mr. Epstein a massage, correct? 11 Q. And you don't recall today whether or not you 11 A. Correct. 12 listened to any or. all of them at or around the time 12 Q. Mr. Epstein, according to her recollection, 13 that you drafted the search warrant affidavit? 13 began to masturbate; is that right? 14 A. I can't recall if I did or didn't 14 A. Yes, as he stroked her vagina. 15 . Q. Your best memory is that you relied on the 15 Q. But she told you that Mr. Epstein was touching 16 supplemental reports authored by you as the predicate 16 her breast and touching her vagina; is that correct? 17 for what you represented to 'judge warranted his • 17 A. Correct. 18 authorizing a search and seizure of Mr. Epstein's 18 Q. And she didn't tell yon she protested or 19 property, correct? 19 objected to such touching, did she? 20 A. Correct 20 A. No. 21 Q. Back to Ms... This is the first time she 21 Q. Because it would be in your report? 22 was at Mr. Epstein's home that she was telling you about 22 A. It would be in the report if it did. 23 on January 9th, correct? 23 Q. And she then told you that she was paid $200 24 A. Yes. 24 for the massage, correct? 25 Q. And she ultimately told you about two 25 A. Correct. Page 389 Page 391 1 occasions that she went there; is that correct? 1 Q. And she was tearful, at least during parts of 2 A. I believe so. 2 this interview; is that correct? 3 Q. And she, in fact, went back a third time, did 3 A. Correct. 4 she not? Did she not? 4 Q. But she didn't tell you that she refused the 5 A. I can't recall whether she — how many times 5 $200, correct? 6 she went without looking at it. 6 A. Right. 7 Q. Let's first look at what's in front of you, 7 Q. And she didn't tell you that she was so 8 which is the probable cause aflidaviL She removed her 8 tranwiatizni injured or damaged by this incident that 9 pants and blouse, correct? 9 she didn't voltmtarily return several days later, 10 A. Correct. 10 coned? 11 Q. And that was a voluntarily act on her part in 11 A. I'm sorry, one more time. 12 response to Mr. Epstein telling her to getting 12 Q. She didn't tell you that she was traumatized 13 comfortable, correct? 13 by this event at the time it occurred, did she? 14 A. Correct. 14 A. I don't recall her saying that she was 15 Q. And that she stayed only in panties because 15 traumatized. 16 she didn't have a bra on that evening, correct? 16 Q. Or in any way injured because she, infect, 7 A. Correct. 17 was Invited to return and did return several days later 18 Q. So she took off her shirt and, therefore, was 18 alone; is that right? 19 naked froni the waist up; is that right? • 19 A. I believe so. 20 A. Correct 20. . In other words, she told you, if you recall, 21 Q. AM Ms... was still there; is that right? 21 that she received several days later a telephone call 22 A. (Non-verbal response). 22 from la is that correct? 23 Q. And the two of them were massaging 23. . A. Correct. . 24 Mr. Epstein? 24 Q. And who essentially invited for to conic back, 25 A. Yes. 25 correct? 19 (Pages 388 to 391 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricclutl (MI Electronically signed by Jeana Ricdutl (401 c5062637.abol-462c-a836-bc614e31ed7a EFTA00298231 Page 392 Page 394 1 A. Right, to work. 1 If we start on 73 since it's redacted, I 2 Q. And this time, she wasn't with M. ? 2 want to assure you I'm talking about what I believe to 3 A. Yes. 3 be the same interview on January 9, 2006. Paragraph 3 4 Q. AM she elected to return to Mr. Epstein's 4 is. telling you she was told she could model 5 house, this time knowing that it was not to model 5 lingerie, and then much of the same right up to the last 6 lingerie? 6 sentence where she stated she went to Mr. Epstein's 7 A. Correct. 7 house three or four times total. 8 Q. And in fad, went back on her own as a 8 - A. Right. 9 response to Ms. inviting her to give Mr. Epstein 9 Q. And then on the next paragraph, she was 10 a second massage? 10 telling you that she once brought a friend? 11 A. Correct. 11 A. Correct. 12 Q. And again, Mr. Epstein — she went upstair to 12 Q. Some of the young women told you they were 13 Mr. Epstein's bedroom area and gave Mr. Epstein a 13 terribly upset while talking to you; is that correct? 14 massage, correct? 14 A. Correct. 15 A. Correct. 15 Q. And they had a variety of reasons to be upset, 16 Q. And again, she was paid for that massage, 16 didn't they? 17 correct? 17 MS. ARBOUR: Form. 18 A. Correct. 18 BY MR. WEINBERG: 19 Q. And she didn't, between the dates of these tvio 19 Q. To your knowledge. 20 massages and the date you went to her house on 20 A. To my knowledge, yeah, absolutely. 21 January 9, 2006, or went to her school, she didn't call 21 Q. One thing is that some of the women yawere 22 you or didn't ask her parents to call you to complain 22 interviewing, for instance Ms... and Ms. M., twit: 23 about the conduct that occurred at El Brillo, correct? 23 actively bringing third parties to visit Mr. Epstein; k 24 A. Correct. 24 that correct? 25 Q. Now, if we switch for a second from your 25 MS. ARBOUR: Form. Page 393 1 affidavit to your incident report, do you recall that 1 THE WITNESS: Correct. 2 she went back a third time and brought a friend a third 2 BY MR. WEINBERG: 3 time? 3 Q. And being paid for it? 4 A. I believe — I believe she may have brought 4 MS. ARBOUR: Fa 5 someone. 5 TIIE WITNESS: Yes. 6 Q. AM do you recall who she brought? 6 BY MR. WEINBERG: 7 A. Not off the top of my head, no. 7 Q. And that constitutes a violation of the 8. Q. AM do you recall writing on page 74 of your 8 Florida statutes, does it not? 9 incident report that she once brought a friend, and she 9 MS. ARBOUR: Form. 10 said that she didn't know the last name, to give 10 THE WITNESS: For unlicensed massages or... 11 Mr. Epstein a massage and that she was paid $200 for . 11 BY MR. WEINBERG: 12 bringing a friend? 12 Q. For any and — I mean, did you believe that 13 A. !can't readL 13 you threatened Ms... with a criminal prosecution, did 14 Q. Perhaps you can read page 74 and see if that 14 you not, when she was videotaped on October 5, 2005 15 refreshes your recollection. 15 being interviewed? 16 A. Page 74? 16 MS. ARBOUR Form. 17 Q. Yes. 17 • THE WITNESS: I didn't threaten Ms..., but 18 Just to orient you, it's her interviews with 18 I did explain to her that what she did was illegal. 19 you start on page 73. The first of January 9, 2006. 19 BY MR. WEINBERG: 20 There's some redactions, but if you refer to 20 Q. Was illegal? 21 paragraph 3, you'll sec that she was the person who told 21 A. Right 22 you she could model lingerie and then it continues. .22 Q. And similarly, what Ms... did was illegal? 23 A. I think your 74 is different than this 74. 23 • MS. ARBOUR: Fain.. 24 Q. We have different reports? May I sec yours 24 • BY MR. WEINBERG: 25 for a second? 25 Q. In your mind. 20 (Pages 392 to 395) PROSE. COURT REPORTING AGENCY, INC." Electronically signed by Jeans Medlin (601 Electronically signed by Jeans Riccluti (601 e6082637-abel-48204836-be614•314dra EFTA00298232 Page 396 Page 398 MS. ARDOUR: Same objection. 1 to her and her father that she had lied to her father 2 THE WITNESS: Pretty much. I mean, you 2 about her visit with Mr. Epstein, correct? 3 3 A. Again, I don't know if she lied to her father. 4 BY MR. WEINBERG: 4 I know she went there originally with the intentions to 5 Q. Did you ever conduct a criminal investigation 5 model. 6 of Ms. M.? 6 Q. But she never told her father she had been 7 A. No. 7 paid for topless massages, comet? 8 Q. Did you ever conduct any followup 8 A. Not to my knowledge. 9 investigation of Ms... when she declined to speak to 9 Q. And her father told you what he knew of what 10 you? 10 she had done or not done with Mr. Epstein, collect? 11 A. No. 11 A. As far as he knew, yes. 12 Q. To your knowledge, did you or anyone else in 12 Q. And clearly, there was at least a lie by 13 the Palm Beach Police Department have any contact with 13 omission from Ms. M. to the father or the father to 14 Ms. M. during the time period of this investigation 14 you, correct, because Ms.. was telling you she did 15 which began in March of '05 and ended in December of 15 far more than her father told you she did? 16 '06? 16 A. Yes. 17 A. I spoke to her that one time and didn't speak 17 Q. And she was not the only minor that you 18 to her again. 18 interviewed, correct? 19 Q. Eva seen a report from anyone else in Palm 19 A. Correct. 20 Beach that ever spoke to her? 20 Q. And therefore, Mr. I was not the only parent 21 A. I don't believe anyone else spoke with her.' 21 • that you had occasion to say that you were doing an 22 Q. And you did no background on her to your best 22 investigation in which their daughter was either a 23 recollection in terms of her character, her reputation, 23 witness or a victim, coned? 24 her credibility, correct? 24 A. Correct. 25 A. No. 25 • Q. And you know, from having conducted followup Page 397 Page 399 Q. Likewise, Ms. did you do any background 1 and interviews, that parents learned a lot more as a to determine whether she was a credible, trustworthy, 2 result of your visits than they had learned beforehand reliable source of information about Mr. Epstein? 3 regarding what had occurred between their daughters and A. Based on the sworn taped statement that I took 4 Mr. Epstein, correct? of Ms. M., I mean, she had specific knowledge as to 5 MS. ARBOUR: Pam. persons within the home, descriptions of the home, 6 THE WITNESS: Right. within the home, within the bath — you know, the 7 BY MR. WEINBERG: 8 bedroom, the bathroom area. 8 Q. And that you also knew that sane of the tears 9 Q. But she was telling you, was she not, that she 9 that were being shed were being shed by the girls 10 was emotionally — had emotional consequences to what 10 because suddenly their parents were involved, correct? 1/ she did; is that right? She was crying at different 11 MS. ARBOUR Form 12 times she was talking to you; is that right? 12 THE WITNESS: I don't know if the tears were 13 A. Absolutely. 13 because the parents were involved. I know that 14 Q. And several of the girls did; is that right? 14 there was a lot of shame, a lot of embarrassment 15 A. Absolutely. 15 BY MR. WEINBERG: 16 Q. And one of the realities were that their 16 Q. A lot of fear, fear of school? 17 parents were fording out what happened, correct? 17 MS. ARBOUR: Form. 18 A. Yes, in some of the victims, yes, the parents 18 THE WITNESS: I know, in Ms. case, 19 did find out. 19 she was in fear of Mr. Epstein. 20 Q. And that was traumatizing to them, was it not? 20 BY MR. WEINBERG: 21 MS. ARBOUR: Fonn. 21 Q. And do you know in Ms. case she was 22 THE WITNESS: I'm sure it was embarrassing for 22 also in fear of her school friend in that which she had 23 than, yes. 23 done? .24 BY MR. WEINBERG: 24 Let's step back a step. What she had done is 25 Q. In fact, with it was becoming clear 25 she had gotten money for a sexual massage, correct? 21 (Pages 396 to 399) PROSE COURT' REPORTING AGENCY, INC. Electronic/By signed by Jeans Rleekel PM= Electrote signed by Jeans Rlcdutl (401 c6062637,41301-462e4a136-bc614•31467a EFTA00298233 Page 400 Page 402 1 A. She got money for providing a massage while 1 BY MR. WEINBERG: 2 Mr. Epstein touched her breasts and fondled her vagina 2 Q. Correct? 3 Q. Would you consider that this fans within the 3 MS. ARBOUR: Same objection. 4 broad ambit of prostitution? THE WITNESS: The negotiation part, X for Y. 5 MS. ARBOUR: Form 5 BY MR. WEINBERG: 6 THE WETNESS: Prostitution would be for sex 6 Q. So absent the negotiation, there is no 7 for money. 7 prostitution? 8 BY MR. WEINBERG: MS. ARBOUR: Fonn. 9 Q. So Ms. M. did not engage in prostitution, 9 THE WITNESS: No. 10 but others did, during the course of the investigation? I0 BY MR. WEINBERG: 11 MS. ARBOUR: Form 11 Q. And therefore, in your opinion, the women 12 • THE WITNESS: I wouldn't say others did. Ifs 12 going to see Mr. Epstein were not going there pursuant 13 a negotiation. If you're paying for a sex act, 13 to a prostitution agreement, correct? 14 it's a negotiation. You get X for Y. 14 A. Coned. 15 BY MR. WEINBERG: 15 Q. They were going there as consenting adults or 16 Q. So that if the negotiation was purely for a 16 even consenting minors to do something other than 17 topless massage, then there was no prostitution? 17 prostitution? 18 MS. ARBOUR: Form. 18 MS. ARBOUR: Form. 19 THE WITNESS: Not in my eyes, no. 19 THE WITNESS: They were going there to provide 20 BY MR. WEINBERG: 20 the manage but, you're right, it wasn't 21 Q. So in your eyes, were any of the so-called 21 prostitution. 22 victim/witnesses, did any of them engage in 22 BY MR. WEINBERG: 23 prostitution? 23 Q. And in fact, had some of these girls that went 24 MS. ARBOUR: Form. 24 there who were under 18, had they been over 18, then 25 THE WITNESS: Do you mean since that time, 25 this entire case would have been a consenting massage Page 401 Page 403 or — 1 case, correct? 2 BY MR. WEINBERG: 2 MS. ARBOUR: Form. 3 Q. Well, let's start with that time, when 3 MS. FINNIGAN: Form. 4 Mr. Epstein was the customer. Were any of the women 4 THE WITNESS: If they axle over 18? 5 going to his house engaging in prostitution, in your 5 BY MR. WEINBERG: 6 opinion? 6 Q. Yes. 7 MS. ARBOUR: Form 7 A. That it would have just been what, a massage 8 THE WITNESS: In my opinion? ease, you mid? 9 BY MR. WEINBERG: 9 Q. It would have been a case between two 10 Q. Yes. 10 consenting adults, other than prostitution. 11 A. No. 11 MS. ARBOUR: Form. 12 Q. And that included those who were going to his 12 THE WITNESS: Unless we got a complaint. 13 house who were above 18 as well as below 18, correct? 13 BY MR. WEINBERG 14 MS. ARBOUR: Form. 14 Which you didn't get in this case, other than 15 THE WITNESS: Like I was told, people that I 15 the parent Mmeh '05 complaint as a result of 16 interviewed that were above 18, what happened 16 overhearing a discussion? 17 between them were between two consenting adults. 17 MS. FINNIGAN: Form. 18 BY MR. WEINBIRO: 18 THE WITNESS: Right. 19 Q. And so to your mind, it's not the giving of 19 BY MR. WEINBERG: 20 money, it's the negotiated agreement that constitutes 20 Q. Ms... certainly, although emotional during 21 the essential element that distinguishes prostitution 21 her interview, never said that anybody forced her to 22 from simply a consensual act as long as the people who 22 return to Mr. Epstein's house on the second occasion 23 engaged in it were both over 18? 23 when she gave a second massage, correct? 24 MS. ARBOUR: Form. 24 A. Coned. 25 25 Q. And she never said anybody forced her to bring 22 (Pages 400 to 403) .( 561) 832-750.0 • PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricclull (601 Electronically signed by Jeana Ricciutf (601 c6062637-abo1-462c-a836-be614e314d7a EFTA00298234 Page 404 Page 406 1 a friend over fora third visit, correct? 1 scheduling communication, to the best of your knowledge, 2 A. Correct. . 2 based on all of your many conversations with your many 3 Q. And at most, your evidence reflected that 3 witnesses? 4 there were many young women that, in fact, called 4 MS. ARBOUR: Form. 5 Mr. Epstein's house seeking to come over to give him 5 THE WITNESS: Right massages, correct? .6 BY MR. WEINBERG:. 7 A. Yes, there were messages from various people 7 Q. And once they are at his house, none of the 8 that called. 8 girls claimed that he violently forced them to do 9 Q. And that when someone in Mr. Epstein's 9 anything they didn't want; is that correct? 10 residence called out to any of these young people, it 10 MS. ARBOUR Form. 11 was, at most, to schedule a visit, correct? • 11 MS. FINNIGAN: Form. 12. MS. ARBOUR: Form. 12 THE WITNESS: There was an instance where 13 THE WITNESS: Correct. 13 that was a vaginal penetration. 14 BY MR. WEINBERG: 14 BY MR. WEINBERG: 15 S None of these girls complained that MI 15 Q. And you recall, as soon as the person 16 or anyone else threatened them to come over? 16 protested, Mr. Epstein apologized and stopped that act; 17 A. No, there was no threats to come over, no. 17 is that right? 18 Q. No coercion to come over? • 18 MS. ARBOUR: Form. 19 MS. ARBOUR: Form. 19 THE WITNESS: I believe so, yes. 20 MS. FINNIGAN: Form. 20 BY MR. WEINBERG: 21 BY MR. WEINBERG: 21 Q. And that was Ms. Jane Doe 103? 22 Q. Is that correct? 22 A. Yes. 23 A. Not thatim aware of. 23 Q. And she was — turned 18 in December of 2004, 24 Q. None of the As ever told you that their 24 correct? 25 calls with were anything more than an 25 MS. FINNIGAN: Form. Page 405 Page 407 1 visitation to come over? 1 THE WITNESS: I'm not sure of the time frame 2 MS. ARBOUR: Form. 2 where she turned la. 3 BY MR. WEINBERG: 3 BY MR. WEINBERG: 4 Q. A scheduling call? 4 Q. Let me see if I can find this for you. At the 5 MS. ARBOUR: Same objection. 5 bottom of page 10 of that affidavit, on September I1, 6 BY MR. WEINBERG: 6 2005, WFAH, DOB, 12/30/1986 was arrested by the Palm 7 Q. Correct? 7 Beach Police Department That's the same Jane Doe 103 8 A. As far as l know, yes. 8 that we're talking about, correct? It's the very last 9 Q. And the same with anyone else in Mr. Epstein's 9 line. I'm only pointing out the date of birth. 10 household, no one ever said they got a phone call from 10 A. Yes. 11 anyone who lived at El Brillo doing anything roore than 11 Q. So she was 18 as of 12 seeing if they wanted to schedule a visit, correct? 12 correct? • 13 MS. ARBOUR: Form. 13 A. What page was that, I'm sorry? 14 THE WITNESS: I believe so. 14 Q. This is the bottom of page 10. 15 BY MR. WEINBERG: 15 A. She would have been 18, yes, in 2004. 16 Q. No one ever said they negotiated amounts of 16 Q. And she didn't • you a date on this one. 17 money on the phone; is that correct? 17 • A. 18 A. Not that I recall, no. 18 Q. 2004. And when you interviewed Ms. Jane Doe 19 Q. No one ever said that they were required to . 19 103 on October 10th and October 11th, and she told you 20 make promises of sexual performance on the phone as a .20 about this one event where there was momentary 21 condition of being invited to come over? 21 penetration, she protested, Mr. Epstein immediately 22 MS. ARBOUR: Form. • 22. apologized and ended that sex act, that she didn't give 23 . THE WITNESS: No, I don't believe so. 23 you a date that that occurred, did she? 24 ' BY MR. WEINBERG: 24 A. I can't recall if she did or she didn't. 25 so thophone part ofit was simply a 25 Q. If she gave you a date, it would be in the 23 (Pages 404 to 407) (561) 832-7500 PROSE COURT. REPORTING .AGENCY INC. : ..(561) 832-75OS. Electronically signed by Jeanie Ricciutl (601 Electronically signed by Jeans Ricciutl (601 a0828374ball-4112o-e8364:614.3 • 14dfa • • EFTA00298235 Page 408 Page 410 1 report - 1 about five or six-month period after she turned 18 on 2 A. Yes, sir. 2 3 Q. -- and if she didn't, either the didn't 3 A. I'm trying to recall, because I do remember 4 remember or she wasn't asked; is that right? 4 her stating that she was going less and less. I'm 5 MS. ARBOUR: Form. 5 trying to recall, because I know she was going less and 6 THE WITNESS: No, I know that I would have 6 less to his residence. 7 asked ha.. 7 Q. Do you recall writing in this probable cause 8 BY MR. WEINBERG: 8 affidavit that events that Jane Doe 103 advised you 9 Q. So if we don't have a date in the report as to 9. that her relationship continued to escalate during the 10 how long before October 10 and 11, 2005 that single 10 . period she saw Mr. Epstein? 11 event occurred, then she didn't remember; is that right? 11 A. From the beginning, yes. 12 MS. ARBOUR: Form. 12 Q. Yes, and we can — and this event where she 13 THE WITNESS: Can you ask that question one 13 said no and Epstein stopped, was an escalation of their 14 more time? 14 contact in an earlier appearance, correct? 15 BY MR. WEINBERG: A. I'm trying to recall. She had gone to his 16 Q. Sure If there's no date for that — 16 house — she had been going to his house for several 17 A. Then she did not recall that specific date. 17 years, and I think that was the escalation, what you . 18 Q. And therefore, since she was seeing 18 meant. 19 Mr. Epstein, according to what she told you, over some . 19 Q. And it's fair to say that some subset of those • 20 extensive period of tiro it could have occurred while 20 couple of years occurred after she turned IS, and a 21 she was — before or it could have 21 significant part of it was before she turned 18, 22 occurred after we just have no way of 22 coned? 23 knowing? 23 A. The significant part, I would say -- 24 A. It would have been before because one of the 24 Q. If there was two years and she graduated high 25 last times that she met with him was when she provided 25 school in the spring of 2005, then she saw him — part Page 409 Page 411 1 her high school transcript because he was going to 1 of it when she was 18, after she tamed 18 on 2 assist her in getting her into a college. 2 and part of it was before she walla, 3 Q. And when was that; a high school transcript? 3 correct? 4 The high school year ends in the spring? 4 A. I would assume so. 5 A. It would have been, yes. 5 Q. And she didn't give you a date when the single 6 Q. And not in December? 6 act, where she said no and Mr. Epstein stopped occurred, 7 A. Cornet 7. it's not in your report and you don't have an 8 Q. And so if she turned 18 in December, that 8 independent memory, correct? 9 would have been in the middle of her senior year in high 9 A. Correct. ' 10 school? 1.0 Q. How many times have you personally interviewed 11 A. Correct 11 Ms. Jane Doe 103? 12 Q. And therefore, she continued to see 12 A. !vane to say two. 13 Mr. Epstein after she was 18 and up to the period 13 Q. October in Tallahassee and then again in the 14 immediately before her graduation in the spring of 2005, 14 March period in Tallahassee again? 15 cornea? 15 A. One was in Jacksonville, one was in 16 Let me date it another way. She was a • 16 ' Tallahassee. 17 freshman at college when you went to see her in October 1.7 Q. And you have not personally seen her or 18 of 2005? 18 interviewed her since 2006? 19 A. Correct. ' • 19 A. I delivered a grand jury subpoena. 20 • . Q. Therefore, she was a senior in high school up • • .20 Q. To her in April 2006? 21 through the spring of 2005? 21 • A, I believe so. 22 A. Correct. 22 Q. And have you ever seen her since then? 23 Q. And therefore, since she gave Mr. Epstein her 23 _. , A. • No. 24 transcript, shortly before or at the time of her. 24 Q. Have you ever spoken to her since the grand 25 graduation, she was still seeing Mr. Epstein for this 25 jury returned an indictment against Mr. Epstein? 24 (Pages 408 to 411) .(561).832-7;500 PROSE COURT REPORTING AGENCY,...INC. ..(561). 832-7506. Electronically signed by Jeana Ricclutl (601 Electronically signed by Jeans 'Melon (601 e15062687-abe1-452c-a834143c8140314d7a EFTA00298236 Page 412 Page 414 1 A. I don't believe so. 1 Q. In other words, Mr. Epstein in now way 2 Q. Have you had any e-mails or text messages or 2 generated personal profits from any of his massages or 3 any communication with Ms. Jane Doe 103 in the last 3. contacts with any of the witnesses that were involved in 4 three and a half years? . 4 your case, correct? 5 A. No. 5 MS. ARBOUR; Form. 6 Q. So with Ms. M., just so I'm clear, there was 6 • THE WITNESS: Not that Fm aware of. 7 no intercourse between her and Mr. Epstein, correct? 7 BY MR. WEINBERG: 8 A. I don't believe so. 8 Q. You have no evidence that M. ever gave 9 Q. No oral sex that she complained of to you? 9 Mr. Epstein money or that ■ ever gave Mr. Epstein 10 A. No. 10 money as part of his share of these incidents, correct? 11 Q. No forced sex she complained of to you? 11 MS. ARBOUR: Form. 12 A. • No. 12 THE WITNESS: Not that I'm aware of. 13 Q. She never said that she had seen Mr. Epstein 13 BY MR. WEINBERG: 14 anywhere outside of his residence, correct? 14 Q. M. told you that she had met Mr. Epstein 15 A. What do you mean? 15 about a year before pa 2005 interview; do 16 Q. She never claimed that Mr. Epstein took her on 16 you remember that? 17 his airplane awhere? 17 A. Uh-huh. 18 A. Ms. IS? 18 Q. And her birth dater on 19 Q. Yes. 19 page 15 of your affidavit, 20 A. Not that I'm aware of. 20 A. Yes, sit 21 Q. And she never claimed that Mr. Epstein took 21 ' Q. So therefore, she was 18 in of 200s, 22 her on any trips outside of his private residence, 22 correct? 23 correct? 23 A. Yes. 24 A. Not that I'm aware of. 24 Q. So there she was 18 when you interviewed 25 Q. So the three or four times she and Mr. Epstein 25 her on 2005; is that right? Page 413 Page 415 / were physically in the same location, according to her, 1 • • A. Yes. 2 occurred exclusively on El Drilla; is that right? 2 Q. And if she met Mr. Epstein one year before 3 A. Yes. 3 your interview, then she met him when she was 17? 4 Q. Let me switch to another person 4 A. Or depending on the date when she met him, she 5 interviewed, M. Do you remember 5 could have been on the edge of 16, beginning of 17. 6 A. Yes. 6 Q. And do you recall who introduced her to 7 And do you remember interviewing her in 7 Mr. Epstein? 8 of 2005? 8 A. 1 believe it was , maybe. 9 A. That would have been around that time. 9 Q. And if your report reflects would that be 10 Q. By the way, just let me step back one second. 10 lime Doe 103? 11 When Ms... brought another girl to Mr. Epstein's 11 A. Yes. 12 home, she told you she, Ms. was paid for that; is 12 Q. And she, like the others, was introduced to 13 that right? She was paid — 13 Mr. Epstein by a third party, one of their friends; is 14 A. Yes. 14 that right? 15 Q. You have no evidence in this case that any of 15 MS. ARBOUR: Form. 16 the girls who gave Mr. Epstein massages ever paid money 16 . • THE WITNESS: rm sorry? 17 to Mr. Epstein? 17. BY MR. WEINBERG: 18 A. What do you mean? 18 Q. Like others, she, M. was introduced to 19 Q. There is no money flowing back to Mr. Epstein, 19 Mr. ein by another young girl that was friends with 20 or to any of the people employed by Mr. Epstein, from 20.. Ms. M., correct? 21. any of the young women that gave him massages at his • 21 A. Yes. 22 house, correct? 22 . Q. And that, in this case, was Ms. Jane Doe 103, 23 A. That money went back to Mr. Epstein? 23 correct? 24 Q. Yes. 24 A. Yes. 25 A. Not that fm aware of. 25. Q. And Ms. Jane Doe 103 took her to Mr. Epstein's 25 (Pages 412 to 415) PROSE COURT REPORTING AGENCY,".INC.. : Electronically signed by Jeana RIcciuti (601 Electronically signed by Jeana Rlcciuti (601 660624337-abirt-462o-a836441114•314Ca EFTA00298237 Page 416 Page 418 1 house, correct? 1 THE WITNESS: What do you mean "profited"? 2 A. Yes. 2 BYMR. WEINBERG: 3 Q. And does your report affidavit reflect a 3 Q. He didn't make any money by seeing., 4 had heard that several girls were making money by 4 correct? 5 providing massages to Epstein and she agreed and was 5 MS. ARBOUR: Same objection. 6 taken to the house by Ms. Jane Doe 103? 6 THE WITNESS: Not that Tin aware of. 7 A. Yes. 7 BY MR. WEINBERG: 8 Q. So Ms. Jane Doe 103, like Ms. would tell 8 Q. He, at most, paid for the massages he 9 people, you know, that if they went to see Mr. Epstein, 9 received, correct? 10 they were expected to give him a massage, correct? 10 MS. ARBOUR. Form. 11 MS. ARBOUR Form. 11 BY MR. WEINBERG: 12 THE WITNESS: Possibly, yes. 12 Q. That's what Ms... represented to you? 13 BY MR. WEINBERG: 13 A. Yes. 14 Q. And in this case, at least, Ms. a. went 14 Q. And on one occasion, she said when she was 17, 15 there with her eyes open? In other words, she 15 she consensually agreed to engage in sex with 16 volunteered to go there and try to make money by giving 16 Mr. Epstein, correct? 17 Mr. Epstein a massage just like she understood several 17 A. Yes. 18 other girls in her community had done? 18 Q. Nobody threatened her, right? 19 A. Correct. 19 A. Not that I'm aware of. 20 MS. ARBOUR: Form. 20 Q. She seemed like a relatively mature 21 BYMR. WEINBERG: 21 18-year-old when you spoke to her? 22 Q. And Ms. like others, never complained to 22 A. Yes. 23 you, she never wont to you herself before you went to 23 Q. And this occurred just shortly before her 24 her; is that right? 24 interview with you, correct? 25 A. Correct. 25 A. What do you mean "shortly before"? Page 417 Page 419 1 Q. And she didn't initiate any complaints through 1 Q. Meaning that her recollection that on one 2 any parent, teacher, medical professional, law 2' occasion she had had sex with Mr. Epstein, consensual 3 enforcement officer or anybody else to your knowledge? 3 sex occurred shortly before she was interviewed by you .4 A. Not to my knowledge. 4 in of 2005, correct? . 5 Q. And be went directly to her because she was S A. Right. 6 18 in correct? 6 Q. She, too, introduced others to Mr. Epstein. 7 A. Correct 7 did she not? . 8 Q. And she told you that she, in fact, during the 8. A. Yes, I believe so. 9 first time, wearing thong panties, gave Mr. Epstein a Q. And do you ranentber interviewing her — within 10 massage, coual? 10 a week of your interview with Ms. a., you interviewed 11 A. Yes. 11 someone with the initials.? We can find this on 12 Q. And that she received money for that, correct? 12 page 16? 13 A. Yes. 13 A. Yes. 14 Q. And there was no prior arrangement of money 14 Q. At the bottom of page 16 of the affidavit, 15 for sex, so this, too, was not prostitution, correct? 15 Detective Samut (phonetic) and you on November 15th, met 16 A. Correct. 16 and during the sworn statement said she had met 17 Q. And she returned 15 times to Mr. Epstein's 17 Mr. Epstein a year . And she was — her date of 18 residence, correct? 18 birth on this report i Do you see that 19 A. A total of, yes, that's what she recalled. 19 four lines up on the bottom of 16? 20 Q. On at least one of the occasions, she was with 20 A. It would have been M. Is that the one 21 Ms. Jane Doe 103 who was also was paid $200, correct? 21 you're talking about? 22 A. Correa. 22 Q. This is on the bottom of page 16, 23 Q. And Mr. Epstein, in no way financially 23 . "November 15th, Detective Samut and I met with a. 24 profited from his relationship with correct? 24 A. You're on — yeah. 25 MS. ARBOUR: Form. 25 Q. I'm probablyon a different-page than you. Do 26 (Pages 416 to 419) (561) 832-7500. PROSE COURT-REPORTING AGENCY, INC. Electronically signed by Jeana Ricciull (601 Electronically signed by Jeana Ricciutl (601 c6062637-abe1-452c-a836-bc614e314d7a EFTA00298238 Page 420 Page 422 1 you see the four lines from the bottom, short paragraph? 1 2 A. Yeah, right. 2 BY MR. WEINBERG: 3 Q. "f, date of birth, n 3 Q. Well, it could even be M.? 4 Correct? 4 A. It could have been the person who actually 5 A. Right. 5 brought than. 6 Q. So she said she met Mr. Epstein though • 6 Q. And that any massage that occurred always 7 correct? 7 occurred on the second floor of Mr. Epstein's El Brillo 8 A. I believe so. 8 residence, correct? 9 Q. AndMs.. was accurate with her in saying MS. ARBOUR: Earn. 10 to her that she could make 5200 giving Mr. Epstein a 10 TILE WITNESS: I believe so. 11 massage? 11 BY MR. WEINBERG: 12 A. Yes. 12 Q. By *always,' I mean of all of the witnesses 13 Q. AndMs... said the massage would have to be 13 that were interviewed by them, they told you that they 14 topless, correct? 14 went upstairs with someone and entered a room where 15 A. I believe so, yes. 15 there was a massage table when Mr. Epstein came into the 16 Q. And.. returned several times to 16 room, correct? 17 Mr. Epstein's horn; voluntarily, correct? 17 MS. ARBOUR: Form. 18 A. I believe so. 18 THE WITNESS: Correct. 19 Q. Meaning, she agreed to go with Ms.. the 19 BY MR. WEINBERG: 20 first time and meet Mr. Epstein and give him what she 20 Q. Now, in 2003 you conducted a very different 21 knew would be a topless massage? 21 kind of criminal investigation that related to the same 22 A. I don't know if the word "topless" came in, 22 residence at El Brillo on Palm Beach, correct? 23 but I know it was a massage. 23 A. Arc you talking about the burglary case? 24 Q. Take a look at the second — top of the 24 Q. Yes. 25 sentence of the next page. Ifs at the very top, the 25 A. That wasn't my case, but I assisted. Page 421 Page 423 1 top two words. 1 Q. You were a participant in the investigation 2 A. "Massage topless," okay. 2 burglary when Mr. Epstein was the victim, correct? 3 Q. And again, she was, like WI of the other 3 A. Correct. 4 girls had no prior communication with Mr. Epstein, 4 Q. As part of your assistance, you brought 5 Ms. or anyone at the El Brillo home before she 5 certain cameras into Mr. Epstein's home; is that 6 arrived there physically the first time, correct? 6 correct? 7 A. Correct. 7 A- Correct 8 Q. And there were no negotiations that you knew 8 Q. And do you recall that Mr. Epstein shared with 9 of, you know, where prices were discussed, correct? 9 you that he, himself, attempting to identify who was 10 MS. ARBOUR: Form. 10 stealing money from him, had gone out and for the 11 THE WITNESS: Not that I'm aware ot yes. 11 purpose of making that identification, had purchased 12 BY MR. WEINBERG: 12 certain cameras himself? 13 Q. And what these girls repeatedly told you is 13 A. I believe so, yes. 14 that they went to Mr. Epstein's home, invited by one of 14 Q. And that he installed them so that the camera 15 their friends? 15 was poking out of a camera on the first floor of his 16 MS. ARBOUR: Form. 16 residence, directed towards his desk area where he left 17 THE WITNESS: They were invited by one of 17 a bag that commonly had United States currency, correct? 18 their friends or associates. 18 A. I wasn't sure if it was the bag or the drawer, 19 BY MR. WEINBERG: 19 but it was focused on the desk area. 20. Q. Came into the first floor and were taken by 20 Q. Camera, first floor directed to the desk area? 21 somebody up to the second floor, correct? 21 A. Yes. It was a bookshelf behind. It was like 22 A. Correct 22 an L bookshelf. 23 Q. And that somebody was usually-? 23 Q. And that you came in and supplemented those 24 MS. ARBOUR: Form. 24 cameras to try to help Mr. Epstein identify this thief, 25. THE. WITNESS: or, on occasion, it was a 25 correct? 27 (Pages 420 to 423) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Medal (601.280.428-9381) Electronically signed by Jeans RIccluti (601-280428.9381) O5062637-abel-452c-a8364x614e314d7a EFTA00298239 Page 424 Pogo 426 1 A. Correct. 1 A. I know that was some of their concerns, but I 2 Q. And you, thereafter, took out your cameras 2 don't believe anyone specifically came out and said, "I 3 when the thief was identified by Mr. Epstein, correct? 3 was videotaped". 4 A. Correct. 4 Q. Right. Nobody told you that the massage was 5 Q. And the thief was identified through 5 videoed, to their knowledge? 6 photographs of this desk area on the first floor of 6 A. To their knowledge, no. 7 Mr. Epstein's residence, correct? 7 Q. And nobody told you that they had seen a 8 A. I believe so, yes. 8 camera in the massage room on the second floor of 9 Q. And you never saw a camera in the massage room 9 Mr. Epstein's residence. 10 on the second floor of Mr. Epstein's residence during 10 A. I don't recall, because like I said, I know 11 this 2003 period, correct? 11. that was one of the concerns. 12 A. I never went upstairs. 12 Q. I want to separate out a concern from what 13 Q. None of the girls said that the massages was a 13 they told you they saw. No one ever told you they saw a 14 videoed or a photographed event, did they? 14 camera on the second floor of Mr. Epstein's residence? 15 A. One of the girls recalled having their 15 A. I don't recall. I don't recall someone saying 16 photograph taken while in a tub. 16 that they saw a camera. I know that there was concerns 17 But no, I never went upstairs during that 17 that the incident was videotaped. 18 investigation, so I don't know if there was any covert 18 Q. And they expressed to you that was just a 19 cameras up there, so... 19 speculative subjective concern, but that they did not 20 Q. You don't know that there was one, correct? 20 see a camera videotaping any massage; is that correct? 21 A. Correct 21 MS. ARBOUR: Fonn. 22 Q. And the only covert camera you knew of was the 22 THE WITNESS: Not that I can recall. 23 one that Mr. Epstein disclosed to you, correct? 23 BY MR. WEINBERG: 24 A. Correct 24 Q. You interviewed roughly 30 different women 25 Q. And he disclosed it to you in saying he 25 that had been to Mr. Epstein's home, correct? Page 425 Page 427 • 1 purchased it, correct? 1 A. Yes. . 2 A. Yes. 2 Q. Some over 18 and some under 18, correct? 3 Q. And he purchased it from a spy store, a store 3 A. Yes. 4 that sold such covert cameras, correct? 4 Q Some over 18 when you interviewed than, some 5 A. Yes. 5 said that they had been there when they were under 18, 6 Q. And he told you, you as a law enforcement 6 correct? 7 officer, that he had done so for a specific purpose, 7 MS. ARBOUR: Form. 8 correct? 8 THE WITNESS: Correct. 9 A. It was for that case, yes. 9 13Y MR. WEINBERG: 10 Q. Right. To identify someone who was 10 Q. And not a single one of those 30 people told 11 responsible for the theft of currency from the desk area 11 you that they saw a camera on the second floor of 12 on the first floor? 12 Mr. Epstein's residence, correct? 13 A. I believe it was currency and a gun, if Fm 13 MS. ARBOUR Form, asked and answered. 14 not mistaken. 14 THE WITNESS: I can't recall if anybody 15 Q. And he neva told you he had ever, on any 15 specifically crime out and said that they saw a 16 other occasion, purchased a covert camera, correct? 16 camera or not 17 A. Not that I'm aware og no. 17 BY MR. WEINBERG: 18 Q. And with the exception of this one girl who 18 Q. Nobody, to your current recollection, told you 19 said she was photographed in a tub, no other girl told 19 that they saw videotaping of any massage that occurred 20 you that they were photographed, correct? 20 in Mr. Epstein's residence or any sexual contact that 21 A. I don't believe so. 21 occurred in Mr. Epstein's residence, cored? 22 Q. No girl told you that they were videoed, 22 MS. ARBOUR: Form. . 23 correct? And by "no girl," I mean none of the girls 23 THE WITNESS: Not that I can recall. 24 that you interviewed in connection to your 2005 24 BY MR. WEINBERG: 25 investigation of Mr. Epstein. 25 Q. And nobody said that they had ever seen a 28 (Pages 424 to 427) ' PROSE COURT REPORTING AGENCY INC.. (561) 832-7506 ' Bectronlcally signed by Jeans RIcclutl (601 . Electronically signed by Jeans RIcclud (601 c6062637-abel-452c-a836-bc614e31467a EFTA00298240 Page 428 1 photograph of themselves in Mr. Epstein's residence with 1 MS. ARBOUR: Form. 2 one exception, that being Jane Doe 103, who claimed that 2 THE WITNESS: Yeah Yes. 3 a photo was taken ofha in a tub, correct? 3 BY MR. WEINBERG: 4 A. I believe it was just Jane Doe 103. 4 Q. Jennifer Doe 4, do you recall her? 5 Q. Right. Not any of the other 29 or so 5 A. Do you mean Jane Doe 4? 6 witnesses that you interviewed, correct? 6 Q. I'm sorry, Jane Doe 4. 7 MS. ARBOUR: Form. A. Yes. 8 THE WITNESS: Right. 8 Q. Do you recall interviewing her in or around 9 BY MR. WEINBERG: 9 October 6, 2005? 10 Q. And when you enteral Mr. Epstein's home, 10 A. Yes. 11 pursuant to judicial authorization on October 20th, you 11 Q. And do you recall reciting to a judge in a 12 were looking for photographs, were you not? 12 probable cause affidavit certain statements that 13 A. Yes. 13 Ms. Jane Doe 4 made to you? 14 Q. And you did not fmd the photo of Ms. Jane Doe 14 A. 'recall! put in — I put in a lot of 15 103 that she said was taken ofher in a tub, correct? 15 information that had been gathered during the 16 A. Carat. 16 investigation for the search warrant. 17 Q. And Ms. Jane Doe 103 didn't tell you how many 17 Q. And is it fair to say that — and I want to 18 months before October 10 and 11, 2005, the dates of your 18 focus you on the probable cause affidavit rather than 19 interview with her, that photo was taken, correct? 19 the search warrant affidavit, because that's the one 20 A. She did not give a specific date, no. 20 that's in evidence as Exhibit 1, that you said 21 . So once a in remembering back, she turned 18 21 therein — it's on page 9 if you want to work through 22 on The photo could have been taken 22 Ms. Jane Doe 4 with me — that you interviewed her on 23 after she was 18, before she was 18, correct? 23 October 6, 2005? That's the bottom paragraph. 24 A. It could have been either one. 24 A. Yes. 25 Q. And she never claimed that Mr. Epstein was in 25 Q. And that her date of birth was Page 429 Page 431 1 the tub with ha, did she? 1 is that correct? 2 A. No. I believe was with her. 2 A. Yes. 3 Q. At the time of the photo? 3 Q. So at the time you interviewed her, she was 4 A. Yes. 4 over 18, correct? 5 Q. You're certain she said that? S MS. ARBOUR: Fonn. 6 A. I believe so. 6 THE WITNESS: I believe so, yes. 7 Q. Is there any reason that you didn't say that 7 BY MR. WEINBERG: 8 in your report? 8 Q. And you interviewed her at University? 9 MS. ARBOUR; Form. 9 A. Yes. 10 THE WITNESS: Again, I'm going off 10 • Q. And you explained to her why you were there, 11. recollection. 11 cared? 12 BY MR. WEINBERG: 12 A. Yes. 13 • Q. Okay. 13 Q. Which is, that you were conducting a criminal 14 A. I believe that's what she said tome. 14 investigation of Jeffrey Epstein? 15 Q. AndI'll go back. Is them any reason —1 15 A. That is correct. 16 represent to you that's not in your 87-page incident 16 Q. And that's a practice you used when you were 17 report Is there any reason you would have omitted such 17 introducing yourself to either the adult witnesses who 18 a description of the type of photo that Ms. Jane Doe 103 18 had turned 18 or the parents of the minor witnesses, 19 was claiming to you was taken ofher in the tub? 19 correct? • 20 A. No, I would have not omitted anything from the 20 MS. ARBOUR: Form. • 21 report. 21 THE WITNESS. Correct. 22 Q. So, therefore, that would have been the kind 22 BY MR. WEINBERG: 23 of detail that you would have included in the report if, 23 Q. And Ms. Jane Doe 4 told you that she was aware 24 • in fact, you recalled it happening at or around the time 24 of the ongoing investigation; is that correct? 25 you wrote the report, correct? 25 A. Yes. • 29 (Pages 428 Lo 43].} PROSE COURT REPORTING. AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeann Ricciuti (601 c5062637-abo1-452c-a836-hc614e314d7a EFTA00298241 Page 432 Page 434 1 Q. And neverthelms, she agreed that she would 1 Q. And she told you that she was comfortable with 2 Speak to you; is that right? 2 what she was doing? 3 A. Correct 3 MS. ARBOUR: Form. •4 Q. And she told you that she had known..? 4 BY MR. WEINBERG: 5 A. Yes. ' . 5 Q. Let me put it another way: That if she was 6.. Q. And thatIMI. was the person who introduced 6 uncomfortable, she would not do what she was 7 her to Jeffrey Epstein? 7 uncomfortable in doing, correct? MS. ARBOUR: Form • 8 MS. ARBOUR: Same objection. 9 THE WITNESS: I believe so. 9 THE WITNESS: •Right. 10. BY MR. WEINBERG: 10 BY MR. WEINBERG: 11. Q. And again, this was not a meeting that was — 11 Q. In other words — 12 . the introduction of Jane Doe 4 to Epstein by IMI. was 12 A. It was actually even stated in the — that if 13 not preceded by — 13 she felt uncomfortable, to say so and Mr. Epstein would 14 ' (Ms. O'Connor exits the proceedings.) 14 stop pushing the issue. 15. MR. PIKE: Go ahead and finish the question, 15 Q. And she wasn't the tint person that told you 16 • but then don't answer until your attorney returns, 16 this; is that correct? 17 okay? 17 MS. ARBOUR: Fenn. 18 MR. WEINBERG: Well, we can withdraw that 18 THE WITNESS: I believe so. I believe she 19 question and take a five-minute break. Let's take 19 wasn't the only one. 20 a break. 20 BY MR. WEINBERG: 21 (A briefrecess was taken.) 21 Q. And you interviewed a number of people that 22 (Ms. O'Connor re-joins the proceedings.) 22 told you that Mr. Epstein would ask them to take off all 23 24 • 25 . BY MR. WEINBERG: Q. Page 9 on date of birth is aaffidavit. Doe Ms. So as 24 comfortable 4's felt Jane they we with and • and she was 18 at the time of 23 25 thek clothes, and they would take off as much clothes re not forced to take off any remaining clothes, correct? Page 433 Page 435 1 your interview, correct? 1. A. I know that there were, I believe., one or two 2 A. I believe so. 2 that went down to their bra and panties when he told 3 Q. And since your interview was in October and 3 . them to get comfortable. And during the interviews, 4 her birthday was in she had been 18 for 4 Mr. Epstein stated to take off either their bra and/or 5 months? 5 panties. is A. (Non-verbal response). 6 Q. And they would either do it or not do it, 7 Q. Is that correct? 7 depending on their choice, correct? 8 . MS. ARBOUR Form. 8 MS. ARBOUR: Fon. 9 THE WITNESS: I believe so. 9 THE WITNESS: Correct 10 . BY MR. WEINBERG: 10 BY MR. WEINBERG: 11 Q. And she toldott that she had been introduced 11 Q. I mean, none of them said Mr. Epstein tore 12 to JeffEpstein byM., correct? 12. their clothes off — 13. A. Correct. • 13 A. No. 14 Q. And that she, like others who Ms... brought 14 Q. — over their objection? 15 to Mr. Epstein's house, knew that the purpose for which 15 A. No. 16 she was going was to give a massage and receive some 16 MS. ARBOUR: Form. .17 . money, correct? 17 BY MR. WEINBERG: 18 MS. ARBOUR: Form. 18 Q. And all of them told you that he respected the 19 THE WITNESS: I believe so, yes. 19 limits that they set; he didn't physically overcome 20 BY MR. WEINBERG: 20 their limits, correct? 21 Q. • And she told you that she had been there lots 21. MS. ARBOUR: Form: 22 of times over two years, correct? 22 THE WITNESS: There was one girl in 23 .. MS: ARBOUR: Form. . 23 .particular, I can recall, where he was massaging 24 THE WITNESS: Yes. Yes. 24 her vagina and told her to relax, I'm not going 25 BY MR. WEINBERG: 25 inside. And she claimed that during the massage, 30 (Pages 432 to 435) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciutl (601 Electronically signed by Jeans Riccluti (601 c5662637-abet-452c-a836-bc614e314d7a EFTA00298242 Page 436 Page 438 1 he did go inside digitally, but — not force make similar allegations, correct — 2 himself it was just the incident we talked about. 2 MS. ARBOUR: Form. 3 BY 'MR. WEINBERG: 3 THE WITNESS: Right 4 Q. And then she said no and he stopped, coned? 4, BY MR. WEINBERG: 5 MS. ARBOUR: Form. ' 5 Q. — who told you that Mr. Epstein deferred to 6 THE WITNESS: i think she pulled back. 6 .the limits they set, to the massage and to whatever 7 BY MR. WEINBERG: occurred in connection with the massage? 8 • Q. And he didn't try it again? 8 MS. ARBOUR: Form. 9 • MS. ARBOUR: Fonn. 9 THE WITNESS: Yes. 10 THE WITNESS: He withdrew his forgers, yes. 10 BY Mk W13INBERG: .11 . BY MR. WEINBERG: 11 Q. Ms. Jane Doe 4 was one of those people who 12 Q. And with the exception of that girl, you 12 told you that she told Mr. Epstein she had a boyfriend 13 interviewed girl after girl after girl that said that 13 and would not go beyond certain limits, correct? 14 limits were set and respected? 14 MS. ARBOUR: Form. 15 - MS. ARBOUR: Form. 15 -THE WITNESS: I believe so. 16 THE WITNESS: Aside from the — Ms. Jane Doe 16 BY MR. WEINBERG: 17 103's. 17 Q. And that she told you that she went to 18 BY MR. WEINBERG: 18 Mr. Epstein's house on a number of occasions and that 19. Q. Yes, taking aside Ms. Jane Doe 103 and the one 19 she provided massages to Mr. Epstein, correct? 20 other girl you just mentioned, you interviewed 20 or 30 20 A. Yes. 21 others who made no similar complaint to you, correct? 21 Q. And that when she expressed feeling 22 MS. ARBOUR: Form. 22 uncomfortable, Mr. Epstein would stop pushing whatever 23 THE WITNESS: Correct. 23 was the issue that caused her to say she felt 24 BY MR. WEINBERG: 24 uncomfortable, correct? 25 Q. And they instead said that limits were set by 25 MS. ARBOUR: Form. Page 437 Page 439 1 themselves and then Mr. Epstein deferred to those 1. THE WITNESS: I believe that's what Ms.. 2 limits? 2 told her. 3 MS:ARBOUR Form. 3 • BY MR. WEINBERG: 4 THE WITNESS: As I recall -- see, I recall, . .4 Q, And that's what she said was her experience, 5 like, interviewing Ms. Jane Doe 103 where she said 5 too? .6 things became escalating, so I don't know what 6 MS. ARBOUR: Form. limits you're referring to. 7 THE WITNESS: Yeah.' 8 BY MR. WEINBERG: BY MR. WEINBERG: 9 Q. With the limit set by It Jane Doe 103 wherein Q. In other words, Ms... told her, you set the 10 on one occasion you said Ms. Jane Doe 103 objected and 10 limits, youknow, and those limits were being respected, 11 Mr. Epstein stopped. There was no other indication from 11 correct? 12 Ms. Jane Doe 103 that she objected, correct? 12 MS. ARBOUR: Form. 13 A. That was the time where — 13 THE WITNESS: I believe so. 14 Q. Right. But for that time, Ms. Jane Doe 103 14 'BY MR. WEINBERG: • 15 never told you that she told Mr. Epstein, don't do that, . 15 Q. And that Ms. Jane Doc 4 corroborated that, in 16 and he did anyway? 16. fact, when she set limits, Mr. Epstein respected them? 17 A.- And that other incident involving the other 17 MS. ARBOUR: Form. 18 girl, which I believe was Jane Doe 2, where the 18: • . THE WITNESS: I believe so. 19 insertion of the fingers. 19 BY MR. WEINBERG: 20 Q. And she pulled away and that ended the •. • 20 Q. And Ms. Jane Doe 4.said that during the period 21 incident, correct? 21 that she was going there, that it was not until, quote, 22 . MS. ARBOUR: Form. 22 : recently, that Jane Doe 4 even began removing her • 23 THE WITNESS: Yeaklbelieve that was — 23 clothes and staying in her thong underwear to provide a 24 BY MR. WEINBERG: 24 • massage, correct? 25 Q. 'You interviewed 28 Other people who didn't 25 A. Correct. itv=est 31 (Pages 436 to 439) PROSE. COURT REPORTING 'AGENCY, ('561)"832-75O.6 Electronically signed by Jeana Rlcciutl (601 Electronically signed by Jeana RicciutI (601 00526.37413•1452e-s836-be614•314d7a EFTA00298243 Page 440 Page 442 1 Q. In other worth, through the vast majority of 1 Q. So certainly, with Ms. Jane Doe 4, that was 2 the period she was seeing Mr. Epstein, she was giving 2. • no indication that Mr. Epstein ever did anything except 3 Mr. Epstein massages that she represented to you were 3 defer to the limits that she set on her massage, 4 given with most of her clothes on? 4 correct? 5 MS. ARBOUR: Form. 5 MS. ARBOUR: Fenn. 6 THE WITNESS: That's what 1— that's what she 6 THE WITI•IFSS: She did state that he would try 7 claimed, yes. 7 to get away with more and more on each massage, 8 BY MR. WEINBERG: 8" which was quoted in the PC, but... 9 Q. And that Ms. Jane Doe 4, like others, said 9 BY MR. WEINBERG: 10 that she was driven over by the person that introduced 10 Q. Right. All sbe had to do was say no, and he 11 her, in this case, Ms. M.? 11 stopped. 12 MS. ARBOUR: Form. 12 • MS. ARBOUR: Form. ' • 13. THE WITNESS: Right. 13. THE WITNESS: That's pretty much what she 14 BY MR. WEINBERG: 14 stated. 15 !,I ; That she would be met on the first floor by 15 BY MR. WEINBERG: 16 = correct? 16 Q. With all of the women you interviewed, they 17 A. Correct. 17. were brought to the house by somebody else who was one 18 Q. That she would voluntarily accompany 18 of their friends: is that correct? 19 upstairs, correct? 19 MS. ARBOUR: Form. 20 MS. ARBOUR: Foam. 20 BY MR. WEINBERG: 21 THE WITNESS: Correct. 21 . Q. Or associates? 22 BY MR. WEINBERG: 22 MS. ARBOUR: Same objection. 23 Q. And that the massage was always in the 23 THE WITNESS: Pretty much. 24 upstairs area, correct? 24 BY MR. WEINBERG: 25 MS. ARBOUR: Form. 25 Q. And it was common practice during these events Page 441 Page 443 1 THE WITNESS: Correct. 1. for the person who brought them to stay at the house 2 BY MR. WEINBERG: 2 during at least the first of the massages, correct? 3 Q. And nobody ever told you that they had engaged '3 MS. ARBOUR: Form. 4 in any sexual activity with Mr. Epstein in his lust 4 THE WITNESS: Correct. 5 floor office, did they? 5 BY MR. WEINBERG: 6 A. Not that I can recall, no. 6 Q. So that, for instance, Ms. M. stayed at the 7 Q. Or that he ever received a massage in his 7 house while Ms Jane Doe 4gave Mr. Epstein a massage 8, first floor office, cornea? And by "office," I mean 8 for the first time, correct? 9 that area that that theft of money from his bag a MS. ARBOUR: Font 10 • drawer occurred two years before. • . 10 INE.WITNESS. 'believe so. 11 A. Not that I can recall. • . 11 BY MR. WEINBERG: . 12 Q. And Ms. Jane Doe 4 continued to tell you that 12 er And Ms. M. stayed at the house while 13 as she described her massages, that on one occasion, 13' Ms. M. gave Mr. Epstein a massage for the first time, 14 Mr. Epstein grabbed her buttocks and when he tried to 14 correct? 15 touch her breasts, she would pull away, tell him to stop 15 • A. Correct. 16 and he would stop, correct? 16 Q. When you interviewed Ms. M., she never told 17 MS. ARBOUR: Form. 17 you that she heard anybody scream or complain or object 18 Tim WITNESS: Yes. 18 or protest the massage while she was in the house, 19 BY MR. WEINBERG: 19 correa? 20 Q. And that, likewise, she said that she set . 20 MS. ARBOUR: Form. 21'. limits and would not permit Mr. Epstein to in any way 21 THE WITNESS: I did recall an incident 22 we a vibrator, correct? 22 U. involving a girl by the name of - 23 . MS. ARBOUR: Form. 23 BY MR. WEINBERG: • • 24 WITNESS: Correct 24 Q. Risk. 25 BY MR. WEINBERG: 25 A., where.r think the* was a disagreement 32 (Pages 440 to 443) PROSE COURT REPORTING AGENCY; . • 1561) 832-7 5 0 6 Electronically signed by Jeana Mcclull (801M Electronically signed by Jeana Moduli (601 c6062637-abut -452c-a836-bc614e314d7a EFTA00298244 Page 444 Page 446 1 between Mr. Epstein and Ms. M. and there was -- 1 A. Yes. 2 Q. She was upset — 2 Q. How long before the prior deposition was that 3 A. — she was upset, and I think she left and no 3 meeting? 4 moneys were paid. 4 A. It was actually documented in the report. I 5 Q. Right. And didn't she come back a second time 5 did a supplement to that nature. I want to say a month, 6 even though she was upset the first time? 6 a month before, a month and a half prior. 7 MS. ARBOUR: Form. 7 Q. So this is in 2010? 8 THE WITNESS: Yes, she did. 8 A. Yes. 9 BY MR. WEINBERG: 9 Q. And this was shortly before the fu•st day of 10 Q. And with that exception, there was no other 10 the current deposition? 11 representation made to you by any of the friends of the 11 A. Yes. 12 masseuses or the people that introduced them to 12 Q. And you wrote a report about meeting with 13 Mr. Epstein, that any of the people that gave him a 13 Mr. Kuvin? 14 massage ever had a conflict that they complained about 19 A. Ult•hult 15 verbally or screamed or yelled in the house, correct? 15 Q. And that tt.po. t is available to us as a public 16 MS. ARBOUR: Form. 16 record? 17 THE WITNESS: Not that fm aware of, no. 17 A. Yes. It's with the case number. 18 BY MR. WEINBERG: 18 Q. And the case number being the '06 number or 19 Q. And there were occasions, were there not, 19 the '05 number? 20 where some of these girls that went to Mr. Epstein's 20 A. Thc '05 — well, ifs cross referenced back 21 house to give massages had boyfriends? 21 and forth, so... 22 MS. ARBOUR: Form. 22 Q. And do you recall what the content of the 23 THE WITNESS: I believe so. 23 conversation between you and Mr. Kuvin were? 24 BY MR. WEINBERG: 24 A. It really wasn't much. I mean, I told him — 25 Q. And on occasion, the guys took the girds to 25 he asked about certain things within the report; I Page 445 Page 44"/ 1 the house — 1 referred him to the report That was basically it. 2 MS. ARBOUR: Form. 2 Q. Was there any discussion of the subjects that 3 BY MR. WEINBERG: 3 he intended to ask you about during the deposition? 4 Q. — since someof them didn't drive? 4 A. No. He bad asked me some certain things 5 A. I'm trying to think. I know some took taxis, regarding the report, and I just referred him to the 6 I know — I wouldn't know if the boyfriends took them (): 6 report. I was like, no, it's documented. 7 not. 7 Q. Did he al you whether there was any current 8 Q. Let me ask you some different kind of 8 investigation ongoing regarding Mr. Epstein? 9 questions as we work our way to the lunch break. 9 A. I don't believe so. 10 • Have you discussed your testimony with any of 10 Q. Did he tell you that he was aware of an 11 the Plaintiffs' lawyers before corning to the first 11 ongoing investigation being conducted by another agency? 12 deposition last month? 12 A. I daft believe so. 13 A. I spoke with Mr. KUVI11. 13 Q. Did he discuss with you any knowledge that he 14 Q. Yes. 14 possessed regarding any ongoing Federal investigation? 15 A. I met with him at Starbueks in West Palm prior 15 A. No, not that i was aware of. 16 to the depo. 1.6 Q. Did he try to motivate you to recommence a 17 Q. And did he ask you to meet with him or did you 17 criminal investigation of Mr. Epstein? 18 ask to meet with him? 18 A. No. 19 . A. He had called me and asked to meet with me. 19 Q. Are you engaged in any ongoing criminal 20 Q. And did he tell you the purpose of meeting 20 investigation of Mr. Epstein? 21 with you was to try to talk to you about the Epstein 21 A. No, I am not, and... 22 case? 22 Q. Do you know whether anyone else in your 23 A. I believe so. 23 • department is? 24 Q. And you agreed and went and met with him, 24 A. Nopc. 25 correct? 25 Q. Same questions for Mr. Edwards: Did you ever 33 (Pages 444 to 447) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (801 Electronically signed by Jeana Ricciuti (601 c6062637-abe1-462c-a836-bc614o314d7a EFTA00298245 Page 448 150 1 have any communications with Mr. Edwards prior to the 1 Q. And Mr. Garcia? 2 start of the deposition that was on March 19, 2010? 2 A. No. 3 A. I did speak with Mr. Edwards by telephone some 3 Q. And anyone from Mr. Josefsberg or anybody fro 4 time ago. It might even bo documented in the report us 4 his law firm? 5 well. 5 A. No. 6 Q. What's your memory of that conversation? Who 6 Q. How about investigators, did you know a man 7 called who? 7 nano listen? 8 A. He called me. There was some reference to a 8 A. No. 9 girl that was, what he claimed, was not on the part of 9. Q. Fandrey? 10 the original investigation; that he has a client. I 10 A. No. 11 referred him to the FBI, because everything had been 11 Q. Jenne? 12 turned over to the FBI, so... 12 A. No. 13 Q. So he called you to see whether or not his 13 Q.' Has any private investigator ever attempted to 14 client was in any way included in your prior 14 interview you regarding Jeffrey Epstein? 15 investigation? What exactly do you recall him saying? 15 A. No. 16 A. It was he has or had a client, I'm not 16 Q. Has any private investigator ever informed you 17 really sum. 17 that they were conducting surveillance on Jeffrey 18 Q. Did he name the client? 18 Epstein's residence? 19 A. No. 19 A. No. 20 Q. How would you know whether or not his client 20 Q. Did you have occasion to learn that any 21 was included? 21 private investigator was ever conducting a nighttime 22 A. We have nothing at the police department. 22 surveillance of Jeffrey Epstein's residence during the 23 Everything was referred over to the FBI, so it was easy 23. past 12 months? 24 for me to say contact the FBI because we have nothing 24 A. No. My — no. My only involvement with 25 here. 25 private investigators were the ones that were following Page 449 Page 451 1 Q. And do you have any other recollection of the 1 me and pulling my trash. But other than that, that's 2 conversation with Mr. Edwards? 2 it. 3 A. Not that I'm aware of, no. 3 Q. Whoever they were, whatever they did, let's 4 Q. Do you recall what in the incident report 4 put that aside. You've had no direct communication with 5 Mr. Kevin was asking you about? 5 any person who represented themselves to be working with 6 A. No. I know I documented it, but... 6 any of the Plaintiffs' lawyers in this case? Q. So whatever the report that you documented 7 A. No. 8 would be your best memory of your conversation with him? 8 Q. And do you know whether or not Chief Reiter A. Yes. 9, had any communications with any investigator working on 10 Q. Now, after the start of the deposition, did 10 the Epstein investigation? 11 you have any further conversations with Mr. Kuvin or 11 A. Not that I'm aware of. 12 Mr. Edwards regarding Mr. Epstein or regarding these 12 Q. Did he ever tell you that he had any 13 proceedings other than the ones that were on the record 13 communications with Mr. Jenne, or Mr. Fandrey or 14 during the deposition? 14 Mr. Fisten? 15 A. Since the dopers started? 15 A. Not that fin aware of. 16 Q. Yes. 16 Q. And have you ever seen any note, report, 17 A. No. 17 document, memorandum, e-mail or log entry in the Palm 18 Q. And during the deposition, during any of the 18 Beach records that anyone had been observed 19 breaks in the deposition, did either of the two 19 surveillance — surveying Mr. Epstein's residence in the 20 Plaintiffs' lawyers have any conversations with you of 20 past 24 months? 21 21 A. Not that I'm aware of. 22 A. Nothing case-related. It was just... 22 Q. Would investigators, in a normal course of 23 Q. Same questions regarding Mr. Mermelsteln and 23 business, if they were conducting an investigation in a 24 Mr. Horowitz flaw you ever spoken to them? 24 private area of Palm Beath, notify the police that they 25 A. No. 25 intended to be parked in a certain area and watching a 34 (Pages 448 Lo 451) PROSE COURT REPORTING:AGENCY, INC. Electronically signed by Jeana Riceititi (601 Electronically signed by Jeans nicciuti (601 650624374b01-462c-a8364x614•314d7a EFTA00298246 Page 452 Page 454 1 certain residence? 1 regarding investigations. I mean, I usually 2 MS. ARBOUR: Form. 2' forward e-mails to the woman who inputted the 3 THE.WITNESS: Some do, some don't In my 3 supplements into the report. I utilin'd the • 4 years of experience, I've encountered private 4 e-mails for communication with other agencies, s investigators that informed the police department, 5 researching information. 6' and there's investigators that don't. 6 BY MR. WEINBERG: 7 BY MR. WEINBERG: 7 Q. Were there any other agencies involved in the 8 Q. Media. The media: Have you, yourself, ever 8 investigation of Jeffrey Epstein when you began it in 9 talked to a media representative/reporter named Connolly 9 the fall of 2005? 10 who was doing an article for Vanity Fair? 10 MS. ARBOUR: Form. 11 . A. He did telephone me several times and left me 11 THE WITNESS: Not that I'm — no, not that I'm 12 voice mails. I believe I called him once and referred 12 aware of. 13 him to our media person, which was Janet Consuelo. I 13 BY MR. WEINBERG: 14 said, you know, if you have — want anything media 14 Q. And with the exception of Federal agencies, 15 related, dst's the person you need to speak to. I 15 were there any other agencies involved at any time in 16 don't speak to media. But other than that... 16 the investigation of Jeffrey Epstein? Putting aside the 17 Q. Any other media representative attempt to 17 FBI and the Federal authorities. 18 speak to you? 18 A. Not that I'm aware of. 19 A. Local reporters, they sent me e-mails, but 1 19 Q. And did you use your e-mail to communicate 20 just referred those to Janet. 20 with any Federal authority regarding Jeffrey Epstein? 21 Q. Sure. And how would they — did you have 21 A. I don't believe so. 22 e-mail addresses that are ace assible to members of the 22 Q. Do you have the e-mail addresses of the 23 media and the public? 23. various FBI agents who was involved in the Federal 24 A. I mean, they're on my business card, you know, 24 investigation of Mr. Epstein? 25 my e-mail address, so... 25 MS. ARBOUR: Form.. Page 453 Page 455 Q. What e-mail address is that on your business 1 BY MR. WEINBERG: 2 card? 2 Q. For instance, Ms. Kizitendahl is the case 3 A. 3 Cent- 4 Q. And is that an e-mail that you would use to 4 MS. ARBOUR: Same objection. 5 conduct electronic communications with other police 5 TIE WITNESS: I don't believe so. I don't 6 offiects on an investigation? 6 believe so. 7 A. It's the e-mail that I use for work, yeah. 7 BY MR. WEINBERG: 8 Q. When did you start using that e-mail? 8 Q. Do you know Whellwr or not you ever sent a 9 A. When we rust got it. I mean... 9 communication to the FBI from your office in jrecarey 10 Q. How many years ago? Do you recall when you 10 e-mail? 11 first got an e-mail system or a personal e-mail for 11 A. I can't recall, but I don't believe so. 12 yourself? 12 Q. How about the media? 13 A. I don't know. I would venture to say back in 13 A. I don't speak to the media, so... 14 like 2003,2002. 14 Q. How about Chief Reiter? 15 Q. So before the beginning of the investigation 15 A. Within the agency, yeah, I sent e-mails all 16 of Mr. Epstein? 16 the time within the agency to different detectives, 17 A. (Igen-verbal response). 17 secretarial staff, Chief. 18 Q. And before the beginning of Ms. Pagan's 18 Q. Was there a decision that was discussed 19 investigation of Mr. Epstein; is that correct? 19 between you and Chief Reiter as to whether or not to 20 A. I believe so. 20 make available the incident report to the media, the 21 Q. And what is your practice in terms of using 21 Epstein 87-page incident report? 22 e-mail to communicate with other officers or other 22 A. I know I wasn't consulted with that. I mean, 23 detectives engaged in a common investigation? 23 that was decisions made. 24 MS. ARBOUR: Form. 24 Q. Who made that decision? 25 THE WITNESS: Generally, I don't send e-mails 25 MS. ARBOUR: Form. 35 (Pages 452 Lo 4 5 5) PROSE COURT REPORTING AGENCY, INC." Electronically signed by Jeana Medial (601 Electronically signed by Jeans Moduli (601 c50126374brI-4520-4835-bc614•314dre EFTA00298247 Page 456 Page 458 1 BY MR. WEINBERG: 1 interviewed by the Palm Beach Police between March of 2 Q. To the best of your knowledge. 2 2005 and your beginnings of the investigation in late 3 A. You'd have to ask Chief Reiter on that one. 3 September of 2005? 4 Q. Is it ordinary practice of the Palm Beach .4 A. That would have been documented in the report. 5 Police to disseminate incident reports to the media? 5 Q. Do you recall any other woman interviewed 6 MS. ARBOUR Form. 6 during that six-month period? 7 THE WITNESS: Once they're filed, they become 7 A. I can't recall. 8 public record, so you can go into the police agency 8 Q. Do you recall that trash pulls were occurring 9 and ask for any report. 9 during this March and April of 2005 period? 10 BY MR. WEINBERG: 10 A. I did read that, yes. 11 Q. And the media has access to the incident 11 Q. Do you recall that within the trash pulls, 12 reports? 12 there was some references to a belief amongst the 13 A. That's correct. 13 officers that there were sex utensils or sex objects 14 MS. ARBOUR Fortn. 14 that were being identified and pulled out of the trash? 15 BY MR. WEINBERG: 15 A. Yes. 16 Q. And was there anything unusual, from your 16 MS. ARBOUR Form. 17 perspective, regarding how this incident report was 17 THE WITNESS: I recall the incident, the thing 18 handled vis-a-vis the media? 18 you're talking about, which was later turned out to 19 A. I don't believe so. 19 be a handle of a — utensils. 20 Q. But if there was, that would have been a 20 BY MR. WEINBERG: 21 decision made by Chief Reiter and not yourself, correct? 21 Q. Of an eating utensil? 22 MS. ARBOUR: Form. 22 A. Yeah. 23 THE WITNESS: Correct. 23 Q. And do you recall within the incident report 24 BY MR. WEINBERG: 24 there was a reference to this so-called object as one 25 Q. This case, this investigation began in March 25 that was consistent with use of anal sex? Page 457 Page 459 1 of 2005, correct? 1 A. Yes. They thought originally it was an anal • 2 A. Correct. 2 wand. 3 Q. With a phone call from someone connected to 3 (Mr. Garcia entered the room.) 4 ..'s family into the police department? 4 BY MR. WEINBERG: MS. ARBOUR: Form. 5 • Q. And do you recall that, even after your search 6 BY MR. WEINBERG: 6 on October 20. 2005, wherein you saw lots of similar Q. Is that right? 7 utensils in the kitchen that clearly were designed for 8 A. I believe so. 8 eating; that there was no amendment to the Incident 9 And you read n report regarding a debriefing 9 report that reflected the discoveries of October 20 in 10 of M., correct? 10 that the believed sex toys were, in fact, kitchen 11 MS. ARBOUR: Form. 11 Menai? 12 THE WITNESS: I believe so, yes. 12 MS. ARBOUR: Form. 13 BY MR. WEN:BERG: 13 (Ms. Finnigan exits the proceedings.) 14 Q. But you had no ability to reach your own 14 BY MR. WEINBERG: 15 aulibility determinations because you, yourself, never 15 Q. That was a terribly-worded question. 16 reinterviewed Ms. M., correct? 16 A. I was just going to say. 17 MS. ARBOUR: Form. 17 Q. Let me reword it. 18 THE WITNESS: Correct. 18 The incident report contained the beliefs of 19 . BY MR. WEINBERG: 19 the officers, that what they were picking out of the 20 Q. And those interviews were exclusively done by 20 garbage were sexual mechanisms that -- 21 others; is that right? 21 A. Right, they thought they were anal wands. 22 MS. ARBOUR: Form. 22 Q. — they thought were anal wands. 23 THE WITNESS: Correct. 23 A. Right 24 BY MR. WEINBERG: 24 Q. That on October 20th, when you went to 25 O. And Were there any other young women who were 25 Mr. Epstein's residence, you realized as a professional 36 (Pages 456 to 459) (561) .832-750.0 . . PROSE COURT 'REPORTING 'AGENCY, INC. Electronically signed by Jeana Medlin (601 Electronically signed by Jeana Riccluti (601 c6002637413•1452e48384=614•31447a EFTA00298248 Page 460 Page 462 1 law enforcement officer that that conclusion was A. l wanted to familiarize myself completely with 2 mistaken. 2 the case. 3 A. Correct. 3 Q. And the best way to do it, you concluded as a 4 Q. Putt these objects taken out of the garbage 4 professional officer, was to listen to the verbatim tape 5 were, in fact, pans of eating utensils, correct? 5 recordings? 6 A. Correct. 6 MS. ARBOUR: Fort. 7 Q. Was there ever an amendment to the incident 7 THE WITNI3SS: As I would on any other case. 8 report that reflected the knowledge that what had •8 BY MR. WEINBERG: 9 previously believed to have been a sex utensil was, in 9 Q. And you wrote a report, an incident report 10 fact, an eating utensil? 10 that is dated September 26, 2005. Let Inc just show you 11 MS. ARBOUR: Form. 11 this and ask you then to give it back because it's full 12 THE WITNESS: It might have been referenced in 12 of notes, but I want to ask you a couple of questions 13 the report I'm net 100 percent certain on that. 13 from there. Do you recognize this kind of document? 14 BY MR. WEINBERG: 14 A. Yes. That was a supplement that I had 15 Q. If it wasn't in the 'two t, then there wasn't 15 submitted to the secretary to be inputted into the 16 an amendment to the report, fair to say? 16 report. 17. MS. ARBOUR: Form. 17 Q. And in that supplement, you had referenced in 18 THE WITNESS: Fair to say. 18 this middle paragraph, "On September 22, I was informed 19 BY MR. WEINBERG: 19 by Sergeant Szarszewski — 20 Q. I want to go back to September, when you first 20 A. Szarszcwski, yes. 21 got involved. You asked Ms. Pagan and others to send 21 Q. — that there would be no trash pickup as it 22 you any tape recordings that had been conducted during 22 was recycled pickup day." And then you sent a request 23 the beginning days of the investigation; is that 23 for copies of the micro and standard-sized cassettes, 24 correct? 24 were requested from Crime Scene to familiarize myself 25 A. Correct 25. with the interviews conducted. Page 461 Page 463 1 Q. And you wanted to hear the tape recordings, 1 And the crime scene, the crime scene in this 2 did you not? 2 investigation was Mr. Epstein's residence, correct? 3 A. Yes.' 3 A. No, from the Crime Scene Unit 4 Q. And even one of the tapes was kind of — it 4 Q. From the Crime Scene Unit? 5 was broken during the copying for you, correct? S A. Yes, who holds all evidence from the Palm 6 A. Correct Beach Police Department. 7 Q. And you wanted to hear the tapes because you 7 Q. So the word "Crime Scene" refers to a unit 8 knew that listening to the tapes would give you the best 8 within the Palm Beach Police Department? 9 source of knowledge as to whth witnesses were telling A. The Crime Scene Unit, yes. 10 police officers in your absence, correct? 10 Q. And they're the evidence custodians? 11 MS. ARBOUR: Form. 11 A. Yes. 12 ' THE WITNESS: I wanted to get the perspective 12 Q. And they have logs of evidence going in and 13 of the victim, yes. 13 out? 14 BY MR. WEINBERG: 14 A. Correct. 15 Q. And the perspective of the victim is more 15 Q. Just like you kept logs when different items 16 accurately disclosed through a contemporaneous tape 16 . seized on October 20th were reviewed by you, correct? 17 recording than through note taking, correct? 17. A. What logs are you referring to? 18 MS. ARBOUR: Form. '18 Q. You kept different property logs. 19 THE WITNESS: I believe so. 19 A. Oh, the property receipts? Yes. That's done 20 BY MR. WEINBERG: . 20 with every piece of evidence Nat gets submitted into 21 Q. And therefore, the source that you wanted to 21 Crime Scene. 22 got was the tape recordings, correct? 22 Q. So therefore, the Crime Scene has a log that 23 A. Correct. would contain an identification of each item of evidence 24 Q. Rather than just relying on the narrative that 24 that was maintained by the Palm Beach Police as of 25 was incorporated into an incident report, correct? 25. September 22,2005, correct? ' 37 (Pages 460 to 463) 0 PROSE COURT REPORTING AGENCY INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricciuti (601:11/11 c6062637-0•1-462e48364x614•314d7a EFTA00298249 Page 464 Page 466 1 A. They have property receipts, yes, copies of 1 Q. Now, also told you that immediately after 2 the property receipts. . 2 • leaving Mr. Epstein's house with the $200 or $300 she 3 Q. So they would have the receipts for the videos 3 received that day, she and.. went shopping, correct? that reflected surveillance before September 22nd, 4 A. She told Detective Pagan. 5 correct? 5. Q. Right. And she was inolthe only different 6 A- Correct. 6 women told you that they went shopping with the money Q. They would have property receipts for the 7 they got from Mr. Epstein following their massages, 8 results of the bash pulls before September 22nd. 8 correct? 9 • A. Correct. 9 MR. GARCIA: Object to the form. 10 Q. And the had the tape recording of their 10 THE WITNESS: I can't recall if they told me 11 debriefing ofM., correct? 11 they weat specifically shopping, but.: 12 . A. Correct. 12 BY MR. WEINBERG: • 13 Q. Wherein M. said that she went to 13 Q. Did you ever ask them what they did with the 14 Mr. Epstein's house on one occasion, correct? 14 $200 they received? 15 A. I believe so, yes. 15 A. I might have. I can't recall at this time if 16 Q. With M., correct? 16 I did or didn't. 17 A. Yes. 17 Q. Did you ever ask lane Doe 103 — strike that. 18 Q. Knew what she was going there for? 18 • • Jane Doe I.03 told you that she had received a 19. MS. ARBOUR: Form. 19 significant amount of money because she said she bad 20 THE WITNESS: So she claims, yes. 20 • gone to Mr. Epstein's home on many occasions, correct? 21 BY MR. WEINBERG: 21. MS. ARBOUR: Form. 22 Q. Represented herself to be 18 to Mr. Epstein? 22 • THE WITNESS: Yes. 23 MS. ARBOUR: Form. n BY MR. WEINBERG: • 24 THE WITNESS: That, I don't recall. • 24 Q. And that it totaled thousands, rather than 25 25 hundreds, correct? Page 465 Page 467 BY MR. WEINBERG: 1 A. I would believe so. . 2 Q. If it's in the incident report, you wouldn't 2 Q. And did you ever ask her what she did with her 3 believe that's inconsistent with your memory, correct? 3 money? 4 MS. ARBOUR: Form. 4 A. I can't recall if I did or didn't. 5 BY MR. WEINBERG: 5 Q. Do you recall ha declining or reflising to 6 Q. In other words, if it's in your incident 6 tell you what happened to the money that she made with 7. report, you have no reason to doubt that she said that? 7 Mr. Epstein? 8 A. Correct. 8 • A. I can't recall. 9 • Q. If it was said, it was said to someone else, 9 Q. When you drafted the search warrant 10 correct? 10 affidavit — 11 MS. ARBOUR: Font 11 A. Yes, sir. 12 . THE WITNESS: Correct. 12 Q. — this was less than a month into the 13 BY MR. WEINBERG: 13 investigation that was being led by you, correct? 14 Q. Your recollection is that, as you testified to 14 MS. ARBOUR: Form. 15 last time, that took her upstairs, correct? 15 THE WITNESS. Uh-huh. 16 . A. Who, ? 16- . BY MR. WEINBERG: 17. It Q. You took it over in the third week of 18 A. She is the ono who was interviewed by 18 September of 2005? 19 Detective Paw, but... 19 A. Towards the end of September, yes. 20 Q. . Right. But she described it that some other 20 Q. There had — and you one of the first things 21: woman took hefupstairs, correct? 21 you did was to interview correct? 22 A. Some other woman, yes. 22 A. That was in October. 23 Q. But she didn't give the name or or 23 . Q. The first week in October, correct? 24 any third party, correct? 24 A. Yes. 25 A. I believe so. 25 Q. And you went to Ms...'s house, did you not? 38 (Pages 464 to 467) PROSE COURT REPORTING. AGENCY, INC.• Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeans Ricciuti (601 06042837-ebet-452c-a834-bc814•314d7a EFTA00298250 Page 468 Page 470 1 A. Yes, I did. 1 telephones that you use to call out, correct? 2 • Q. Ms... lived out of Palm Beach, did she not? 2 A. Yes. 3 A. Yes. 3 Q. And are tape recorders which would permit you 4 Q. And the decision was made that you could 4 to tape record an outgoing phone call, correct? 5 interview her without the presence of an officer from a 5 A. Yes. 6 different department if she elected to come back to the 6 Q. And Ms... certainly told ou that she had 7 headquarters, correct? 7 spoken on occasion on the phone to 8 A. Correct. 8 A. Yea 9 Q. And you asked her to come back to the 9 Q. And that she had spoken to for the 10 headquarters, correct? 10 purpose of scheduling certain visits to Mr. Epstein's 11 A. Yes, I did. 11 home, correct? 12 Q. And she agreed to corns back to the 12 A. Yes. 13 headquarters, did she not? 13 Q. And that she had Ms. phone number? 14 A. Yes, she did 14 A. Uh-huh. 15 Q. And at that point in time, when she was at her 15 Q. And that she could have called Ms. 16 house and you were asking her to be cooperative, she 16 while she was at the Police headquarters, correct? 17 agreed to be cooperative; is that right? 17 A. Yes. 18 A. Well, she agreed to come back to the Police 18- Q. And did you decide whether or not you would 19' Department for further questioning. .19 ask her to make such a call? 20 Q. And she agreed essentially to cooperate with 20 A. It was within her statement where she claimed 21 your investigation of the interview, right? 21 she wanted nothing to do with or Mr. Epstein, that 22 MS. ARBOUR: Form. 22 she had stopped communicating with so it would 23 THE S: Correct. I mean, she answered 23 have been out of the norm for her to call. 24 the questions, if that's what you mean. 24 Q. You have asked cooperating witnesses to place 25 BY MR. WEINBERG: 25 tape recorded telephone calls to targets of your Page 469 Page 471 1 Q. And she answered them by identifying to you at 1 investigation on other occasions, have you not? 2 least six other people that she had brought and 2 A. Yes. 3 introduced to Mr. Epstein, correct? 3 Q. And that was certainly an investigative 4 A. Correct. 4 technique that you considered employing in this case? 5 Q. And she agreed to talk to you abort.; is 5 A. Considered it. 6 that right? 6 Q. And then you made a decision as the case agent 7 A. I believe so, yes. 7 not to request that Ms... lace a recorded phone call 8 Q. And she answered any questions you asked her; 8 to either Mr. Epstein or Ms. =, correct? 9 is that right? '9 A. Correct. • 10 A. Yes. • 10 Q. And not to ref= to Mr. Epstein's house 11 Q. Mr. Epstein was in town at the time; is that 11 . wearing a recorder wherein the events that transpired 12 right? 12 • there and the conversations that occulted there could be 13 MS. ARBOUR: Form. 13 recorded and transmitted to some — to law enforcement, 14 BY MR. WEINBERG: 14 correct? 15 Q. 'Do you recall that your incident report 15 A. Correct. 16 reflects that his — 16 Q. Back to the search warrant affidavit. You've 17 A. Yes, that his plane was in town, yes. 17 authored other search warrant affidavits, have you not? 18 Q. And that Ms is at the Police Department 18 A. Uh-huh. 19 with you; is that right? 19 Q. And your goal when you authored them is to be 20 A. Ub-huh. 20 complete and accurate, is it not? 21 Q. She is being interviewed behind a one-way 21 A. Yes. 22 glass so that the content of the interview was being 22 Q. You understand that the magistrate — strike .23 observed by others? 23 that — that the judge that's going to review the . 24 A. Yes. 24 al£davit ordinarily has no other independent bases to 25 Q. And within the Police Department are 25 know whether or not to authorize a search of a residence 39 (Pages 468 to 471 ) . PROSE COURT REPORTING AGENCY,. INC. Electronically signed by Jeana RIcciutl (601 Electronically signed by Jeana RIcciuti (601 c5062637-abel-452c-a836-bc614.314d7a EFTA00298251 Page 472 Page 474 1 .crept the information that's being provided to him by 1 BY MR. WEINBERG: 2 the affiant, correct? 2 Q. When you searched the Dell computer taken from 3 MS. ARBOUR: Form. 3 the second residence, did you conduct the search or did 4 'THE WITNESS: Correct. 4 a forensic expert conduct it? 5 BY MR. WEINBERG: 5 A. It was sent to the Sheriffs office for 6 Q. And these affidavits are under oath, correct? 6 imaging, and then the imaging itself was looked at. 7 A. Yes. 7 Q. Not one of your witnesses ever said that they 8 Q. And they're designed to be accurate and 8 saw Mr. Epstein use a computer; is that correct? 9 complete, are they not? 9 A. I'm trying to recall. Not that I can recall. 10 A. Yes. 10 Q. Not one of your witnesses said they ever 11 Q. Because you understand that omissions can be 11 received an e-mail from Mr. Epstein, correct? 12. as deceiving as misrepresentations, correct? 12 A. I can't recall at fills time. 13 A. Correct. 13 Q. Not one of your witnesses ever said that when 14 Q. In this case, you were seeking authority to 14 they were at Mr. Epstein's house, they had ever looked 15 conduct a search of Mr. Epstein's private residence, 15 at anything on a computer at Mr. Epstein's house or ever 16 coil 16 seen anything on a computer at Mr. Epstein's house? 17 A. Correct. 17 A. I ain't recall. 18 Q. And you sought that permission based on an 18 Q. Not one of your witnesses ever said that they 19 affidavit that reported to the judge the results of 19 had received an e-mail from anyone other than 20 certain interviews you conducted? 20 Mr:Epstein who resided at Mr. Epstein's house, coned? 21 A. Uh-huh. 21 A. I can't recall if.. claimed that she got an 22 Q. And certain blowup investigations, such as 22. e-mail. That's why I'm not 100 percent certain on the 23 the results of trash pulls and phone records; is that 23 email. 24 right? 24 Q. If it's not in the incident report, you have 25 A. Correa 25 no independent memory of anyone telling you that they Page 473 Page 475 1 Q. Within the affidavit, you asked for permission 1 ever received an e-mail from or or 2 to search any DVDs, any CDs, any computer discs, any 2 anyone else that resided at Mr. Epstein's home, caret 3 media that you could find in Mr. Epstein's residence; is 3 A. Fin trying to recall. I can't recall. 4 that correct? 4 Q. You do recall that the scheduling was done as 5 A. Correct. 5 a routine practice by phone, correct? 6 Q. And in het, you did seize such CDs, DVDs and 6 A. Yes. 7 various media discs, did you not? 7 Q. And that largely, the conversations, to the A. We seized some. 8 extent they were explained to you, were simply phone 9 Q. And you searched them -- 9 calls to and from picking a time, picking a date 10 A. Yes. 10 . when they would go to Mr. Epstein's home, correct? 11 Q. — not knowing what was on them? 11 . MS. ARBOUR: Form 12 A. Correct. 12 THE WITNESS' I believe so. 13 Q. And likewise, you seized a Dell computer from 13 BY MR. WEINBERG: 14 a guest house that was a separate and detached residence 14 . Q. And you saw message pads that confirmed El 15 on the Epstein property, is that correct? 15 the message was generally limited to, Pm availalco. 16 A. Correct 16 call me, Icon come, messages that were reflective of 17 Q. And you ultimately gave back anything seized 17 scheduling and an openness to going to Mr. Epstein's 18 from that separate residence, understanding that it, in 18 home, correct? 19 essence, was the home of another individual, correct? 19 MS. ARBOUR: Form. 20 A. Because it was returned back to the innocent 20 BY MR. WEINBERG: 21 party who had no evidence on his computer us to the 21 Q. We can go through a lot of the messages this 22 items that we were searching, yes. 22 . afternoon, but... 23 Q. And when you searched these computers, you 23 A. I believe so. 24 were looking for anything; is that correct? 24 Q. The investigation you conducted, that included 25 MS. ARBOUR: Form. 25 the search on October 20th, continued into November and 40 (Pages 472 to 475) • PROSE COURT REPORTING .AGENCY,' INC. Electronically aligned by Joana Fticclutt (601 Electronically signed by Joana Rlcciuti (601 c5062637-abol-462c-a836-bc614e314d7a EFTA00298252 Page 476 Page 478 1 December of 2005, correct? 1 it a fivocount charge against Mr. Epstein, two counts 2 ' A. Uh-huh. 2 with five allegations, if you recall? 3 Q. So it began in Much and it continued through 3 A. I can't recall. 4 December of 2005, correct? 4 • Q. There was ono count for lewd and lascivious, 5 A. Yes. 5 and one count for unlawful sex act that was returned by 6 Q. The first time you formalized a probable cause 6 a Palm Beach grand jury in and around June of 2006. 7 affidavit was May 1, 2006, correct? 7 MS. ARBOUR: Form. 8 A. Uh-huh. 8 BY MR. WEINBERG: 9 Q. And that probable cause affidavit resulted 9 Q. Let me go back. There was a grand jury 10 several months later when the State Attorney was 10 indictment, correct? 11 presenting a case to the grand jury? 11 A. Yes. 12 A. That was — that whole fiasco with the State 12 Q. Thereafter, there was information? 13 Attorney's office where originally we were going to go 13 A. Yes. 14 to the grand jury, then we postponed it, and then we 14 Q. The grand jury indictment charged 15 were going to go back to the grand jury, then we 15 solicitation, correct? 16 postponed it, and then they said no, we want a probable 16 A. I believe so. 17 cause affidavit. So I submitted it as a probable cause 17 Q. And that came about on either the end of Juno 18 affidavit, and they came back and said no, we want to go 18 or July of 2006, correct? And we can go back — 19 back to the grand jury — 19 A. I believe you're right I'm not 100 percent 20 Q. To cut through it, there was some, to put it 20 certain, but I believe you're right. 21 mildly, niscommunication between the State Attorneys 21 Q. And before the grand jury acted, did you and 22 office and the Palm Beach Police Department? 22 Chief Reiter discuss going to the Federal authorities 23 MR. GARCIA: Object to the form. 23 and bypassing the State Attorney? 24 MS. ARBOUR: Form. 24 A. I can't recall. I believe it might have been 25 MR. GARCIA: Mischaracterizes his testimony. 25 after, but I'm not 100 percent certain. Page 477 Page 479 1 BY MR. WEINBERG: 1 Q. Do you have any records, notes, reports that 2 Q. Let me go back and start again. In April, 2 would refresh your memory as to the first time that 3 they told you they were going to conduct a grand jury 3 either you or Chief— or to your knowledge, 4. and subpoenas went out to certain people, okay? 4 Chief Reiter communicated with the Federal authorities 5 A. It was prior to April, I believe. I think we 5 and asked them to commence or initiate an investigation 6 were in March. 6 of Mr. Epstein? 7 Q. So in March, the grand jury subpoenas were 7. MS. ARBOUR: Form. 8 served for an April appearance. Does that chronology 8 THE WITNESS: No, Ideal have any records. 9 make sense? 9 BY MR. WEINBERG: 10 A. I think that's when the discussions were back 143• Q. And do you know whether or not — was it you 11 and forth about grand jury. 11 that made that initiation to the Federal government? 12 Q. And Ms. Jane Doe 103 was served with a gland 12 A. I believe so. 13 jury subpoena? 13 ' Q. And do you recall just how you did that? Did 14 A. I drove up and I served her with a grand jury 14 you drive over to the Federal — to the US Attorneys 15 subpoena. 15 office? Did you call the FBI? How was the initiation? 16 Q. And that grand jury was postponed or canceled; 16 A. I am also assigned to the Joint Terrorism Task 17 correct? 17 Force, so I have daily communication with people at the 18 A. Yes. 18 FBI, if not every other day. Iliad the clearance, you 19 Q. And a second grand jury was thereafter 39 to in and out of the office. But Fm trying to 20 convened during the summer of 2006, correct, months 20 recall. I believe it might have been me. 21 after the first one? 21 Q. And what's your best recollection as to how 22 A. Yes. 22 this occurred as to, did you go to the FBI, were you 23. Q. And taking that timeline, between the grand 23 talking to them in any way at a Joint Task Force 24 jury for which you subpoenaed Ms. Jane Doe 103 the first 24 meeting? Did you make it a point to bring this matter 25 time and the grand jury that ultimately returned — was 25 to their attention? What's your best recollection of 41 (Pages 476 to 479) PROSE COURT REPORTING AGENCY, INC. .(561) 832-7506 Bactronicaily signed by Jeans Rlcdutl 1601= Electronically signed by Jeans flicciuti (601 61012637-atirl-461:483843414414dra EFTA00298253 Page 480 Page 482 1 how the dialogue commenced? 1 A. -- that they wanted everything pertaining to 2 A. I don't recall. I can't recall. 2 the case, and everything that was pertaining to the case 3 Q. But you do recall at least one conversation 3 went with them. 4 with the Federal authorities regarding Mr. Epstein? 4 Q. Do you have any logs, diaries, calendars, 5 A. Yes. 5 notes that would provide you with the basis to know the 6 Q. Do you recall more than one conversation with 6 date of this meeting? 7 them? 7 A. Of the Federal subpoena, or — A. I recall a meeting with Junior Ortiz, who was 8 Q. No, of the meeting between you and Chief — 9 the supervisor, the local supervisor. He was present, 9 A. No, there were no logs. 10 Chief Reiter was present, 'was present. That would 10 Q. — Reiter that met with the special agents. 11 have been in the summer. 11 Was there any follovrup that you engaged in? 12 Q. Do you recall where that meeting occurred? • 12 A. Not that I can recall. !mean, once they came 13 A. It was at the FBI office because it was in 13 in and took over the stag that was it. 14 Junior's office. 14 Q. How long did this meeting occur? 15 Q. Was this before or after the Federal subpoena 15 A. About an hour or so. I wouldn't — I believe. 16 went out to the Palm Beach P1) for the production of 16 Q. And do you recall questions that were asked of 17 their records regarding the State investigation? 17 you during this hour? 18 A. This would have been before. 18 A. No. 19 Q. And this is the first meeting you recall 19 Q. And do you recall information that you 20 wherein Mr. Epstein was discussed with the Federal 20 cornmtmicated during this hour? 21 authorities in your presence? 21 A. No. 22 A. Yes, I believe so. 22 Q. And do you recall any questions asked of 23 Q. And do you recall whether it was you or 23 Chief Reiter during this hour? 24 Chief Reiter that invited —that initiated this 24 A. No. 25 meeting? 25 Q. Do you recall anything said by Chief Reiter to Page 481 Page 483 1 A. I can't recall. I'm trying to think back. 1 the FBI? 2 Q. So, who else was at this meeting? 2 A. No, I'm sorry. 3 A. I know Junior was there, I believe the Chief 3 Q. Who first raised the issue of nexus, of 4 was there, I was there. 4 whether there was any Federal nexus to what had been, up 5 Q. And do you recall whether or not you took any 5 to this day, a purely local investigation of activities 6 notes that were memorialized in any report regarding the 6 being conducted of Mr. Epstein's private residence? 7 content of this meeting? 7 MS. ARBOUR: Form. 8 A. No. 8 THE WITNESS: I can't recall whether it was me 9 Q. And was the purpose of you and Chief Reiter 9 or former Chief Reiter. 10 going to the FBI and having this meeting to request that 10 BY MR. WEINBERG: 11. they take over the criminal investigation of 11 Q. And those conversations occurred before this 12 Mr. Epstein? 12 meeting? 13 MS. ARBOUR: Form. 13 A. Either at the meeting or just before the 14 THE WITNESS: It wasn't to take over. I 14 meeting. 15 believe it was to determine if there was any 15 Q. And did this meeting occur at or around the 16 Federal nexus or any Federal violation, but it 16 time that Chief Reiter was writing letters expressing 17 wasn't to take over, although subsequently that's 17 his displeasure with the State and State Attorney's 18 what happened, but... 18 investigation? 19 BY MR. WEINBERG: 19 MS. ARBOUR: Object to f01111. 20 Q. And did you and Chief Reiter provide the 20 ME WITNESS: I believe it was after the 21 Federal authorities with whatever information was 21 letters. 22 available to you? 22 BY MR. WEINBERG: 23 A. We didn't have a choice. They came in with a 23 Q. Do you remember those letters? 24 Federal subpoena -- 24 A. Yea 25 Q. Following this meeting? 25 Q. And those letters were written or drafted and 42 (Pages 480 to 483 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RitrJult (801 Electronically signed by Jeana Ricciuti (601 cS062637-abol-452c-ati36-bc614e314d7a EFTA00298254 Page 484 Page 486 1 1 written by ChiefReiter and sent to whom? 1 MS. ARBOUR: Form. 2 . A. They were sent to some of the parents of the 2 • THE WITNESS: I wouldn't consider what she did 3.. victims. 3 her investigation. I think she just looked at .4 Q. If I represent to you that at least some of 4 these girls' MySpace accounts. I wouldn't consider - 5 , - - those letters were dated in May of 2006, would that jog s that an investigation. 6 your memory as to when this meeting.with Special Agent 6 BY MR. WEINBERG: 7 Ortiz occurred? 7 Q. But she had in her possession at this time 8 A. I believe it would have been after those 8 your incident report? 9 letters. 9 MS. ARBOUR: Fenn. 10 Q. But before the return of the State grand jury 10 THE WITNESS: Yes. 11 indictment? 11 BY MR. WEINBERG: 12 A. I don't believe it was before the grand jury. 12 • Q. Your probable cause affidavit? 13 I believe it was after the sand jury. 13 • MS. ARBOUR: Form. 14 Q. So your best memory, therefore, would be that 14 THE WITNESS: I don't know if it was drafted 15 it would be after both the letters and the grand jury? 15 yet. 16 A. Comet. 16 BY MR. WEINBERG: 17 Q. You had different conversations with the State 17 Q. But she had the raw materials of your many 18 Attorney during this period, with one or more of the 18 interviews over many months, correct? 19 State attorneys? 19 MS. ARBOUR: Fenn. 20 A. Yeah, Assistant State attorneys. 20 THE WITNESS: Yes. 21 Q. Which Assistant State attorney do you recall 21 BY MR. WEINBERG: 22 talking to? 22 Q. She had the results of the search, did she 23 A. 23 not? 24 Q.64 recall any conversation with 24 A. Yes. 25 Ms. wherein you discussed whether or not your 25 Q. She had the message pads available to her, did Page 485 Page 487 1 witnesses were or were not victims? 1 she not? 2 MS. ARBOUR: Form. 2 MS. ARBOUR: Form. 3 THE WITNESS. I recall her picking and 3 THE WITNESS: I don't believe she had the 4 choosing who she wanted to refer to as a victim. 4 message pads. They were in our evidence. 5 Most ofmy conversations with her I know were 5 BY MR. WEINBERG: 6 documented in the report. 6 Q. But she could if - 7 BY MR. WEINBERG: 7 A. She had, I think, certain copies of certain 8 Q. 13o you recall words to the effect that you 8 pages of than. • 9 were frustrated with her because one ofha opinions 9 Q. She had a file as an Assistant State Attorney 10 were that there was no victims in this case? 10 in charge of a criminal' investigation ofMr. Epstein 11- MS. ARBOUR: Fonn. 11 that was being conducted by your department, correct? 12 THE WITNESS: I did recall that conversation, 12 MS. ARBOUR: Form. 13 ' Yes- ' 13 THE YoTINESS: I believe she did have a file, 14 BY MR. WEINBERG: 14 yes, of items that were given to ha by us. 15 Q. And what do you recall of that conversation? 15 BY MR. WEINEIF.RO: 16 A. I recall her, after viewing some of the 16 Q. She didn't only have that which was provided 17 materials that were supplied to her by Dershowitz, she '17 by the Defense, 18 started to claim that the victims were not victims based 18 MS. ARBOUR; No. 19 on the materials that were supplied by the MySpaces. 19 THE WITNESS: No. She had items that we had 20 Q. The victims were not victims? 20 provided. 21 A. That's what she was claiming. 21 BY MR. WEINBERG: 22 Q. And this is the State Attorney's statements to 22 Q. And putting aside what you believe was the 23 you based on her investigation which included her review 23 more important evidence to her, which was her review of 24 of materials provided to her by Defense Counsel 24 the MySpace pages of certain of your witnesses, she did .25 Professor Alan Dersb3witr2 25 . communicate to you, the case agent, ha belief that 43 (Pages 484 to 487) ' . PROSE COURT REPORTING AGENCY; INC. Electronically signed by Juana Ricciuti (601 Electronically signed by Jeana Ricciuti (601 c5062637-abel-462c-a836-bc614e314d7a EFTA00298255 Page 488 Page 49C 1 there was no victims i n this case? Q. And she was the proseCutor in charge of the A. Based on what she was observing on those case? • 3. pages. At least that's my opinion: MS. ARBOUR: Form. 4 Q. But what her statement to you was: There are THE WITNESS: She was one of the prosecutors 5 no victims in this case? that was assisting in this case. MS. ARBOUR: Forni -BY MR. WEINBERG: 7 THE WITNESS: I believe so. Q. AM when did she make the statement to you, 8 BY MR. WEINBERG: . ff . "There are no victims here"? 9 Q. And that was made after she reviewed the 9 A. This is when we were debating we go to the 10 MySpace pages, comet? 10 . grand jury, not to go to the grand jury, write me a PC, 11 MS. ARBOUR: Form .. • 11 don't write me a PC, we're going back to the grand jury. 12 114E WITNESS: I believe so. 12 • Q. Late spring of2006? 13 BY MR. WEINBERG: 13. A. Like I said, this was ongoing from in the 14 O. But also after she had in her possession a 14 • investigative stage. This was prior to the arrest 15 very substantial investigative incident report that . 15 . . Q. And she was talking to you about going to the 16 reflected many interviews with many witnesses conducted 16 grand jury, correct? 17 both by you and others working with you and by others 17 •• A. Whether we were going to go to the grand jury, 18 before you, correct? 18. then we weren't going to go to the grand jury. 19 MS. ARBOUR: Form. 19 Q. But the first grand jury, which was scheduled 20 ME WITNESS: In my opinion, once 20. . in March or April, different witnesses were subpoenaed 21 Mr. Dershowitz became involved, her demeanor on 21 to that grand jury, correct? 22 this case was completely different. 22 A. Correct. 23 BY MR. WEINBERG: 23 Q. Amongst them was Ms. Jane Doe 103, correct? 24 Q. And let me go back to square one so we can 24 A. Yes. 25 finish this area and then have lunch. 25 . Q. Amongst them was Ms. M., correct? Page 489 Page 491 1 A. Okay. 1 A. Yes. 2 Q. Okay? Before Mr. Dershowitz got involved, she 2. Q. Was amongst them Ms.M.? 3 had an incident report, did she not? 3 A. Yes. 4 A. IJh-hub. .4. • Q. Who else? 5 Q. She had a probable cause — a search 5 A. I believe this was it. I think that was the 6 warrant - 6 initial — they were going to do it in sections, and 7 A. I take that back. Prior to Mr. Dershowitz 7 they were going to pick those girls to go first. 8 being involved, I don't believe she had the incident Q. And the criminal offense that she was 9 report as of yet. It was still in the investigative investigating at the time was felony solicitation? 10 stage. The search had been conducted, interviews bad 10 MS. ARBOUR: Form. 11 been conducted, I had been providing her with copies of 11 • THE WITNESS: I don't know what she was 12 the interviews, but I don't believe that she had a copy 12 . looking into. I know what f was seeking. 13 of the incident report as of yet: 13 BY MR. WEINBERG: • 14 Q. Right. And she had copies of certain portions: 14 Q. You and her had disagreements about witnesses 15 of what ultimately was incorporated into the incident ' 15 and charges, correct? 16 report, correct? 16.. A. Yes. 17 MS. ARBOUR: Form. . 17 Q. -And you had disagreements about whether or not 18 THE WITNESS. I don't believe so. 18. . the witnesses that you denominated victims and she said 19 BY MR. WEINBERG:. 19 weren't victims, you had disagreements over their 20 Q. She had — did she not have copies ofmulls 20 credibility, did you not? 21 of- 21.. A. Not over their credibility. It Was over, 22- A. When the case is under investigation, were 22.: like, the MySpace pages I bad the feeling that she was 23 not going to release the incident report. She may have 23 1134118 to — 24 had the face sheet and the — involving Mr. Epstein's 24 • Q. I don't mean to interrupt, but I want to stick 25 name on it,.but that's basically it. .25 . . to conversations and evidence and not feelings, so 44 (Pages 488 to 491) PROSE COURT 'REPORTING AGENCY, ':.:.•: :":(561)' -832-7506 Electronically signed by Jeana RIccluti (601M( Electronically signed by Jeana Rlccluti (601 c15062637-abe14620-68364x:614•314d7a EFTA00298256 Page 492 Page 494 1 MR. GARCIA: Cm ahead and finish your answer, 1 BY MR. WEINBERG: 2 sir. Don't let him interrupt you. You can finish 2 Q. And the State Attorney was weighing the 3 your answer. 3 -.MySpace information with the information that they were 4 THE WITNESS: I had the feeling that she was 4 ,. receiving from the Palm Beach Police Department; is that 5 trying to brush this case under the carpet. That 5 correct? 6 was my — 6 MS. ARBOUR: Form. 7 BY MR. WEINBERG: 7. . THE WITNESS: Well, the information and the 8 Q. You believed that she was minimizing the CIL% 8 meetings that Mr. Dershowitz had with Barry correct? . 9 Krisher. 10 A. (Non-vabal response). 10 BY MR. WEINBERG: 11 Q. And you believed that one of the reasons she 11 - Q. And you were not present at some of these 12 was minimizing the case was her review of the MySpace 12 meetings? 13 pages of some of your witnesses, correct? 13 - A. Correct. 14 A. I know that the attitude of the State 14 Q. So you don't know the full scope of the 15 Attorney's office was very pro-assisting us from the 15'• presentation being made by attorneys, including 16 very beginning. Once Mr. Dersbowitz became involved in 16 Professor Dershowitt, on Mr. Epstein's behalf, correct? 17 the investigative stage, everything changed. 17 A. I just found it odd that during the 18 Q. So let's talk about these MySpace pages for a 18 investigative stage, we were already discussing 19 minute. MySpace pages are an Internet site where the 19 strategies on whether to prosecute or not to prosecute, 20 witnesses herself would put information out there that 20 and this was still in the investigative stage of it. 21. was available to whoever accessed the site, correct? 21 • Q. Putting aside your feeltngs, you were not 22 MS. ARBOUR: Form. 22 present at these presentations? 23 TIIE WITNESS: MySpacc is a social network that 23 A. Some I were. 24 you can basically create anything that you want to 24 Q. Some you were. You don't know the full scope 25 create on a MySpace page. 25 of the arguments and the evidence that was being Page 493 Page 495 1 BY MR. WEINBERG: 1 provided to the State Attorney by the Defense lawyers, 2 Q. And you understood that certain of your 2 correct? 3 witnesses created their own MySpace page, correct? 3 MS. ARBOUR: Form. 4 A. It's possible. 4 THE WITNESS: The ones that I chose to go to, 5 Q. And did you ever, in order to determine any of 5 'just — I was privy to some of the information 6 the background of your witnesses, go on their MySpace 6 but not all. 7 Pages? .7 BY MR. WEINBERG: 8 A. I did view some of their MySpace pages, and I 8, Q. And the fact is that 9 did view sane of the items that Mr. Dersbowitz provided 9- A. .Yesh.: . 10 to Mr. Krisher, but we're talking about teenagers who 10 . Q. — came to separate conclusions from case 11 put -- this is information that's put on a site that's 11 .• chiefDetective Joe Recarey, regarding the gravity of 12 not checked for any validity. I can create a site using 12 Mr. Epstein's conduct, correct? 13 your information. 13' • . MS. ARBOUR: Form. • 14 . Q. Did you ever ask Ms. lane Doe 103 in any 14 . -THE WITNESS: Pm sorry? 15 followup interview, is there anything on your site that 15 BY MR. WEINBERG: 16 doesn't depict you? 16 • Q. You and the State Attorney's office came to 17 A. Actually, I never spoke to any of the victims • 17• • different conclusions in this case, correct? 18 about — . 18 MS. ARBOUR: Porni. 19 Q. Did you ever do an independent investigation IR: . THE WITNESS: We had our disagreements, yes. 20 to determine whether any of the information provided by 20: . • BY MR WEINBERG: 21 Professor Dershowilz to the State Attorney was 21 Q. And those disagrectrients led to you and 22 fabricated or falsified or externally placed there by ' • . 22 . ChiefReiter inviting the FBI agent intothis 23 some third party? 23 - investigation, correct? 24 MS. ARBOUR: Pam. 2.4 • . • •MS. ARBOUR: Pam. • 25 THE WITNESS. No 25.. • THE WITNESS: Not the disagreements. The faet 45 (Pages 492 to 495) PROSE COURT REPORTING -AGENCY, INC.. '4561) $32-7506 . Electronically signed by Jeana Rlectutl (601 Electronically signed by Joana Rlcciull (601 c5062637-abo1452c-a836-bc8146.314d7a EFTA00298257 Page 496 Page 4981 1. that the case wasn't— it wasn't-- in my eyes, it 1 CERTIFICAT3 2 SIATROP FLORIDA 2 wasn't any justice served. 3 COUN1Y OF PALMREACH 3 BY MR. WEINBERG: ' 4 $ LkamRieciuri. Registered Professional 4 Q. Your disagreanents with the State Attorneys Reporter and Notary Public in and for the State of 5 charge decision led you to go outside the State law 6 Florida a Lana, do hereby certify that the 6 enforcement community and transmit information about aforemanional witness was by me lint duly mom to 7 testify the whole truth; that I was unbolt() to and 7 Mr. Epstein to Federal authorities? did moon said deposition in stenotype; and that the 0 MS. ARBOUR: Form, asked and answered. 8 foregoing pages numbered 319 to 495 are a true and cartel transcription of my shorthand into of said 9 THE WITNESS: And also to see if there was any a deposition. 10 Federal nexus pertaining to the case. 10 I further certify that aid deposition vein taken at the time and place hereinabove set forth and 11 BY MR. WEINBERG: it that the taking of sad deposition was commenced and 12 Q. But you sought to determine if there was a completed as haeinabove set out. 13 Federal nexus relating to this case as a result of your 12 1 further certify that I am not an attorney or 14 disagreements with the charge decisions that were being 13 counsel crony of the parties, nee am I a relative a 15 made by.your State Attorney, correct? employee of any attorney a counsel of party connected 14 with the action, nor an I &mei* interested in the 16 MS. ARBOUR: Form. action. 17 • THE WITNESS: I believe so. 15 The icaton of this transcript 18 MR WEINBERG: Why don't we Igo a break and 16 does not apply toLanny reproduction of die same by any 19 have lunch. means unless under the direct °retro] and/or direction 17 of the catifying reporter. 20 :u 21 MR. WEINBERG: as Dated this lath ft , of May, 2010. 22 (A luncheon recess was taken.) 20 21. C.__ ../ 23 earn Rleciutl, FPR, CLR 24 23 4 25 25 Page 497 1 CERTIFICATE OF OATH 2 STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 6 I, the undersigned authority, certify that 7 JOSEPH RECAREY pctsonally appeared before Inc and was 8 duly sworn on the 27th day of April, 2010. 9 10 Witness my hand and official seal this 27th 11 day of April, 2010. 12 13. 14 15 C --j..40 16 Jeana Ricciuti, RPR, PPR,ter 17 Notary Public - State of Florida My Commission Expires: 2/17/2013 18 My Commission Na: DD 854778 19 20 21 22 23 24 25 4.6 (Pages 496 to 498) PROSE COURT REPORTING 'AGENCY, INC. ' Electronically signed by Jeana RIcclutl (601 Electronically signed by Jeans Ricciuti(601M) c5062637-abel-452c-a836-bc614e31447a EFTA00298258