EFTA00298259

Page UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME I OF II JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994 08-80993, 08-80811, 08-80893, 09-80469 09-80591, 09-80656, 09-80802, 09-81092 DEPOSITION OF DETECTIVE JOSEPH RECAREY Friday, March 19, 2010 9:37 - 5:12 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1509 PROSE COURT REPORTING AGENCY, INC. EFTA00298259 EFTA00298260 Page 2 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 1 APPEARANCES CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 On behalf or Ole Plaintiffs, BE, CL: 3 SPENCER T. KUVIN, ESQUIRE 2 CASE No.502008CA0373150000TMB AB LEOPOLD KUVIN 3 2925 PGA Boulevard B.B. State 200 5 Palm Beach Gardens, Florida 33410 Plaintiff, Phone: 5 6 6 -vs- VOWME 1 OF11 On behalf of the Plaint", L.M., SW. and 7 Jane Doe: e ~SI 9 BRADLEY J. EDWARDS. ESQUIRE 8 FARMER. LOW, WEISSRM. EDWARDS Defendants. 10 195 Kra & LEHRMAN, P.L 9 425 North Andrews Avenue 10 11 Suite 2 11 Fort Lauderdale, Florida 33301 12 Mom' 12 DEPOSMON OF 13 On lzhalf Ø6h 8: DETECTIVE JOSEPH RECAREY 14 JESSICA ARBOUR, ESQUIRE 13 MERMELSIEN 8cHOROWITZ,P.A. 14 Friday, March 19, 2010 25 18205 Biscayne Boulevard 15 937- 5:12 pm. Suite 2218 16 250 Australian Avenue South 16 Miami, Florida 33160 Plasm. Suite 1500 17 E-mail: 17 West Palm Beach, Florida 33401 18 0815~0 o K i , 488 18 103: 19 19 20 20 KATHERJHE W. EZELL ESQUIRE 21 PODHURST ORSECK 22 Reported By: 21 25 West Elegier Street Suil4 800 Cynthia Ilepldns, RPR, FPR 22 Minne- FØ 33130 23 Notary Public, State of Florida Phonc~ Prose ØQØ Reporting 23 <Via 24 509 24 25 25 Page 3 1 1 Apecaianoes (*mimed 2 On behalf of the Ptainttffs: 2 UNTIED STATES DISTRICT COURT 3 ISIDRO MANUEL GARCIA, ESQUIRE SOUTHERN DISTRICT OF FLORIDA GARCIA, ELKINS & LIOEBRINOER 3 224 Datura Awnuc, Sub< 900 CASE NO. 10-80309 W491 him Beach, Florida 33401 4 5 !tone 6 and 5 JANE DOE NO. 103, 7 TARA A. FINNIGA/4, ESQUIRE 6 Plaintiff, TARA A. FINNTOAN, P.A. 7 -vs- VOLUME I OF R a 224 Datum Street 8 JEFFREY EPSTEIN, Suite 900 9 West Min Buck Florida 3340) 9 Defendant. Phone' I 10 10 11 On behalf of the Defendant, Jeffrey Egleix 11 12 MICHAEL PIKE, ESQUIRE 12 DEPOSITION OF BURMAN, LØN, LUTITER & COLEMAN. LLP 13 303 Banyan Boulevard DETECTIVE JOSEPH RECAREY SUN 400 13 14 West Palm Beach. florid' 33401 14 Friday, March 19, 2010 Phone 15 9:37 - 5:12 p.m. 15 16 and 16 250 Australian Avenue South 17 JAC* ALAN GOLDBERGER., ESQUIRE Suite 1500 ATTERBURY, GOLDB/eRGF.R & WEISS, P.A 17 West Palm Beach, Florida 33401 18 250 Australian Avenue South 18 Suite 1400 19 19 West Patin Eked\ Florida 334014012 Phone: 20 20 21 21 and 22 Reported By: 22 MILTON G. WEINBERG, ESQUIRE Cynthia Hopkins, RPR, FPR LAW OFFICE OP MILTON G WEINBERG 23 10 Park Plata 23 Notary Public, State of Florida Suite 1000, Parse Court Reporting 24 Bost" Map:schwa 02116 24 fob No.: 1509 Phon 25 25 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. EFTA00298261 Page 6 Page 8 Appearances continued... 1 PROCEEDINGS 2 On behalf of the Witness: 2 MR. KUVIN: Just so we're clear with 3 JOANNE M. O'CONNOR, ESQUIRE 3 respect to the deposition, I understand that JONES, FOSTER, JOHNSON & STUBBS, PA 4 505 South Flagler Drive, Suite 1100 4 Mr. Epstein has three attorneys here today but West t ida 33401 5 only one of them, pursuant to the Rules, is 5 Phone: 6 going to be permitted to object to questions. 6 7 So I just wanted a designation as to which Also Present: Jeffrey Epstein 3 8 attorney is going to be objecting to questions. 9 INDEX 9 MR. PIKE: I will be objecting and 10 10 Mr. Weinberg will probably be asking questions. 11 11 I don't — 12 EXAMINATION DIRECT CROSS REDIRECT 13 12 MR. KUVIN: I have no problem - DETECTIVE JOSEPH RECAREY 13 MR. PIKE: Do you have any objection with 14 14 that? MR. KUVIN 9 15 MR. KUVIN: I have absolutely no problem 15 BY MR. EDWARDS 242 16 16 if you want to switch it up as to who is 17 17 objecting and who is asking questions. That's 18 EXHIBITS 18 not a problem. I just don't want to get three 19 19 set of objections. 20 21 EXHIBIT DESCRIPTION PAGE 20 MR. PIKE: twill be the main on the 22 21 objections and Mr. Weinberg will be taking, PLAINTIFFS EX. 1 PROBABLE CAUSE 15 22 asking the questions. 23 AFFIDAVIT 23 MR. GOLDBERGER: Do we have to tag each PLAINTIFFS EX. 2 INCIDENT REPORT 23 24 other? 24 PLAINTIFF'S EX 3 INCIDENT REPORT 45 25 PLAINTIFFS EX 4 PROPERTY RECEIPTS 126 25 MR. KUVIN: No. I would prefer you Page 7 Page 9 MERITS CONTINUED_ 1 wouldn't talk at all, but we'll deal with that 2 MINT DESCRIPTION PAGE 2 later. nAmmnsEcaAnwnnvmximn 127 3 (A discussion was held off the PLAINTIFFS EC 5 SUPPLEMENT FOR own 151 OP CUSTODY LOG 4 record.) PLAINEFFS EC 6 PAGE FROM MESSAGE PAD 196 PLAINTIFFS ER 7 Moue MESSAGE 204 5 Thereupon, PIA/MPS EX 8 PHONE MESSAGE 205 6 (DETECTIVE JOSEPH RECAREY) PLAINTIFFS DC 9 PHONE MESSAGE 208 PLAINTIFFS DC 10 PHONE MESSAGE 209 7 Having been first duly sworn or affirmed, was PLAINTUTS EX 11 PHONE MESSAGE 210 8 examined and testified as follows: PLAINTIFFS EC 12 PHONE MESSAGE 212 4 PLAINTIFFS EC 13 PHONE MESSAGE 213 9 THE WITNESS: I do. PLAINTEFFS DC 14 PHONE MESSAGE 215 10 PLAINTIFFS Et. 15 PHONE MESSAGE 215 10 DIRECT EXAMINATION PLAINTIFF'S DC 16 PHONE MESSAGE 217 11 MR. KUVIN: All right. Just as a 11 PLAINTIFFS DC 17 PHONE MESSAGE 219 PLAINTIFFS DC 18 PHONE MESSAGE 220 12 stipulation on the record so that we have it 12 PLMNTIFFS DC. 19 PHOLE MESSAGE 221 3 all clear, what we have discussed prior to PLAINTIFFS DC 20 PHONE MESSAGE 222 13 PLAINTIFF'S DC 21 PHONE MESSAGE 223 14 starting the deposition is, is that since we're 14 PLAINTIFFS EX. 22 PHONE MESSAGE PLAINTIFFS Et 23 AND 24 PHOTOS 225 15 discussing girls which were under the age of 227 PLAIN EC 25 PH E 230 16 18, minors at the time of the incidents 15 PlAINTIFFS EX. 26MS. 240 17 involved in this case, we're going to be using CELLPHONE LOG 16 pLAEMPFS EX. 27 LEITER DATED JULY 24, 241 18 their names as previously agreed to in all the 2006 17 PLAINTIFFS DC 28 INTELLIGENCE REPORT 243 19 other depositions in the case pursuant to court DATED 112804 20 order. 18 19 21 The names will be used in the 20 21 22 deposition, but they will not be used in 22 23 the official transcript. There will be a 23 24 key at the end of the transcript which 24 25 25 will be sealed and confidential onl for 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. EFTA00298262 Page 10 Page 12 1 the eyes only of the attorneys involved in 1 Q. All right. We're going to be talking to 2 this litigation. 2 you today about incidents that occurred back in 3 Therefore, Detective Recarey should 3 roughly 2005,'6, and 7. During that period of 4 feel free to discuss names with the 4 time were you a detective? 5 understanding that those names shall not 5 A. Yes. 6 be made public outside the lawsuits that 6 Q. Okay. All right. And lets just 7 are currently pending in both state and 7 summarize briefly what you're going to talk about B federal court. But that way hopefully it 8 first and then we'll get down into the details of 9 will avoid confusion and I just want to 9 it. 10 make sure we get agreement from all 10 Did you have occasion to begin an 11 counsel sitting around the table that that 11 investigation with respect to a gentleman by the 12 is the understanding. And if there is any 12 name of Jeffrey Epstein? 13 clarification on that issue, please let us 13 A. Yes, I did. 14 know. 14 Q. And when did that investigation begin 15 MR. PIKE: Agreed. 15 roughly? 16 MR. EDWARDS: Agreed. 16 A. That case was assigned to me on September. ] 17 MR. GARCIA: Agreed. 17 believe, of 2005. 18 MS. ARBOUR: Agreed. 18 Q. And what were you assigned to investigate? 19 MR. KUVIN: Katherine, agreed? 19 A. There was an allegation of an underaged female 20 MS. P7RII • Yes, I am here. 20 that had went to the home of Mr. Epstein and was asked 21 MR. KUVIN: Did you hear my stipulation? 21 to perform a massage at which time it became sexual in 22 MS. P7Pli : Yes. 22 nature and she was paid for her services. 23 MR. KUVIN: Do you agree with that? 23 Q. All right. 24. MS. WPM: Yes. 24 MR. PIKE: fin going to object to fomi as 25 MR. KUVIN: Okay. 'just wanted to make 25 speculation and hearsay and move to strike. Page 11 Page 13 1 it clear. 1 BY MR. KUViN: 2 MS. EZELL: Thank you. 2 Q. With respect to the investigation that you 3 BY MR KUVIN: 3 performed, how long roughly did that investigation 4 Q. Why don't you give us your full name, if 4 last? in other words what period of time are we 5 you would, please. 5 looking at here from beginning to end? And if it 6 A. Joseph Recarey. 6 helps you, I have the incident report. 7 Q. Detective Recarey, could you please tell 7 A. It was approximately, I believe, a year. 8 us what you do fora living. 8 Q. Okay. Could you summarize for us 9 A. I am a detective with the Town ofPalm Beach 9 generally, and like 1said we'll get into details by 10 Police Department. 10 going through it, but generally what did you do 11 Q. How long have you been a detective for the 11 during the investigation? 12 Town ofPalm Beach? 12 MR. PIKE: Form. 13 A. Approximately 15 years. 13 THE WITNESS: Conducted interviews, 14 Q. And what is your exact title there for the 14 executed a search warrant, issued subpoenas. 15 Town ofPalm Beach? 15 continued with interviews. 16 A. Detective or a police officer. 16 BY MR. KUVIN: 17 Q. Do you work in a particular unit? 17 Q. When you did the interviews, are we 18 A. The — currently assigned to the Organized 18 talking about any interviews with Mr. Epstein? 19 Crime/Vice and Narcotics. 19 A. No, there was no interviews with Mr. Epstein. 20 Q. How long have you been assigned to that 20 Q. Did he ever agree to talk to you? 21 unit? 21. A. Originally when I was speaking with attorney 22 A. Approximately three years. 22 Guy Fronstin, there was a mention that he would be 23 Q. Okay. What did you do before that for the 23 available for an interview. However, that never came to 24 town? 24 be. 25 A. I was a general detective. 25 Q. Why not? 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. EFTA00298263 Page 14 Page 16 1 MR. PIKE: Same objection. 1 with either In Mend who were 2 THE WITNESS: It was discussed that he 2 minors at the time of the incidents that 3 would not appear to, for any interview. 3 occurred. 4 BY MR. KUVIN: 4 MR. PIKE: Move to strike. 5 Q. All right. Eventually a probable cause 5 BY MR. ICUVIN: 6 affidavit was filled out in and around May of 2006; 6 Q. Did you feel there was sufficient possible 7 is that coned? 7 cause to charge Mr. Epstein at that time and if so 8 A. Correct. 8 with what? 9 Q. And what was the basis of the probable 9 MR. PIKE: Font 10 cause affidavit if you could summarize for it for 10 NE WITNESS: Yes, I did, and it was with 11 us? What were — what did you find after doing your 11 four counts of Unlawful Sexual Activity with a 12 investigation? 12 Minor, and one count of Lewd and Lascivious 13 MR. PIKE: Form. 13 Molestation. 14 THE WITNESS: There were several victims 14 BY MR. KUVIN: 15 that had been interviewed based on their age, 15 Q. All right. The lewd and lascivious 16 the acts that occurred at the residence. There 16 molestation charge, could you explain that a little 17 was enough probable cause to request a warrant 17 more as well? 18 for Mr. Epstein. 18 MR. PUCE: Form. 19 BY MR. KUVIN: 19 THE WITNESS: The victim, that was the 20 Q. All right. And for those that might not 20 initial victim that came forward, it was a 21 understand, a warrant means what? 21 14-year-old minor at the time of the incident. 22 A. An arrest warrant. 22 She had gone to the house. This was the 23 MR. KUVIN: Okay. I would like to show 23 initial report that was taken by Officer Pagan. 24 you what we'll mark as Exhibit 1. Why don't 24 14 at the time. Was brought over to perform a 25 you give me a shed 25 massage. The incident turned into a, sexual in Page 15 Page 17 1 (Plaintiffs Exhibit No. 1 was marked for 1 nature, and it was at the time she was paid for 2 identification.) 2 her services and left. 3 BY MR. KUVIN: 3 MR. PIKE: Move to strike. 4 Q. All right. What we have marked as 4 MR. KUVIN: 5 Exhibit 1, is that the probable cause affidavit that 5 Q. Okay. Now, this personM,col ou come 6 you filled out with respect to Mr. Epstein? 6 to learn that her name at the time was 7 A. Correct. 7 A. Yes, I did. 8 Q. And does your signature appear on each and 8 Q. All right And according to the 9 every page of this probable cause affidavit? 9 information you had, she was how old at the time 10 A. Correct. 10 that she came over to Mr. Epstein's house for the 11 Q. And is that your signature at the bottom 11 sexual contact? 12 left corner? 12 MR. PIKE: Form. 13 A. Yes, bottom right 13 THE WITNESS: Fourteen. 14 Q. Bottom right. I apologize. 14 BY MR. KUVIN: 15 All right: Let's go to, if we could, 15 Q. All right Was she the youngest that you 16 Page 22 of 22. And the last paragraph, could you 16. were able to determine came to Mr. Epstein's home 17 explain to us the conclusions in the probable cause 17 during your investigation? 18 affidavit and exactly what Mr. Epstein was being 18 A. Coned. 19 arrested for at the time? 19 MR. PIKE: Form. 20. MR. PUCE: Form. 20 BY MR. KUVIN: 21 THE WITNESS: Based on the interviews 21 Q. All right. With respect to the others, 22 conducted, it was determined that Mr. Epstein, 22 justso we have it on the record and we're clear,. 23 who at the time of the incident was 23 would have been whom? 24 approximately 51 years of age, did have vaginal 24 A. Jane Doe No. 103. 25 intercourse either with his penis or 25 5 (Pages 14 to 1 7) • PROSE COURT REPORTING AGENCY, INC. ' EFTA00298264 Page 18 Page 20 1 A. Jane Doe No. 2. 1 A. So many things occurred with the State 2 MR. PIKE: I am going to object to form 2 Attorneys Office. Originally it was determined that it 3 through these series of questions so we don't 3 was going to.be a grand jury. 4 have to keep repeating with regard to the 4 Q. Okay. 5 information. 5 A. And then the case was going to be presented to 6 MR. KUVTN: Yeah, well, I want to make 6 the grand jury. That was later retracted and they 7 sure I understand what is the form objection. 7 wanted a probable cause affidavit 8 MR. PIKE: Your, your questions are 8 Q. Okay. 9 relating back to opinion and hearsay evidence 9 A. I submitted the probable cause affidavit 10 and the investigation. So, actually just go 10 Shortly thereafter I was told we're going back to the 11 ahead and I will put it on the record. Go 11 grand jury. 12 ahead. 12 Q. Okay. Well, let me ask you this: After 13 MR. KINN: All right. I just wanted to 13 the probable cause affidavit was issued, did you 14 make sure I knew because I wanted to fix them 14 institute the search of the home at that point or 15 if there was something that I could do to fix 15 you institute the search of the home before the 16 them. 16 davit was — 17 MR. PIKE: I don't think you can unless 17 A. Prior, prior to theMaffidavit. 18 you want to start the depo over. 18 Q. Okay. All right. Let's go back. Why 19 MR. ICUV1N: No, but I can start from now. 19 don't you give us, if you would, briefly your 20 MR. PIKE: Let's go. 20 training and experience as an officer. Just start 21 BY MR. KUVIN: 21 with, you know, where you went to the academy and 22 Q. All right. During your investigation did 22 where you started working and then kind of work us 23 you identify who III was, and if so who? 23 through to when you got your job at Palm Beach 24 MR. PIKE: Form. 24 County or Palm Beach. 25 THE WITNESS: Yes, I did. I identified 25 A. I went to the police academy back in 1990 -- Page 19 Page 21 S 1 Q. Okay. 2 BY MR. KUVIN: 2 A. -- down here in Palm Beach County. I was 3 Q. CA is who? 3 hired by Palm Beach in 1991 where 1 did three years on 4 the, as a patrol officer. : Same objection. 5 Q. Okay. 6 BY MR. KUVIN: 6 A. I was transferred then to the detective 7 Q. Okay. Now, these girls that you 7 bureau. 8 identified in your probable cause affidavit here at 8 Q. Roughly when? 9 the conclusion, did you find that all of these girls 9 A. '94. 10 were under the age of 18 at the time they went to 10 Q. Okay. 1.1 Mr. Epstein's home? 11 A. From the detective bureau, I went to the 12 MR. PIKE: Form. 12 Organized Crime/Vice and Narcotics Unit where I spent 13 THE WITNESS: Correct. 13 about five, six years. 14 BY MR. KUVIN: 14 Q. When did you get into that unit roughly? 15 Q. And how old were they? 15 A. I would say *96, '95, '96. 16 A. They were approximately 16, 15, 16 and/or up 16 Q. Okay. And you spent how long there? 17 to 17 years of age. 17. A. About roughly five to six years. 18 MR. PIKE: Form. 18 Q. All right. Then where did you go? 19 BY MR. KUVIN: 19 A. Back to the detective bureau. 20 Q. Okay. All right: Do you recall how old 20 . Q. So we're looking at like 2000 and 2001? 21 C.L. was? 21 A. Correct 22 A. I believe she was 16. 22 Q. All right 23 Q. After filling out and signing the probably 23' . A. I was there for up to 2006, I believe, 2000 -- 24 cause affidavit, could you explain to us what 24 2006. 25 reared next? 25 Okay. And then in 2006? 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY.,. INC.. EFTA00298265 Page 2._ Page 24 1 A. They created another, a unit from the 1. Department Incident Report which appears to be 2 Organized Crime/Vice and Narcotics Unit. Made it 2 numbered, thankfully, and consists of 87 pages plus 3 special investigations. Went over to there where Pm -- 3 one. It looks like there is 87 consecutively it was renamed back to the Organized Crime/Vice and 4 numbered pages and then a single page again numbered 5 Narcotics. 5 as Page I, just for the record. Q. Okay. 6 All right. First of all, do you A. That's basically what we would operate on. 7 recognize what we have marked as Exhibit 2? 8 Q. Gotcha. And you've been in that unit 8 A. Yes, !do. 9 since then to the present day? 9 Q. And could you describe for us what that 10 A. Correct 10 is? 11 Q. Okay. Have you ever worked in any other 11 A. It is the Palm Beach Police Department's 12 department? 12 Incident Report. 13 A. I worked for the State Attorney's Office as a 13 Q. AM right. When this investigation first 14 process server for five years. 14 began, were your, were you the first one that was 15 Q. Okay. And that was before going to the 15 contacted regarding potential allegations against 16 academy in 1990? 16 Mr. Epstein? 17 A. Correct. 17 MR. PIKE: Form. 18 Q. Okay. High school graduate? 18 THE WITNESS: No, I was not. 19 A. Correct. 19 BY MR. KLIVIN: 20 Q. Any secondary schooling, college? 20 Q. Who was the first one that was actually 21 A. College credits and specialized training with 21 contacted, and could you explain to us if you NNW IL. 22 the police department. 22 how they were contacted? 23 Q. Okay. Did you get an AA in college or no? 23 A. It was Officer Michele Pagan. 24 A. No. 24 Q. Okay. And do you blow as you sit her: 25 Q. Okay. Where did you get your college 25 today under what circumstances she was contacted? Page 23 Page 25 1 credits? A. I believe it was telephonicalliiitelephone. 2 A. PBCC. 2 Q. Okay. Was she contacted by herself 3 Q. Are you from here locally, Palm Beach? 3 or her parents, do you remember? 4 A. No. 4 MR. PIKE: Form. 5 Q. Where from? 5 THE WITNESS: I totally believe it was the 6 A. New York City. 6 step-mother that called her. 7 Q. When did you come down here? 7 BY MR.. KUVIN: 8 A. 1980. 8 Q. Okay. When Ms. Pagan took down that 9 Q. Okay. All right Let's walk through kind 9 inforMation, how soon after were you actually 10 of chronologically what occurred in this particular 10 brought into the investigation? 11 case. And just so that it's easier for you, let me 11 A. I believe she took the report in March, and I 12 give you the incident report. What I will do is I 12 took, I took possession of the case in September. 13 am going to ask you questions. 13 Q. Do you know why the break in time between 14 If you need to refresh your 14 March and September when you actually get it? In 15 recollection at any point with the incident report, 15 other words do you know why you got the case some 16 just let us know that you're using it to refresh 16 months later? 17 your recollection which is fine. I just want to 17 A. She was transferred to patrol. 18 make sure that we can distinguish between what you 18 Q. Okay. So, Ms. Pagan was originally 19 may recall indepcudendy versus what you may be 19 investigating this case — 20 using to refresh your recollection. 20 A. Correct. 21 (Plaintiffs Exhibit No. 2 was marked for 21 Q. -- until she got transferred to patrol? 22 identification.) 22 A. Yes. 23 BY MR. KUVIN: 23 Q. Did her transfer to patrol have anything 24 Q. All right. I'm going to give what you we 24 to do with this case? 25 have marked as Exhibit 2 as the Palm Beach Police 25 A. No. .7crodrol.16 7 (Pages 22 to 2 5) PROSE COURT REPORTING AGENCY, INC. EFTA00298266 Page 26 Page 28 1 Q. Okay. When you take over the 1 the investigation early on -- 2 investigation in September — and just so we're MR. KUVIN: Okay. 3 clear we're talking about September of 2005? THE WITNESS: — as bringing ill 4 A. Correct. 4 BY MR. KUVIN: 5 Q. When you take over that case, do you take 5 Q Okay. Any other minors that you can 6 any particular action to bring yourself up to speed 6 recall came up at that point; in other words the 7 on what's going on? 7 point between when Ms. Pagan starts the 8 A. I reviewed her reports and listened to the 8 investigation until when you take it over? 9 interviews and what she had already evidentiary-wise. 9 MR. PIKE: Object to the fonn. 10 Q. Okay. Let's go to, if you would, Page 22 10 THE WITNESS: No, not that I can recall. 11 of the incident report. Just so we can make sure 11 BY MR. KUVIN: 12 that we have an accurate chronology here, it appears 12 Q. Okay. Where is Ms. Pagan today? Is she 13 right in the middle of the page we have got the date 13 here locally? 14 of September 8, 2005. And it states: I reviewed 14 A. Yes, she's still with the police department. 15 the case notes of this file as the case will be 15 She rides the bicycle. 16 turned over to Detective Recarey. Do you see that? 16 Q. Okay. If you would, can you turn to 17 A. Yes, I do. 17 Page 17 for me of the Incident Report. Towards the 18 Q. Was that roughly the dale that the 18 bottom, third paragraph from the bottom, it 19 investigation was turned over to you? 19 tefetwces a cross-reference of Epstein's residence. 20 A. No. It was turned over officially I think the 20 Do you see that? 21 19th. 21 A. Uh-huh. 22 Q. Okay. And we see that in Narrative 2 at 22 Q. What was the residence that you found for 23 the bottom of the same page? 23 Mr. Epstein, the address, the physical address? 24 A. Correct 24 A. 358 El Brillo. 25 Q. All right. And the first entry there says 25 Q. Palm Beach Island? Page 27 Page 29 1 on September 19, 2005, you met with Officer Pagan 1 A. Correct. 2 and received the information pertaining to the case? 2 Q. Okay. And it states there that a 3 A. Correct. 3 cross-reference of that address revealed certain 4 Q. All right. When you received that 4 affiliated names. Could you give us those names? 5 information, is it safe to assume that you reviewed 5 MR. PIKE: I am sorry, Counsel, what 6 the investigation materials that Michelle Pagan had 6 paragraph? 7 collected up until that date? 7 MR. KUVIN: Third from the bottom starting 8 A. Yes, I believe so. 8 with the cross-reference. 9 Q. Okay. At this point in time do you know 9 MR. PIKE: Appreciate it. 10 bow many potential victims there were of 10 MR. KUVIN: S 11 Mr. Epstein? 11 TILE WITNESS Mark 12 MR. PIKE: Form. 12 Epstein, and Ghislaine Maxwell. 13 THE WITNESS: No, we didn't know the 13 BY MR. KINN: 14 octant of how many victims at that point. 14 Q. Okay. How is it those affiliated names 15 BY MR. KUVIN: 15 came up? In other words what database were you 16 Q. All right. We 'mow that 16 looking at to reference those names? 17 step-mother had called in and there as an 17 A. If she cross-referenced it, she used the Town 18 investigation regarding her. Were there any other 18 of Palm Beach CAD system. 19 minors at that point that had come into the 19 Q. And just for those that may not know, what 20 investigation? 20 is the CAD system? 21 MR. PIKE: Fonts. 21 A. The CAD system is basically if someone is, is 22 WITNESS: We knew of a girl by name of 22 we had a 911 hangup or an slant) call or any kind of 23 23 incident that accrues within the Town of Palm Beach, 24 MR. KUVIN: Okay. 24 when the officer responds and they encounter someone at 25 THE WITNESS: That her name had come up in 25 the home, whatever the reason, whether it be a false 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. EFTA00298267 Page 30 Page 32 1 alarm, 911 hangup, you get their information. That 1 point during the massage Mr. Epstein - this is 2 information gets put into the CAD system as to who, who 2 all off recollection by the way. 3 the officer encountered on that property. 3 MR. KUVIN: If you want to use the 4 Q. Okay. Is it regular practice for you as a 4 incident report, what we're referring to would 5 detective when taking over a file from another 5 be on Pages 11 through roughly 15 of the 6 detective to review all the materials that they have 6 incident report — 7 put together? 7 MR. PIKE: Just -- B A. Yes. 8 MR. KUVIN: — if you need it to help 9 Q. All right. And are these records 9 refresh your recollection. 10 contained within the Palm Beach Police Department? 10 MR. PIKE: Just so the record is clear, 11 In other words are these the regular business 11 we're still on the one question. There is a 12 records of the department -- 12 form objection on the same answer. 13 A. Yes. 13 THE WITNESS: It was — I haven't found 14 Q. -- the information contained within the 14 exactly where she goes into the story, however 15 investigation that Ms. Pagan had put together? 15 I know — 16 A. It is no longer in the department if that's 16 MR. KUVIN: I think ifs at Page 14. 17 what you're asking. 17 THE WITNESS: — where there was some 18 Q. No, I mean at the time, when you take over 18 touching involved, and Mr. Epstein then, I 19 sometime in September. 19 believe, introduced a massager. 20 A. Yes, correct. It would be. 20 BY MR. KUVIN: 21 Q. Okay. 21 Q. A vibrator? 22 A. It would be. 22 A. Correct. 23 Q. All the information is contained within 23 Q. Okay. Was she asked to take her clothes 24 the Town of Palm Beach investigative unit? 24 off according to what she told the police 25 A. Correct. 25 department? Page 31 Page 33 1 Q. I understand. Now, it's obviously not 1 MR. PIKE: Font 2 public at that point. You're keeping the 2 THE WITNESS: Yes. 3 investigation private? 3 BY MR. KUVIN: 4 A. Correct 4 Q. And how old was she at the time? 5 Q. But nonetheless all those documents that 5 MR. PIKE: Form. 6 you would have reviewed front Ms. Pagan would have 6 THE WITNESS: Fourteen. 7 been business records of the police department at 7 BY MR.. KUVIN: 8 the time? 8 Q. Was there an investigation as to howl. 9 A. Correct. 9 actually was taken to the home? In other words did 10 Q. I understand. Now, when you reviewed this 10 you determine who took her there? 11 information from Detective Pagan, could you walk us 11 A. Correct 12 through exactly what■ had explained occurred to 12 Q. Who was that? 13 her? 13 A. 14 MR. PIKE: Form. 14 15 THE WITNESS: She was taken to 15 BY MR. KUVIN: 16 Mr. Epstein's house for the purpose of making 16 Q. Did Ms. Pagan interview Ms. MI? 17 money, providing a massage. 17 A. No, she did not. 18 MR. KUVIN: Okay. 18 Q. Not at this point? 19 THE WITNESS: Once she got there, she was 19 A. No. 20 taken upstairs to the bedroom area At that 20 Q. Did you ultimately interview Ms. IM 21 time what my understanding was is they were 21 A. Yes, I did. 22 taken to the bedroom area through the stairwell 22 Q. With respect to whatMxplained. I 23 where Mr. Epstein was awaiting to do a massage. 23 would like to walk through this if I could for a 24 MR.. KUVIN: Okay. 24 minute. 25 THE WITNESS: The massage began. At some 25 MR. PIKE: What sage are vou on? 9 (Pages 30 to 33) PROSE COURT REPORTING AGENCY, INC. EFTA00298268 Page 34 Page 36 1 MR. KUVIN: Fourteen. 1 THE WITNESS: He told her to remove, take 2 BY MR. KUVIN: 2 off her clothe's. 3 Q. Was there another woman that she described 3 BY MR. ICUVIN: 4 in the home at Epstein's house? 4 Q. Okay. And she's 14 at this point? 5 MR. PIKE: Form. 5 MR. PIKE: Form. 6 THE WITNESS: Yes. She described a tall 6 THE WITNESS: Cared. 7 blonde female which I believe was 7 BY MR. KUVIN: 8 8 Q. What did explain was his demeanor, BY MR. KUM: 9 Mr. Epstein's demeanor with respect to asking her to 10 Q. Okay. And what did IIIM.10 10 take off her clothes? 11 MR. PIKE: Form. 11 MR. PIKE: Form. 12 BY MR. KUVIN: 12 THE WITNESS: I believe he was stern when 13 Q. -- as far as what she described to you? 13 he instructed her to remove her clothing. 14 MR. PIKE: Same objection. 14 BY MR. KUVIN: 15 THE WITNESS: If I can just — I am going 15 Q. What was he dressed in? 16 to -- 16 MR. PIKE: Form. 17 MR. KUVIN: Yeigie a look. 17 THE WITNESS: In a towel. 18 THE WITNESS: was the one who took 18 BY MR. KUVIN: 19 her upstairs, I believe. 19 Q. Could you explain to us exactly what 20 MR. PIKE: Form. 20 Mr. Epstein supposedly instructed her to do — 21 BY MR. KUVIN: 21 MR. PIKE: Form. 22 Q. Upstairs in Mr. Epstein's house? 22 BY MR. KUVIN: 23 MR. PIKE: Same objection. 23 Q. — and then what he did? 24 THE WITNESS: Yes. 24 MR. PIKE: Same objection. 25 25 THE WITNESS: He instructed her to provide Page 35 Page 37 1 BY MR KUVIN: 1 a massage pointing to the specific lotion for 2 Q. The same home that we described before on 2 her to use. He laid on the table face down. 3 El Brill° Way? 3 As she was providing the massage, he asked her 4 MR. PIKE: Form. 4 to get onto his back. She straddled herself 3 THE WITNESS: Yes. 5 along his back and advised that her exposed 6 BY MR. KUVIN: 6 buttocks was touching his bare buttocks. 7 Q. All right. Let's walk through some of 7 MR. PIKE: Form, move to strike. 8 this. When she gets upstairs, the woman leaves the 8 BY MR. KUVIN: 9 room? Q. What happened next? 10 MR. PIKE: Form. 10 MR. PIKE: Form. 11 . THE WITNESS: Correct. 11 THE WITNESS: He turned over onto his back 12 BY MR. KUVIN: 12 and was masturbating. 13 Q. Okay. At that point does she tell you 13 BY MR. KUVIN: 14 that Mr. Epstein comes in? 14 Q. Okay. Did he masturbate to conclusion 15 MR. PIKE Form. 15 according to her? 16 THE WITNESS: This is what she's informing 16 MR. PIKE: Form. 17 Officer Pagan. 17 THE WITNESS: It doesn't state in the 18. BY MR. ICUV1N: 18 Mort. 19 Q. Pagan, yes? 19 BY MR. KUVIN: 20 • A. Yes. 20 Q. Okay. Did describe what her reaction 21 MR. PIKE: Same objection. 21 was to what was occurring at this point? 22 BY MR. KUV1N: 22 MR KUVIN: Form. 23 Q. All right. And what does Mr. Epstein do 23 THE WITNESS: She was disgusted by his 24 at that point according to what El explained? 24 actions but didn't say anything. 25 MR. PIKE: Form. 25 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY, INC. EFTA00298269 Page 38 Page 40 1 BY MR. KUVIN: 1 THE WITNESS: Yes. 2 Q. Okay. Was Ms.■ able to describe the 2 BY MR. KUVIN: 3 home? 3 Q. How did she describe it? 4 MR. PIKE: Form. 4 A. She stated that his, quote, wee-wee was very 5 THE WITNESS: Correct, she did. She 5 tiny. 6 described Epstein's house as a two-story pink 6 Q Okay. 7 house with a Cadillac Escalade parked in the 7 MR. PIKE: Form, move to strike. Just so driveway. 8 the record is clear, Detective Recarey is 9 BY MR. KUVIN: 9 reading from a document that has been marked as 10 Q. .Was she able to describe the inside of his 10 Exhibit -- 11 home? 11 MR. KUVIN: Two. 12 MR. PIKE: Form. 12 MR. PIKE: Exhibit 2. 13 THE WITNESS: Yes. 13 BY MR. KUVIN: 14 BY MR. KUVIN: 14 Q. Just so we can clarify for the record, 15 Q. Did your investigation uncover any reason 15 Detective, as a detective for the department, do you 16 why a 14-year-old girl, other than what she 16 regularly rely upon reports that are taken down by 17 described for you, may know what the inside of 17 other detectives in the department? 18 Mr. Epstein's home looked like? 18 A. Yes. 19 MR. PIKE: Form. 19 Q. Do you regularly trust other officers to 20 THE WITNESS: I'm sorry? 20 take down certain reports with respect to an 21 BY MR. KUVIN: 21 investigation? 22 Q. Did your investigation wit* any legal 22 • A. Correct. 23 reason why a 14-year-old girl lik would know 23 Q. And is that part of the regular practice 24 what's inside of Mr. Epstein's home ooked like 24 of an investigating detective, in other words to 25 other than what she had described to you? 25 refer to reports that are taken down by other Page 39 Page 41 1 MR. PUCE: Form. 1 officers during the, during an investigation? 2 THE WITNESS: No. 2 A. Yes. 3 BY MR. KUVIN: 3 Q. Okay. Just so we're clear, she referenced 4 Q. If we go onto Page 15 of the incident 4 his wee-wee. Was she referring to his penis? 5 report, does she describe fairly — well, you 5 MR. PIKE: Form. 6 explain to me what detail she described with respect 6 THE WITNESS: Yes. 7 to the interior of the home. Was it detailed? Was 7 BY MR. KUVIN: 8 it vague? How would you describe it? 8 Q. Okay. Was there any legal or lawful 9 MR. PIKE: Form and speculative. 9 reason that you could uncover during your 10 THE WITNESS: When we executed the search 10 investigation why'. may know the size, shape, or 11 warrant, items that she had mentioned, the 11 description of Mr. ein's penis being a 12 photos lining up the stairwell were there, the 12 14-year-old girl? 13' pink and green sofa was there, and there were 13 MR. PIKE: Form. 14 several photographs of naked women that was 14 THE WITNESS: No. 15 there as well. 15 BY MR. KUVIN: 16 • BY MR. KUVIN: 16 Q. All right. And did lescribe to 17 Q. So, essentially everything she described 17 Detective Pagan whether or not she received money 18 in her initial report to Detective Pagan was 18 for this event? 19 verified when you did the search warrant videotape? 19 A. Yes, she did. 20 A. Correct. 20 MR. PIKE: Form. 21 MR. PUCE: Form. 21. BY MR. KUVIN: 22 BY MR. KUVIlt 22 Q. During an investigation like this when 23 Q.. All right. Dididescribe whether or 23. interviewing a 14-year-old, 15-year-old, any let's 24 not she was able to see . Epstein's penis? 24 say girl that's under the age of 18, a minor, as 25 MR. PIKE: Rent 25 ofr ur investirtion, do you have to make a 11 (Pages 38 to 4 1) PROSE COURT REPORTING AGENCY, INC. EFTA00298270 Page 42 Page 44 1 determination as to whether you believe a witness is 1 THE WITNESS: I cannot recall at this time 2 telling the truth or not? 2 whose number that was assigned to. 3 MR. PIKE: Form. 3 BY MR. KUVIN: 4 THE WITNESS: Obviously when you're 4 Q. Okay. There was apparently a purple item 5 conducting an interview, you blow, based on the 5 pulled from the trash pull. Do you see that? 6 information gathered, you would want to verify 6 A. Yes. 7 any information that she provides. So, yes, 7 Q. • All right. I am hying to fmd, just so you would. 8 that I can tie it into the trash pull itself, if we 9 BY MR. KUVIN: 9 look at Pages 1 through 19, where is it that the 10 Q. Okay. Is what you are telling me that 10 trash pull occurs? Does she note it here? 11 when you have a witness talk to you about an event, 11 MR. PIKE: Form. 12 you always try to verify what they have said? 12 MR. KUVIN: Just so that I can have a 13 A. Correct. 13 timeline. 14 Q. Okay. Is it also part of your job as a 14 MR. PIKE: Same objection. 15 detective in your training to interview a witness 15 BY MR. KUVIN: 16 and make an internal decision whether you think they 16 Q. I may have it in the other document, 17 are being truthful or not nuthful based upon how 17 actually. Let me ask it this way: Can you tell by 18 they tell the story, the detail in which they tell 18 looking at that investigative report when that trash 19 it, and their reaction and other factors involved? 19 pull occurred, initially, the first one? 20 A. Obviously when she's providing, when anyone is 20 MR. PUCE: Form. 21 providing information and all the information gathered 21 THE WITNESS: No, I am looking for — it 22 has to be verified -- 22 might have been after based -- ifs how the • 23 Q. Okay. 23 reports are inputted. 24 A. -• you know, in any interview regarding any 24 MR. KUVIN: Here it is. Hang on one 25 case. 25 second. Let's do this; this may help. As part Page 43 Page 45 Q. All right. Before you were involved, did 1 of a subpoena to the Palm Beach Police 2 the department or did Officer Pagan do a trash pull 2 Department, we received a copy of e-mails that 3 of the home? 3 existed with respect to this case and 4 MR. PIKE: Form. 4 Mr. Epstein. 5 THE WITNESS: I believe so, yes. 5 What I would like to mark is what 6 BY MR. KUVIN: 6 we'll call Exhibit 3 I think we're up to 7 Q. And this first trash pull occurred before .7 now. I knew I saw it. I was trying to 8 you got involved in the investigation? 8 ' figure out where. Hang on a second. 9 A. Correct. 9 BY MR. KUVIN: 10 Q. All right. Let's look at Page 19. I want 10 Q. This is a e-mail from Nickie Altornaro. 11 to clarify just a couple of things that we have gone 11 Who was that? 12 over in some other depositions. 12 A. She was the detective bureau secretary. 13 MR. PIKE: Form, move to strike. 13 . MR. KUVIN: Okay. And it's indicated it 14 BY MR. KUVIN: 14 looks like October 17, 2005. Let me just show 15 Q. First of all, there was a subpoena request 15 it quickly to opposing counsel. It was in the 16 for a T-Mobile wireless phone number. Do you see 16 recent production by Palm Beach. 17 that? 17 . (Plaintiffs Exhibit No. 3 was marked for 18 A. Correct 18 identification.) 19 Q. All right. That number that's there in 19 BY MR. KUVIN: 20 the incident report, did you determine what number 20 Q. Do you mind if I look over your shoulder 21 that referenced? In other words what person that 21 while he looks at it. And I want to give you what 22 number referencecia.was it Ms. 22 we have marked as Exhibit 3. This might help a 23 Mr. Epstein, Ms. =, Ms. 23 little bit. Can you describe for us generally what 24 MR. PIKE: Form. 24 this is? 25 MR. KUVIN: -- or someone else? 25 A. This, it appears to be Officer Pagan's 12 (Pages 42 to 4 5) PROSE COURT REPORTING AGENCY, INC. EFTA00298271 Page 46 Page 48 1 incident report which was inputted by Nickie Altomaro. 1 Q. The well being the back of the trash 2 Q. Okay. Can you describe for us the process 2 truck? 3 by which the information is generally taken down at 3 A. Correa 4 the department back in 2005, and how it makes it 4 Q. Before it goes into the main bin? 5 into the incident report? 5. A. Correct. 6 A. Nickie Altomaro was the detective bureau 6 Q. Crotcha. Okay. 7 secretary. As we update the incident report, you type 7 A. Once that area is, we're confirmed that it is 8 up your report. And at this time we were using a DOS 8 empty, they go onto the property, remove the trash and 9 system. 9 place it into the well. We then follow it to an 10 Q. Okay. DOS as opposed to Windows based? 10 unspecified location where we actually remove the 11 A. Yes. 11 contents from the well. 12 Q. Gotcha. 12 Q. All right. Let's walk through now, 13 A. And we would type up the report, forward it to 13 continue turning to the date of 4/1/05 through 14 her either in Word Document or WordPerfect. She would 14 4/3/05. You should be an additional three pages 15 convert the document into a DOS format and input it into 15 down. 16 the system. 16 A. 4/1. 17 Q. All right. If we turn to -- it looks like 17 Q. Yes, sir. All right. If we look at 4/1 18 these are in, somewhat in date order. If we turn to 18 through 4/3/05, what was occurring on those dates? 19 3/21/05 which is on the eighth page. Did you get to 19 MR. PIKE: Form. 20 the date of 3/21/05? 20 THE WITNESS: She met with Detective 21 A. Yes. 21 Mattel of the police department. 22 Q. Okay. Was surveillance instituted on 22 BY MR. KUVIN: 23 Mr. Epstein's home at this time? 23 Q. Was there any additional surveillance 24 A. Correa. 24 conducted? 25 Q. All right. So we're talking March 21st, 25 A. Yes. Page 47 Page 49 2005, surveillance began at his home on El Brillo 1 Q. Okay. And what were the dates of the 2 Way; is that correct? 2 surveillance? 3 MR. PIKE: Form. 3 A. It appears she met with members of the B.S.F. 4 THE WITNESS: Correct. 4 Unit, Burglary Strike Force is what it was, for the 5 BY MR. KUVIN: 5 purpose of conducting surveillance at 358 El Brillo. 6 Q And on that exact date of 3/21/05 what Q. Okay. Now, this surveillance, was this else took place? 7 kept by the department? 8 MR. PIKE: Form. 8 A. Correct 9 THE WITNESS: Officer Pagan requested and 9 Q. Still held by the department? 10 Detective Lee initiated trash pulls from 358 10 A. Not 100 percent certain on that. It might 11 El Brillo. 11 have gone over to the FBI. 12 BY MR. KUVIN: 12 Q. Okay. We'll talk about that when we get 13 Q. Can you describe to us what a trash pull 13 to that point. But nonetheless before the FBI came 14 is? What do you do? 14 in, all of this was kept by the department? 15 A. Well, you inform the supervisor of sanitation 15 A. Correct. 16 that you're interested in pulling your target's trash, 16 Q. By your department Okay. All right If 17 you fund the location, who in turn informs the driver 17 we look at the bottom of the page, what's the date 18 that you're going to be pulling the trash. 18 that the trash pull was actually done? 19 Q. The driver of the trash truck? 19 MR. PIKE: Form. 20 A. The driver the trash truck. 20 THE WITNESS: On the bottom of the page? 21 Q. Ootcha. 21 BY MR. KUVIN: 22 A. Once that's done, we coordinate with the trash 22 Q. Yeah, the one we were talking about. 23 buck driver to ensure that the well is empty prior to 23 A. I'm still looking at Exhibit 3. 24 him going to your target location. He goes -- we follow 24 Q. Yep. 25 him to the target location. 25 A. So, it would be -- . 0.6•APODA, 13 (Pages 46 to 49) PROSE COURT REPORTING AGENCY, INC. EFTA00298272 Page 50 Page 52 Q. Top of the page it starts "at times 1 of it. But if we go back to Page 19, keep both of appear." 2 those documents available in case we need to refer 1 A. Correct. 3 to them. 1 Q. All the way at the bottom of the page, 4 But if we go back to Page 19 of the last line. 5 incident report, do you see towards the bottom of A. On April 5111,2005, the trash pull was 6 the page it references a purple item retrieved from 7 conducted by Detective Lee. 7 the trash pull? 3 Q. All right. And what did Detective Lee 8 A. Yes. 9 fmd? 9 Q. Okay. This particular purple item, did 10 MR. PIKE: Form. 10 Officer Pagan attempt to identify what it was? 11 THE WITNESS: It was a message from 11 MR. PIKE: Form. 12 indicating, and redacted, at 11:00 a.m. or 11. 12 THE WITNESS: Yes, she did. 13 MR. KUVIN: Okay. 13 BY MR. KUVIN: 14 THE WITNESS: The following information 14 Q. And at the point she attempted to identify 15 was obtained from the trash from 358 El Brillo. 15 it, what did she identify it as at this point back 16 BY MR. KUVIN: 16 in April of '05? 17 Q. What additional messages w 17 MR. PIKE: Form. 18 A. One from Jean Luc, David, There 18 THE WITNESS: She believed it was an anal 19 was some redacted redacted, Brit Ri n 19 wand of some sort. 20 is redacted, redacted, 20 21 BY MR. KUVIN: Q. And how did that identification take 21 a message fora receipt dated 4/4 at 1:05, 22 ith a phone number, and she's looking to 22 place? 23 spe to you. 23 A. I believe she researched it on the Internet. 24 Q. Okay. Let's talk about this fora minute. 24 MR. PIKE: Form. 25 The redacting, do you know why those are redacted at 25 Page 51 Page 1 this point? 1 BY MR. KUVIN: 2 MR. PIKE: Form. 2 Q. This particular jelly anal wand, this 3 THE WITNESS: Yes, I do. 3 purple item, was it later identified as something 4 BY MR. KUVIN: 4 different? 5 Q. Why? S A. Yes, it was. 6 A. It indicates either the names or the initials 6 Q. Okay. Can you describe that for us? 7 of the victims. 7 MR. PUCE: Form. 8 Q. The victims, what age were the victims? 8 THE WITNESS: It was during the execution 9 MR. PIKE: Form. 9 of the search warrant. During the search we 10 THE WITNESS: As young as 14 to 16. 10 found that it, it was a handle of a, of a 11 BY MR. KUVIN: 1 utensil used to eat. 12 Q. Okay. So if we see a redacted portion 2 (Ms. Finnigan entered the room.) 13 here, can we safely assume that that references one 3 MR. KUVIN: We added a person. 14 of the victims? 4 MR. GARCIA: There is a summary judgment 15 MR. PIKE: Form. 15 that I have to leave later. She works with our 16 THE WITNESS: Correct. 1. 6 office. 17 BY MR. KUVIN: 17 MR. PIKE: For the record she works with 18 Q. Is there any other redactions that would 18 SW, with Sid Garcia's office. 19 take place other than the names of the potential 19 MR. GARCIA: She shares a space with me. 20 victims? 20 That's close enough. 21 MR. PIKE: Form. 21 MR. KUVIN: Let's continue with the 22 THE WITNESS: Not that I am aware of 22 incident report. 23 BY MR. KUVIN: 23 MR. PIKE: Actually, no, let's not 24 Q. All right There was a reference that I 24 Is she listed as counsel? 25 had started with. I 'ust wanted to see the timi 25 MR. GARCIA: No. She a at 14 (Pages 50 to 53) PROSE COURT REPORTING AGENCY, INC. EFTA00298273 Page 54 Page 56 1 Mr. Epstein's deposition before. 1 MR. PIKE: Form. 2 MR. KUVIN: Has she filed a notice of 2 THE WITNESS: Yes. Captain David Rodgers, 3 appearance? 3 Co-captain Larry Visosld, flight engineer, 4 MR. GARCIA: No. 4 Larry Morrison. 5 MR. KUVIN: I am going to ask her to, ask 5 BY MR. KUVIN: 6 to excuse her. She has not filed a notice of 6 Q. Okay. In this trash pull were there also 7 appearance. There are confidential issues in 7 messages left by some of the potential victims in 8 this case and there are various orders that are 8 this case? 9 binding on various lawyers in this case. 9 A. Correct. 10 Sid, this is one of the very few 10 Q. All those victims being under the age of 11 depositions that you have actually been in 11 18? 12 attendance at, and if she has not filed a 12 MR. PIKE: Form, and form to the last one. 13 notice of appearance, if she has not 13 THE WITNESS: Correct 14 signed any pleadings in this case, I am 14 BY MR. KUVIN: 15 going to ask that she leave otherwise the 15 Q. And that's why they are blacked out? 16 deposition is not going to go forward. 16 MR. PIKE: Form. 17 MR. GARCIA: On what authority? 17 THE WITNESS: Correct. 18 MR. PIKE: She is not counsel. She has no 18 BY MR. KUVIN: 19 right to be here. 19 Q. All right. Let's turn to the next page of 20 MR. GARCIA: She's assisting me with this 20 the investigation. Actually, you know what, let's 21 case. She appeared at your own client's 21 go to the part where you start here which would be 22 deposition which you did not attend. 22 Page 22. 23 MR. PIKE: That's all well and good but 23 MR. PIKE: Thank you. 24 the fact is is that she does not have a notice 24 MR. KUVIN: For what? 25 of appearance here in this. MR. PIKE: Identifying the page. Page 5T, Page 57 1 MR. GARCIA: She will file one today. 1 MR. KUVIN: I thought I did something you 2 MR. PIKE: We're not going to go forward. like and I want to take it back. 3 MR. KUVIN: I am not stopping. 3 MR. PIKE: No. 4 MR. PIKE: The fact is these are 4 BY MR- KUVIN: 5 confidential communications. 5 Q. All right. What is the Burglary Strike 6 MR. GARCIA: Why don't you file a notice 6 Force? 7 of appearance and come back. 7 A. It is now a disbanded unit. However, it was a 8 MS. FINNIGAN: Okay. 8 unit of plain clothed officers. At that time we were 9 MR. GARCIA: That will resolve it. 9 being struck with burglaries. 10 (Ms. Finnigan left the deposition 10 Q. Okay. 11 room.) 11 A. It was a unit created just to combat and 12 BY MR. KUVIN: 12 locate people that were on properties, stuff like that. 13 Q. All right Let's continue on. 13 Q. Okay. Were you part of that strike force? 14 Going to Page 20 of the incident 14 A. No. 15 report, at some point did you gain information with 15 Q. Okay. What occurred with the Burglary 16 respect to Jet Aviation, and if so could you 16 Strike Force once you got involved with the case? 17 describe what information was obtained by Officer 17 MR. PIKE: Fonn. Actually I will withdraw 18 Pagan regarding Jet Aviation? 18 it. That question is fine. 19 MR. PIKE: Form. 19 THE WITNESS: The Burglary Strike Force 20 THE WITNESS: I believe it was a trash 20 had been conducting surveillance at the home of 21 pull where an itinerary was found within the 21 Mr. Epstein at 358 El Brill°. 22 trash pull. 22 BY MR. KUVIN: 23 BY MR KUVIN: 23 Q. Okay. Which officer was assigned to 24 Q. Were there additional names found within 24 monitor Mr. Epstein's home? 25 the itine of ilots? 25 A. Officer Mun an. 15 (Pages 54 to 57) PROSE COURT REPORTING AGENCY, INC. EFTA00298274 Page 58 Page 60 1 Q. Any others? 1 trash pull; is that correct? 2 A. Sergeant Sorge and Officer Minot. 2 A. Correct. .3 Q. Are they still with the department? 3 Q. Can you explain to us what that note was? 4 A Officer Munyan is no longer with the 4 MR. PIKE: Form. 5 department. Sergeant Sorge has since retired. And 5 BY MR. KUVIN: 6 Officer Minot is still with the police department. 6 Q. Just so I'm clear, you saw the note 7 Q. All right And what did the surveillance 7 yourself, correct? 8 find on that particular date? 8 A Yes. MR. PIKE: Form. 9 Q. Clay. Can you explain what it was? 10 THE WITNESS: I had asked them to input 10 A. This notes contained names of different girls 11 that into their report so there should be 11. with different times. 12 supplements by them as to what was, what they 12 MR. PIKE: Form, move to strike. 13 observed. 13 BY MR. KUVIN: 14 BY MR. KUVIN: 14 Q. If we go with the word "additionally," 15 Q. Well, if you look at the summary in the 15 halfway down the paragraph, do you see that where I 16 incident report, what is reported there? 16 am starting? 17 MR. PIKE: Form. 17 A. Yes. 18. THE WITNESS: They filled out an attached, 18 Q. It says "Additionally there was a — 19 a surveillance log which was a placed in the 19 A. "There was a note" and a redaction. 20 attachment file. 20 Q. Do you know who that redaction name is 21 MR. KUVIN: Okay. 21 referring to? As you sit here today can you recall? 22 THE WITNESS: Mr. Epstein had left for the 22 A. I can't recall. 23 airport on his jet which was over at, I 23 Q. All right. What did the note say? 24 "For a good time call," redaction, "and 24 25 believe, Jet Aviation. 25 A. Page 61 Page 59 1 BY MR. KUVIN: 1 Q. Okay. Why would that name be redacted - 2 Q. Okay. Was it determined during your part 2 MR. PIKE: Form. 3 of the investigation that the jet was, in fact, 3 MR. KUVIN: — if you know? 4 Mr. Epstein's jet? 4 THE WITNESS: It would have been the name 5 MR. PIKE: Form. 5 of a minor, victim. 6 THE WITNESS: Correct. 6 BY MR. KUVIN: 7 BY MR. ICUV1N: Q. Okay. If we go onto the next sentence, it 8 Q. All right. Lets get to your next report 8' says: "Also there was another telephone number on 9 which looks like Narrative 5 on Page 24. We come 9. note"; is that correct? 10 down the first paragraph. It looks like this is 10 MR- PIKE: Form. 11 documenting an additional trash pull that took 11 THE WITNESS: Yes. 12 place? 12 BY MR. KUVIN: 13 MR. PIKE Form. 13 Q. . And then there is a redaction, correct? 14 THE WITNESS: Correct. 14 A. Yes. 15 BY MR. KUVIN: 15 Q. Is that the redacted phone number of a 16 Q. Were you a part of the trash pull on 16 minor? Is that why it's redacted? 17 September 21 of 2005? 17 . MR. PIKE: Form. 18 A. No, I was not. 18 THE WITNESS: Yes. 19 Q. Who was? 19 BY MR. KUVIN: 20 A. Sergeant Szarszewski. 20 Q. Then it says: "Also found was a written 21 Q. All right. Did you review the evidence 21 note which stated," redaction, "cannot come at 22 that came out of this trash pull? 22 7:00 p.m. tomorrow because of soccer"? 23 A. Correct. 23 A. Correct. 24. Q. All right. Halfway down the paragyaph, 24 Q. You saw that note? 25 . there was a note that was apgarently pulled on this 25 A. Yes. 16 (Pages 58 to 61) PROSE COURT REPORTING AGENCY, INC: EFTA00298275 Page 62 Page 64 1 Q. And as you sit here today do you know or 1 stimulation. Do you see that? 2 do you recall who that person may have been, which 2 A. Correct 3 minor? 3 Q. I am trying to find out: This was a 4 MR. PIKE: Form. 4 broken piece of hard plastic. Was this what you 5 THE WITNESS: I believe it was Jane Doe 5 ultimately determined was the utensil or was this 6 No. 4, Jane Doe No. 4. 6 something different? 7 BY MR. KUVIN: 7 A. Yes, that was the utensil. They were 8 Q. Okay. Was she in high school at the time? 8 different colors. They were purple, white. I believe 9 A. Yes. 9 they were blue. 10 MR. ME: Form 10 Q. Okay. 11 BY MR. KUVIN: 11 A. But they all were shaped very similar. It was 12 Q. Playing soccer? 12 about that long. I wotdd say four to five inches long. 13 MR. PIKE: Form. 13 Q. Okay. 14 THE WITNESS: Yes. 14 A. And it had groves and had bumps along the way 15 BY MR. KUVIN: 15 with a rounded end and came beck around. 16 Q. Let's go the next thing that I wanted to 16 Q. Gotcha. 17 ask you about and clarify. GO to Page 16, if you 17 MR. PIKE: Form, move to strike. 18 would. 18 BY MR. KUVIN: 19 A. Actually if I can clarify my answer -- 19 Q. All right Let's go to the date of 20 Q. Sure. 20 10/7105 which is the next page, 27. This is 21 A. -- on that one. She might have graduated from 21 reported by you; is that correct? 22 high school already -- 22 A. Correct 23 Q. Okay. 23 Q. Can you describe for us what you did on 24 A. -- and started attending her university. 24 this particular date? 25 Q. Gotcha. 25 A. Ins contacted by Sergeant Frick. Page 63 Page 65 MR. PIKE: Form. For purposes of the 1 Mr. Epstein had been observed riding his bicycle along 2 record, you're pointing to Page 24 of Exhibit 2 South County Road which meant he was back in town. We 3 2, correct? 3 set up to interview 4 THE WITNESS: Correct. 4 Q. Okay. 5 BY MEL KUVIN: 5 A. We went out to her house, knocked on the door. 6 Q. And we're talking about Jane Doe No. 4? 6 She agreed to accompany us back to the police department 7 A. Yes. for Rather questioning. Q. Okay. Regardless was she still under the 8 Q. All right. 9 age of 18; is that why the name was redacted? 9 MR. PIKE: Move to strike. 10 MR. PIKE: Form. 10 BY MR. KUVIN: 11 MR. KUVIN: If you know. 11 1. go onto Page 28. Did you bring 12 THE WITNESS: I can't recall but -- 12 h4s. back to the department? 13 BY MR. KUVIN: 13 A. That's correct- 14 Q. Okay. Let's go to Page 26 fora moment 14 Q. Ms. at this time is how old? 15 It looks like there was an additional trash pull 15 A. I believe she was IS. 16 that was done on October 3rd, 2005; is that correct? 16 MR. PIKE: Form. 17 A. Yes. 17 BY MR. KUVIN: 18 Q. All right And in this particular trash 18 Q. Okay. And when you bring her back to the 19 pull, the next paragraph says: "Inside one of the 19 department, do you interview her? 20 white and color bags, I located a broken piece of 20 A. Yes,1 did. 21 hard plastic or clear acrylic stick which was shaped 21 Q. And what exactly does she explain to you 22 with small ridges." Do you see that? 22 during this— well, let me ask you this: At this 23 A. Correct. 23 point is she a suspect in a crime? 24 Q. This device is commonly used as a sexual 24 A. At this point she was a witness. 25 toy which is inserted into the vagina or anus for 25 Q. Okay. 17 (Pages 62 to 65) PROSE COURT REPORTING AGENCY, INC. EFTA00298276 Page 66 Page 68 1 A. As she was the one that brought the initial 1 MR PUCE: Form, move to strike. And for 2 victim to the house. 2 the record, Detective Recarey, you are still 3 Q. Initial victim being. 3 reading from Exhibit 2, correct? 4 5 A. Correct. MR. PIKE: Form, move to strike. 4 5 THE WITNESS: Some recollection, some off the report. I 6 BY MR. KUVIN: 6 MR. PIKE: The document is in front of 7 Q. So, at this point she's a witness to 7 you? 8 bringing that initial victim,■ to Mr. Epstein's 8 THE WITNESS: Yes, sir. 9 home; is that correct? 9 MR. PIKE: And that's what is refreshing 10 MR. PIKE: Form. 10 your recollection? 11 THE WITNESS: Correct. 11 MR KUVIN: Hey, l appreciate your 12 BY MR. KUVIN: 12 objection. Objection to the form works and 13 Q. So as such any need to read her her 13 then I will continue with my deposition and you 14 Miranda Rights at this point? 14 can cross him later. 15 MR. PIKE: Form. 15 MR. PIKE: That's not a, that's not a form 16 THE WITNESS: No. 16 objection. That's to make sure that the record 17 BY MR. KUVIN: 17 is clear as we go along that Detective Recarey 18 Q. And during the witness interview that you 18 is reading from Exhibit 2 which you previously 19 did with her, what did she describe to you occurred? 19 marked and I am going to continue to do it. 20 MR. PIKE: Form. 20 lam not going to interrupt your 21 THE WITNESS: During a sworn taped 21 deposition, but I am going continue to do 22 statement she explained how she met 22 it to insure that the record is clear that 23 Mr. Epstein; the time that she went to his 23 he is reading from the document that is in 24 house, she provided a massage for Mr. Epstein. 24 front of him. You can proceed. 25 25 Page 67 Page 69 1 BY MR. KUVIN: 1 BY MR. KUVIN: 2 Q. Now, at the time she told you she provided 2 Q. Detective Recarey, as you sit here today 3 a massage, how old was she? 3 do you have an independent recollection of that 4 MR. PIKE: Form. 4 initial interview with 5 THE WITNESS: I believe she stated she was 5 A. Yes, sir. 6 17. 6 Q. Do you recall whether she discussed 7 BY MR. KUVIN: 7 conversations with Mr. Epstein about bringing girls 8 Q. Okay. Let's go down ifyou would, third 8 to the home? 9 paragraph about the sixth line, seventh line from 9 A. Yes. 10 the bottom. It starts with the words "he 10 Q. She discussed that with you? 11 explained.' Do you see that? 11 A. Yes, she did. 12 A. Yes. 12 MR. PIKE: Form. 13 Q. During the interview did recount 13 BY MR. KUVIN: 14 any statements regarding Epstein and obtaining other 14 Q. All right. Are we talking now independent 15 girls? 15 from the incident report that we were referring to 16 A. Yes. 16 before? 17 MR. PIKE: Form. 17 A. Yes. 18 BY MR. KUVIN: 18 Q. And that independent recollection by 19 Q. What was explained? 19 looking at the incident report, does that help 20 A. She stated that Mr. Epstein explained that he 20 refresh your recollection? 21 knew she was not comfortable with providing the massage 21 A. Yes, it does. 22 but he would pay her to bring some girls, told her the 22 Q. All right. But that's not your entire 23 younger the better. explained that she brought a 23 recollection of the incident, is it? 24 23•year-old to perform a massage, and she was told that 24 A. No. 25 she was too old. 25 MR. PIKE: Fonn. earrexuatiseraa..... 18 (Pages 66 to 69) PROSE COURT REPORTING AGENCY, INC. EFTA00298277 Page 70 Page 72 1 BY MR. KUVIN: 1 explained it that she had brought additional women, and 2 Q. You are not just reading a report into the 2 she explained that she had received monies for bringing 3 record, are you? 3 these girls to the house, basically, yes, that she had 4 A. No, sir. 4 incriminated herself. 5 Q. Okay. You were there, right? 5 Q. With respect to potential crimes? 6 A. Correct. 6 A. Correct 7 Q. Sitting in the room with Ms. Mwhile 7 Q. At that point did you read her her rights, 8 she was talking to you? 8 her Miranda Rights? 9 A. Yes, I was. 9 A. At that point when we explained it to her, it 10 Q. Okay. What did Mr. tell you, if 10 was Sergeant Frick who is now a captain, she expressed 11 anything, about bringing young women to 11 her willingness to cooperate in hopes that in the, for a 12 Mr. Epstein's home? 12 lesser charge. 13 MR. PIKE: Form. 13 Q. Okay. So, she agreed voluntarily to 14 THE WITNESS: She brought a 22, 14 cooperate with the investigation? 15 23-year-old to the house to perform a massage 15 A. Comm. 16 end was told that the girl was too old, was 16 Q. And did she cooperate with the 17 told to bring girls; the younger the better. 17 investigation? 18 BY MR. KUVIN: 18 MR. PIKE: Form. 19 Q. Was there any age cutoff as far as how 19 THE WITNESS: When she got home and spoke 20 young; Inman 10, 11, 12, was that described? 20 with her family in regards to the interview, it 21 MR. PIKE: Form, move to strike. 21 was her family's determination and hers not to 22 THE WITNESS: She did not advise. 22 assist. 23 BY MR. KUVIN: 23 BY MR. KUVIN: 24 Q. Just the younger better? 24 Q. Do you 'mow why? 25 A. Younger the better. 25 MR. PIKE: Form. Page 71 Page 73 MR. PIKE: Form. 1 MR. KUVIN: If you know? 2 BY MR. KUVIN: 2 MR. PIKE: Form. 3 Q. And that was told to her by whom? 3 THE WITNESS: I lave no idea why. 4 MR. PIKE: Form. 4 BY MR. KUVIN: 5 THE WITNESS: Mr. Epstein. 5 Q. Just so I understand, initially she agreed 6 BY Iva KUVIN: 6 to cooperate. She then goes home, talks to family, 7 Q. And not a third party, but directly from 7 and then comes back and says she's not going to 8 Mr. Epstein? 8 cooperate; is that the sequence of events? 9 MR. PIKE: Form. 9 MR. PIKE: Form. 10 THE WITNESS: Correct 10 THE WITNESS: Correct. 11 BY MR. KUVIN: 11 BY MIL KUVIN: • 12 Q. Did you ask her which one was youngest? 12 Q. While you're taking her back home, is a 13 MR. PIKE: Form. 13 tape recorder surveillance placed into the police 14 THE WITNESS: I did ask her which one was 14 vehicle? 15 theyotma.- t. She claimed that the initial 15 A. Correct. 16 victim, would have been the youngest. 16 Q. And were you one of the ones that took her 17 BY MR. KUVIN: 17 home? 18 Q. She was how old? 18 A. Yes. 19 MR. PIKE: Fain. 19 Q. All right. What did she say during that 20 THE WITNESS: Fourteen. 20 drive home — 21 BY MR. KUVIN: 21 MR. PIKE: Form. 22 At some point during your interview with 22 BY MR. KUVIN: 23 Ms. ME did you determine that she might actually 23 Q. — as best you can recall? 24 be charged with a crime? 24 MR. PIKE: Same objection. 25 A. At the conclusion of the interview as she 25 THE. WITNFSS: She stated that she was like ,51 19 (Pages 70 to 73) PROSE COURT REPORTING AGENCY, INC. EFTA00298278 Page 74 Page 76 1 a Heidi Fleiss. At that point it was the madam 1 THE WITNESS: Correct 2 over in, I guess, in California 2 BY MR KUVIN: 3 MR. KUVIN: Okay. 3 Q. So, as best as you can recall, were there 4 THE WITNESS: that provided girls to 4 four people that she identified? 5 potential clients. 5 MR. PIKE: Form. 6 BY MR. KUVIN: 6 THE WITNESS: Yes. 7 Q. And the potential client in this case 7 BY MR. KUVIN: 8 would have been? 8 Q. And why would you reference the date of 9 A. Mr. Epstein. 9 birth? What is the importance of that? 10 Q. Okay. 10 A. Indicate their age. 11 MR. PIKE: Form and move to strike. 11 Q. Okay. And why would it be blacked out if 12 BY MR. KUVIN: 12 you know? 13 Q. All right. When was the first time that 13 MR. PIKE: Form. 14 you spoke with any other potential victims? 14 THE WITNESS: At that point they were 15 MR. PIKE: Form. 15 minors. 16 BY MR. KUVIN: 16 BY MR. KUVIN: 17 Q. So, now just so I can understand the 17 Q. Okay. If we turn to Page 31 of the 18 timeline, up to this int we have been discussing 18 incident report for a moment. This is the first 19 you knew a potential victim. You 19 reference I could see to a rental car company. So 20 talked to What is the next potential 20 let me ask you this: At some point did you learn 21 victim you learn about? 21 any information regarding the use of rental cars and 22 MR. PIKE: Form. 22 transporting girls or women to Mr. Epstein's home? 23 WITNESS: During the interview with 23 MR. PIKE: Form. 24 li Eshe explained, she gave us additional 24 THE WITNESS: Yes. 25 names of people that she brought to the house. 25 Page 75 Page 77 MR. KUVIN: Okay. 1 BY MR. KUVIN: 2 THE WITNESS: We identified some with her 2 Q. Tell us about that. 3 assistance of where they reside. 3 A. Dining the investigation it was determined MR. KUVIN: Okay. 4 that one of the girls had a rental car. THE S: That night after we dropped 5 Q. Do you remember which one? 6 off Ms. air her home, we began to attempt 6 A. From Dollar, Dollar Rent-A-Car. to contact some of these girls that have been 7 Q. Okay. Do you remember which girl? to his house. 8 A. I believe it was lane Doe No. 4. 9 BY MR. KUVIN: 9 Q. Okay. And did you determine how she 10 Q. All right. And just so we're clear, if 10 obtained the rental vehicle? 11 you turn back to Page 29 of your incident report in 13. MR. PIKE: Form. 12 the center of the page, once we get an unredacted 12 THE WITNESS: Records were subpoenaed to 13 copy we will know, but for reference sake, do you 13 Dollar to determine from the rental coritract, 14 see in the second paragra wn where it says: 14 and the rental car was being paid for by 15 "With the assistance of we were able to 15 Mr. Epstein. 16 identify.* Do you see that, and there is a whole 16 BY MR. KUVIN: 17 bunch of black? 17 Q. Okay. And at the time was lane Doe No. 4 18 A. Yes. 18 a minor? 19 Q. Okay. It appears, and correct me if I am 19 NIB. PIKE: Form. 20 wrong, that there is one name with a date of birth, 20 THE WITNESS: I believe at this time she 21 both blacked out; a second name with a date of birth 21 had started in the university, so I am not 22 blacked out; a third name with a date of birth 22 100 percent certain as to her age at that 23 blacked out; and a fourth name with the date of 23 particular moment. 24 birth blacked out? 24 BY MR. KUVIN: 25 MR. PIKE: Form, 25 Q. All right. Let's down to the bottom of Kg. 20 (Pages 74 to 77) PROSE COURT REPORTING AGENCY, INC. EFTA00298279 Page 78 Page 80 1 Page 31. At some point there is an additional trash •1 A. It's when it gets inputted. 2 pull done, and a U.S. Airways boarding pass is 2 Q. I hear you. If we go to next 3 obtained. Do you see that? 3 page, there is a preference to a ii. eWho is 4 A. Yes. 4 that? 5 Q. There is a name there Janusz Barrasiak? 5 MR. PIKE: Form. 6 A. Janusz, yes. 6 THE WITNESS: Not 100 percent certain. 7 Q. Did you determine who that individual was 7 BY MR. KUVIN: 8 at any point during the investigation? 8 Q. There is a reference to an MSN Hotmail 9 A. He was Mr. Epstein's houseman at the time. 9 record, 10 Q. Okay. And there is another person that's 10 @hormail.com. le Do you 11 listed there. Who else was listed on a note paper? 11 see that? 12 A. Oh, Ohislaine Maxwell. 12 A. Yes. 13 Q. Did you determine who she was? 13 Q. Did you determine whose e-mail address 14 MR. PIKE: Form. 14 that was during the investi 'on? 15 THE WITNESS: She's Mr. Epstein's friend. 15 A. That was 16 MR. PIKE: Form, move to strike. 16 Q. And who was she? 17 BY MR. KUVIN: 17 MR. PIKE: Form 18 Q. How did you determine that? 18 BY MR. KUVIN: 19 MR. PIKE: Form. 19 Q. if you know. 20 THE WITNESS: Through the media, online, 20 MR. PIKE: Same objection. 21 online resources. 21 THE WITNESS: I believe she was an 22 BY MR. KUVIN: 22 employee. 23 Q. All right. Let's go down now to Page 32, 23 MR. PIKE: Move to strike. 24 just so I can clarify this as well and find out what 24 BY MR. KUVIN: 25 this was. It says: "While sifting through Epstein's 25 Q. Was she a minor at the time, do you Imow? Page 79 Page 81 1 trash, I also collected a three-inch purple finger 1 MR. PIKE: Form. 2 size object which had a broken end. The object 2 THE WITNESS: I don't believe so. 3 appeared to be a broken piece from a sexual toy 3 BY MR. KUVIN: 4 similar to a Cyclone vibrator possibly used for 4 Q. Do you know how old she was? 5 rectum gratification." The evidence was placed in 5 MR. PIKE: Form. 6 bio-hazard bag with possible body fluids. 6 BY MR. KUVIN: 7 MR. PIKE:. Form. 7 Q. Did you ever determine how old she was? '8 BY MR. KUVIN: 8 MR. PIKE: Same objection. 9, Q. At any time did you determine what that THE WITNESS: She was identified but I 10 particular piece of evidence was, whether, in fact, 10 can't recall her age. 11 • it was a sexual toy? 11 BY MR. KUVIN: 12 A. I believe that that was the initial discovery 12 Q. All right. if we go to the next page, 13 of the purple handle. That was the initial discovery of 13 Page 34 references a phone contact you had on 14 it as this was, this is not chronological. 14 October 4 of 2005. Do you see that? 15 Q. This is going back, it looks if we go back 15 A. Yes. 16 up to the paragraph on April I of 2005? 16 Q. Do you recall who that was that called you 17 THE WITNESS: Correct. 17 back? 18 . MR. KUVIN: Gotcha 18 A. I could see her face. I am just trying to 19 MR. PIKE: Form. 19 think of her e. 20 ' BY MR. KUVIN: 20 Q. %sit 21 Q. This is what we were referring to before 21 A. No. It was not.. It was.III 22 in the beginning? 22 • MR. PIKE: Pm sorry. What page and 23 A. Yes. 23 reference are we reading from? 24 ' Q. Gotcha. it would help if you guys did 24 MR. KU VIN: Page 34, first paragraph. 25 this in chronological order. 25 21 (Pages 78 to 81) PROSE COURT REPORTING AGENCY, INC. EFTA00298280 Page 82 Page 84 1 BY MR. KUVIN: 1 believe the following morning I received a 2 . Q. Arawas under the age of 18 at the 2 telephone call from her stating that she was 3 time? 3 not being 100 percent truthful with me when I 4 MR. PIKE: Fonn. 4 first spoke with her. 5 THE WITNESS: Correct. 5 MR KUVIN: Okay. 6 BY MR. KUVIN: 6 THE WITNESS: And at which point she 7 Q. Do you know how old she was back on 7 described that she had been to Mr. Epstein's 8 October 4 of 2005? 8 home. 9 MR. PIKE: Form. 9 BY MR. KUVIN: 10 THE WITNESS: Ilatow she was still in high 10 Q. All right. When she described this to 11 school. I can't recall exactly her age. 11 you, mild you describe for us whether or not she 12 BY MR. KUVIN: 12 explained to you her mental state or her emotions 13 Q. Okay. Did she describe to you whether or 13 about this entire process? 14 not she was taken to Mr. Epstein's home? 14 MR. PUCE: Form. 15 MR. PIKE: Form. 15 THE WITNESS: From what lrecall I believe 16 THE WITNESS: Yes. 16 she was, she was crying. She was upset. 17 BY MR. KUVIN: 17 MR. PIKE: Form, move to strike, 18 Q. What did she describe occurred when she 18 nonresponsive. 19 went to his home? • 19 BY MR. KUVIN: 20 MR. PIKE: Form. 20 Q. Did she appear emotional during that 21 BY MR. KUVIN: 21 conversation you had with her? 22 Q. And just so we're clear, let me back up. 22 A. Yes. 23 Was she describing this to you? 23 Q. Did she appear upset about the incident 24 A. Correct. 24 that she was describing? 25 Q Okay. 25 MR. PIKE: Form. Page 83 Page 8F) 1 MR. PIKE: Form. Still hearsay. 1 THE WITNESS: Yes. 2 BY MR. KUVIN: 2 BY MR. KUVIN: 3 Q. And this conversation occurred between you 3 Q. Describe for us the details of what she 4 and her, yes? 4 told you as best you can recall. And then if you 5 A. Yes. 5 cannot recall the details, then let us know and 6 MR. PIKE: Form. .6 you're welcome to refresh your recollection with the 1 BY MR. KUVIN: 7 incident report. Q. During the investigation itself, correct? 8 MR. PIKE: Font 9 Mft. PIKE: Font 9 THE WITNESS: 1 recall she was taken to 10 THE WITNESS: Correct. 10 the home by trying W 11 BY MR. KUVIN: 11 remember exzWwit illiat ullbelieve 12 Q. Okay. At this poim this was a police 12 she was, she was the girl who was upset. She 13 investigation to determine whether or not there 13 was the one that got upset when either 14 should be charges brought against Mr. Epstein? 14 Mr. Epstein tried to touch her buttocks or her 15 A. Correct. 15 breasts. I can't recall. 16 MR. PIKE: Form. 16 MR. PIKE: Form, move to strike, 17 BY MR. KUVIN: 17 nonresponsive. 18. Q. Okay. All right. What did she describe? 18 MR. KUVIN: Okay. Why don't we do this: 19 MR. PUCE: Form. 19 Would it help toicficli your recollection by 20 THE WITNESS: Well, the initial 20 looking at the incident report? 21. conversation I had with her, she had advised 21 THE WITNESS: Yeah, it's been sane time. 22 that nothing had happened. I believe this is 22 MR. KUVIN: That's fine. Go ahead and 23 when Captain Frick and I went to her home. 23 take a look and refresh your recollection, if 24 MR. KUVIN: Okay. 24 you would, of the interview that you did with 25 THE WITNESS: It wasn't until, I think, I 25 her. 22 (Pages 82 to 85) PROSE COURT REPORTING AGENCY, INC. EFTA00298281 Page 86 Page 88 1 THE WITNESS: Yes. 1 massage I guess he tried to remove her shirt. 2 BY MR. KUVIN: 2 At this point she became upset and they had a 3 Q. Okay. Does the incident report help 3 verbal disaseement. She came back downstairs 4 refresh your recollection regarding your 4 and told = that she wanted to leave. 5 conversation with her? 5 MR. PIKE: Form, move to strike. 6 A. Yes. 6 BY MR. KUVIN: 7 Q. All right. Go ahead and if you would 7 Q. Did she tell you whether she ever returned 8 explain what she told you in this emotional phone 8 to the home? 9 call that she had. MR. PIKE: Same objections. 10 MR. PIKE: Form. 10 THE WITNESS: She did state that she came 13. THE WITNESS: That she was taken to the 11 back to the home a second time. She was 12 home of Jeffrey Epstein by She 12 wearing very tight jeans with a, with a tight 13 went up — she was taken upstairs. 13 belt. She was brought upstairs and I believe 14 BY MR. KUVIN: 14 Mr. Epstein tried to touch her buttocks. She 15 Q. Who was she taken upstairs by? 15 again told him that she did not want to be 16 A. M. While she was upstairs they showed her 16 touched and the massage was discontinued. 17 which lotions to use. 17 BY MR. KUVIN: 18 Q. La's be clear. Hang on a second. I want 18 Q. Now, was she emotional and crying during 19 to make sure that you take a look at Paragraph 2 19 the entire conversation she had with you? 20 there. 20 MR. PIKE: Form, and asked and answered. 21 A. By 21 THE WITNESS: Yes, she was. 22 Q. Okay. So takes her up? 22 BY MR. KUVIN: 23 MR. PIKE: Form 23 Q. Did you investigate to determine whether 24 THE WITNESS: Correct. 24 at the time of this incident that she reported to 25 25 you how old she was? Page 87 Page 89 1 BY MR. KUVIN: 1 MR. PIKE: Form. 2 Q. Just so we're clear before I have you go 2 THE WTINESS: 16 I believe. 3 further, this narrative that you wrote out here, was 3 BY MR. KUVIN: 4 it, when was it written out? 4 Q. How did you verify that? 5 A. October 7th. 5 A. She was still in high school. She was still 6 Q. Okay. Was it written out at or around the 6 attending Royal Palm Beach High School. time that she came and told you this information by 7 MR. PIKE: Form. 3 phone? 8 MR. KUVIN: Okay. Did you — 9 MR. PIKE: Form. 9 THE WITNESS: I located her date of birth. 10 THE WITNESS: Correct. 10 BY MR. KUVIN: 11 BY MR. KUVIN: 11 Q. How did you find the date of birth? How 3 12 Q. You recorded this down within days of this 12 do you verify dates of birth if somebody tells you? 13 phone call? 13 A. Ask the victim the date of birth and we go 14 MR. PIKE: Form. 14 back and confirm it through their driver's license. 15 THE WITNESS: Probably during the phone 15 Q. In other words you don't just take their 16 call, transcribed it onto a Word Document, 16 word for it. Just because they are in high school, 17 forwarded it to NicIde Altomaro to input it 17 you don't assume they are underage, do you? 18 into the system and the notes were destroyed. 18 A. No. 19 BY MR. KUVIN: 19 Q. All right. Did her recollection of the 20 Q. Ail right. Let's go on. So she tells you 20 incident at Mr. Epstein's home bear any similarities 21 that = takes her up to the room. What happened? 21 to the stories that you had heard told to you by 22 What does she tell you happened next? 22 -QM` 23 MR- PIKE: Form, move to strike. 23 MR. PIKE: Form. 24 THE WITNESS: She was shown which oil to 24 THE WITNESS: Yes, they had similarities. 25 be used. Mr. Epstein cameS in. Dt he ......„.., 25 23 (Pages 86 to 89) PROSE COURT REPORTING AGENCY, INC. EFTA00298282 Page 90 Page 92 BY MR. KUVIN: 1 turned over to the FBI? Q. All right. On the following Page 35 there 2 A. Yes. 3 is an additional girl you speak to. It looks like 3 Q. That was pursuant to — well, why don't you go out to a home and speak to someone in the 4 you tell us. Why, why was all of that turned over kitchen area, do you see that, and a sworn taped 5 to the FBI? Why was your entire investigative file o statement was taken? 6 given to them, if you know? 7 A. Yes. 7 MR. PIKE Form. 8 Q. Do you recall which girl this was? 8 THE WITNESS: They came with a grand jury 9 MR. PIKE: Form. 9 subpoena requesting all evidence, all working 10 THE WITNESS: I can see her face but I'm 10 files, all any notes, any, anything 11. trying to recall her name. I want to say• 11 pertaining to the investigation 12 BY MR. KUVIN: 12 BY MR. KUVIN: 13 Q. Uncertain though without seeing the 13 Q. And that would have included all the audio 14 redacted, =redacted, I should say, copy? 14 taped statements that you took? 15 A. I believe it waal She was the one that I, 15 A. Correct. 16 I went to visit her at her house. She had guests, so we 16 Q. All right. And I am sorry, I forgot the 17 went into the kitchen area to talk. 17 name again of this girl that you talked to in the 18 Q. Okay. This statement that you took from 18 kitchen. 19 her was recorded? 19 A. J.L. 20 A. Yes. They are all taped statements. 20 Q. IL, what did she tell you occurred? 21 Q. And she agreed to that statement to be 21 MR. PIKE: Form. 22 taken? 22 THE WITNESS: That he was taken to the 23 A. Correct. 23 home of Mr. Epstein by She was 24 Q. Okay. Do you recall how many taped 24 brought upstairs by an employee of the house. 25 statements you took of girls? 25 I can't recall if she identified who that Page 91 Page 93 1 MR. PIKE: Form. 1 person was, but she was shown which oil to use. 2 THE WITNESS: Several. It was, it was 2 BY MIL KUVIN: 3 quite a bit 3 Q. Much hie the other girls? 4 BY MR. KUVIN: 4 MR. PIKE: Form, move to strike. 5 Q. More than five? 5 MR. KUVIN: Okay. Go ahead. 6 A. Yes. 6 MR. PUCE: What question are we on now? 7 Q. More than ten? 7 MR. KUVIN: Describing what she told him. 8 MR. PIKE: Form — 8 MR. PIKE: Okay. Form. 9 THE WITNESS: Yes. 9 THE WITNESS: She went upstairs, provided 10 MR. PIKE: to five and ten. 10 the massage. 11 BY MR. KUVIN: 11 BY MR. KUVIN: 12 Q. Did you take more than 20? 12 Q. Was she asked to remove her clothes? 13 MR. PIKE: Form. 13 MR. PIKE: Form. 14 MR. KUVIN: Just trying to get an idea of 14 BY MR. KUVIN: 15 how many taped statements might exist. 15 Q. Did she tell you whether she was asked to 16 MR. PIKE: Form. 16 remove her clothes? 17 THE WITNESS: 1 believe more than 20. 17 MR. PIKE: Form. 18 BY MR. KUVIN: 18 THE WITNESS: I can't recall. 19 Q. Now, is that more than 20 different girls? 19 BY MR. KUVIN: 20 MR. PIKE: Form. 20 Q. If we look at Page 35 about halfway down, 21 THE WITNESS: Not only girls. Like 21 the beginning of the line is a blacked out word, and 22 previous employees, people that have worked at 22 it says "feather stated." Do you see that? 23 Mr. Epstein's home. 23 A. Yes. 24 BY MR KUVIN: 24 Q. All right. Does that help refresh your 25 Q. kll±fnjt a ......_, dstatementsultimatel were 25 recollection with respect to -- 24 (Pages 9O to 93) PROSE COURT REPORTING AGENCY, INC. EFTA00298283 Page 94 Page 96 1 A. Yes. 1 BY MR KUVIN: 2 Q. -- what she described? 2 Q. What was her demeanor during this 3 MR. PIKE Form. 3 conversation? 4 TILE WITNESS: Mr. Epstein came into the 4 MR. PIKE: Form. 5 room and asked her to remove her clothing. 5 BY MR. KUVIN: 6 BY MR ICUVIN: 6 Q. I mean, was she calm, cool, collected, was 7 Q. And she was how old at this time? 7 she upset? I mean describe for us if you would her B MR. PIKE: Form. 8 demeanor. 9 THE WITNESS: Sixteen, I believe. 9 MR PUCE: Form. 10 Sixteen, 17. 10 THE WITNESS: rm trying to recall. I 11 BY MR. KUVIN: 11 think she was upset. 12 Q. All right. And did she give him, did she 12 MR. KUVIN: Okay. 13 describe whether or not she gave him a massage? 13 MR. PIKE: Thank you. 14 MR. PIKE: Form. 14 BY MR. KUVIN: 15 THE WITNESS: Yes, she did. I remember 15 Q. Did Mr. Epstein give her money at the 16 she provided the massage. 16 conclusion of this event? 17 BY MR. KUVIN: 17 MR. PIKE: Form. 18 Q. Was she partially naked, top ofher 18 THE WITNESS: Yes. 19 clothing was off at the time exposing her breasts? 19 BY MR. KUVIN: 20 MR. PIKE: Form. 20 Q. Does she describe to you whether or not 21 THE WITNESS: I believe so. 21 Mr. Epstein ejaculated during the massage? 22 BY MR. KUVIN: 22 MR. PIKE: Fonn. 23 Q. All right. During the incident with her, 23 THE WITNESS: Yes, he did. I believe he 24 did she discuss whether or not a large white 24 did. 25 vibrator was used at all? 25 Page 95 Page 97 1 MR. PIKE: Form. BY MR. KUVIN: 2 THE WITNESS: Yes, I do recall it was a 2 Q. Now, at the end of the page I notice you 3 large, large massage, massager, slash, vibrator 3 have a note there regarding her description of her 4 used 4 emotional state. What did she describe to you, if 5 MR. PIKE: Move to strike, leading. 5 anything, regarding how she felt about this incident 6 BY MR.1CU'VIN: 6 occurring? 7 Q. Did she describe whether or not it was 7 A. If I can refresh — 8 used on her? 8 MR. PIKE: Form 9 MR. PIKE: Form. 9 MR.1CUVIN: Please do. 10 THE WITNESS: Yes, she did. She did 10 THE WITNESS: Thanks. 11 recall. She did state it. 11 MR. PIKE: And for the record, the witness 12 BY MR. KUVIN: 12 is refreshing his recollection withExhibit 2. 13 Q. How did she describe it being used on her? 13 THE WITNESS: Okay. That she was ashamed 14 MR. PIKE: Form. 14 and embarrassed about the situation. 15 THE WITNESS: Rubbed on her vaginal area. 15 MR. KUVIN: Okay. 16 BY MR. KINN: 16 MR. PIKE: Is this a good time to take 17 Q. And who was holding it at the time? Did 17 break? 18 she explain that? 18' MR. KUVIN: Sure. All right. It's 11:30 19 A. Mr. Epstein. 19 well take a five-minute break 20 MR. PIKE: Form. 20 (A briefrecess was held and Ms. 21 BY MR KUVIN: 21 Finnigan entered the deposition room and 22 Q. Now, this conversation you had with her 22 Mr. Garcia left the deposition room. 23 occurred in the kitchen area ofher home? 23 BY MR. KUVIN: 24 THE WITNESS: Yes. 24 Q. Okay. All right. Let's go to Page 37 in 25 MR. PIKE: Form. 25 Narrative 10 for a moment. It looks like, correct 25 (Pages 94 to 97) PROSE COURT REPORTING AGENCY, INC. EFTA00298284 Page 98 Page 100 1 me if I'm wrong, that on this particular date, 1 BY MR. KUVIN: 2 October 6th, 2005 well, you tell me. What did 2 Q. All right. Let's move to Page 39 if we 3 you do on that date? 3 could. On October 10, 2005, you made telephone 4 A. That was the date back then when Detective 4 contact with someone. Do you recall who that was? 5 Dawson and I went to down to speak to Jane Doe No. 4. 5 A. Yes, I do. 6 Q. Jane — 6 Q. Okay. And which person was this? 7 A. Doe No.4. 7 A. I believe this was Jane Doe No. 103 8 Q. Okay. And where did you have to go? 8 Q. Okay. And if we go through this 9 A. To the university she was attending. 9 particular phone call, I believe you actually 10 Q. Okay. When you went there did you get a 10 document in this phone call her emotional state. If 11 chance to meet with her? 11 we look at Paragraph 2, five lines up from the 12 A. Yes, I believe so. 12 bottom. 13 MR. PIKE: Form. 13 (Mr. Goldberger entered the 14 BY MR. KUVIN: 14 deposition room.) 15 Q. MI right. And what was her demeanor when 15 BY MR. KUVIN: 16 you met with her on this particular occasion? 16 Q. What did you document as Ms. Jane Doe No. 17 MR. PIKE: Form. 17 103's emotional state was during this conversation 18 THE WITNESS: I can't recall her exact 18 you had with her? 19 demeanor. 19 MR. PIKE: Form. . 20 BY MR. KUVIN: 20 THE WITNESS: She was crying hysterically 21 Q. Do you recall whether this conversation 21 and very upset as she was discussing the 22 was taped? Was this a taped statement? 22 incidents. 23 A. I am trying to remember. I believe it was. 23 BY MR- KUVIN: 24 Q. Okay. And during this particular 24 Q. Okay. And as she's crying discussing 25 interview, did she describe to you what she thought 25 these incidents, does she describe to you how many Page 99 Page 101 1 of Mr. Epstein? 1 times these had occurred? 2 MR. PIKE: Form. 2 MR. PIKE: Font 3 MR. KUVIN: And if you can't recall, 3 MR. KUVIN: And if you need the report to 4 you're welcome to refresh your recollection. 4 help refresh your recollection, you're welcome 5 Just let us know that you need to refresh your 5 come to use that. Just let us know that you're 6 recollection and utilize the report. 6 using it for that purpose. 7 THE WITNESS: I'm going have to look at 7 THE WITNESS: I know it was numerous times 8 the report because it was some time ago. 8 over a two-year period. 9 MR. KUVIN: Okay. Take a look at the 9 MR. PIKE: Mow to strike. 10 report, the bottom of the page, last line. 10 BY MR. KUVIN: 11 MR. PIKE: Are we still on Page 35? 11 Q. If you look at the ixmort afler the 12 MR. KUVIN: Thirty-seven. 12 section that says "Ms. Jane Doe No. 103 began crying 13 BY MR. KUVIN: 13 on the telephone," do you see that line? 14 Q. How did she describe Mr. Epstein? 14 MR. PIKE: Form. 15 MR. PIKE: Form. 15 THE WITNESS: Yes. 16 THE WITNESS: She was uncomfortable. She 16 BY MR. KUVIN: 17 considered Jeff a pervert who kept pushing to 17 Q. How nntny times do you document that she 18 go further and further. 18 tells you she had been there over a two-year period? 19 BY MR. KUVIN: 19 MR. PIKE: Form. 20 Q. And if we look at Page 38, bottom of the 20 THE WITNESS: Hundreds of times. 21 first paragraph, last line, during the incidents 21 BY MR. KUVIN: 22 that she described to you with Mr. Epstein, how old 22 Q. Do you make this report, do you write out 23 was she? 23 this report at or around the time the phone call 24 A. Sixteen. 24 occurred? 25 MR. PIKE: Form move to strike. 25 A. Correct. 26 (Pages 98 to 101) PROSE COURT REPORTING AGENCY, INC. EFTA00298285 Page 102 Page 104 1 Q. Contemporaneous, essentially, as you're 1 first, and I want to go through in here. If we look 2 taking notes? 2 at the last paragraph on Page 39, it says, and I am 3 A. Correct. 3 assuming this is referring to Ms. Jane Doe No. 103 4 Q. You type it up soon thereafter? 4 "became more upset, crying hysterically." 5 A. Correct. 5 Do you see that last paragraph? 6 Q. Is she, at the time these incidents 6 A. Yes. 7 occurred, does she express to you whether she was 7 Q. Okay. So, during this phone call you're 8 under the age of 18? 8 having with her, she's actually crying hysterically 9 MR. PIKE: Form. 9 on the phone to you? 10 THE WITNESS: Yes. 10 MR. PACE: Form. 11 BY MR. KUVIN: 11 THE WITNESS: Yes. 12 Q. How old do you determine that she was 12 BY MR. KUVIN: 13 during the incidents that she describes? 13 Q. And you documented that at the time that 14 MR. PIKE: Fonn. 14 you had the phone call with her? 15 THE WITNESS: Sixteen years old. 15 A. Yes, I did. Asa matter of fact it was 16 BY MR. KUVIN: 16 recorded. 17 Q. And at the time that she's 16 year old, 17 Q. Okay. 18 was she able to recount to you what Mr. Epstein's 18 MR. PIKE: Form. 19 penis looked like? 19 THE WITNESS: It was a recorded telephone 20 MR. PIKE: Form. 20 cat 21 THE WITNESS: Yes, she did. 21 MR. PIKE: Form to the last question. 22 BY MR KUVIN: 22 BY MR. KUVIN: 23 Q. How did she describe it? 23 Q. When this phone call occurred with 24 MR. PIKE: Form. 24 Ms. Jane Doe No. 103, what was her, just so we're 25 THE WITNESS: I believe she recalled it as 25 clear, what was her emotional state? Page 103 Page 105 1 an egg-shaped penis. 1 MR. PIKE: Form, speculation. 2 BY MR. KUVIN: 2 THE WITNESS: She was crying hysterically. 3 Q. All right. I want to make sure that we're 3 And I recall having to give her time to regain 4 talking about the correct girl here. If we look at 4 her composure to continue the conversation. 5 the report on October 10, 2005, does she describe 5 BY MR. KUVIN: 6 whether or not it is circumcised? 6 . Q. And does she describe additional sexual MR. PIKE: Form. 7 acts that she engaged in with Mr. Epstein other than THE WITNESS: Yes, she does. 8 naked massages? 9 BY MR. KUVIN: 9 MR. PIKE: Form. 10 Q. Okay. And did she understand what that 10 THE : es. She described having a 11 meant to be circumcised or not circumcised? 11 relationship with -. I believe 12 MR. PIKE: Form. 12 she described at one time, I believe, she had 13 THE WITNESS: Correct. 13 sex with Mr. Epstein onetime. 14 BY MR. KUVIN: 14 BY MR. KUVIN: 15 Q. Does Ms. lane Doe No. 103 also describe 15 Q. All right. Let's do this: I want you to 16 any additional sexual acts other than naked massages 16 take a look at this lasfparagraph on Page 39 for a 17 for Mr. Epstein that she engaged in? 17 second and see if that helps refresh your 18 MR. PUCE: Form. 18 recollection. And then I would like to ask you a 19 THE WITNESS: Yes, she did. During my 19 couple of questions about the phone call in 20 interview with her, that was actually — there 20 particular. 21 was one on the telephone, and I agreed to meet 21 A. Okay. 22 with her to speak with her personally to get a 22 Q. All right. During this part of the phone 23 more in-depth interview with her. 23 call, is she still, is she still emotional with you? 24 BY MR. KUVIN: 24 MR. PIKE: Form. 25 Q. Let's talk about just this phone call 25. THE WITNESS: Yes, very. 27 (Pages 102 to 105) PROSE COURT REPORTING AGENCY, INC. EFTA00298286 Page 106 Page 108 1 BY MR. KUVIN: 1 Jacksonville tape recorded? 2 ' Q. Okay. And what does she describe occurs 2 A. Yes. 3 between her, Ms. Mr. Epstein, if 3 Q. Okay. So one of the tapes that is 4 anything? 4 currently in the possession of the FBI would include 5 MR. PIKE: Form. 5 that interview? 6 THE WITNESS: It was oral sex performed on 6 A. Correct. 7 her. There was strap-on penises utilized. 7 Q. Okay. Was she still emotional during the 8 Them was other scaml toys being used, a 8 interview in Jacksonville -- 9 vibrator. 9 MR. PIKE: Objection. 10 BY MR. KUVIN: 10 BY MR. KUVIN: 11 Q. Does she describe whether or not 11 Q. — about the incidents that occurred? 12 Mr. Epstein actually puts his fingers inside of her 12 A. At times she would get emotional and start to 13 vagina or not? 13 cry. 14 A. Yes, 14 Q. Okay. If we go down to Page 40 in your 15 MR. PIKE: Form. 15 report — first let me back up. When you meet with 16 BY MR. WAN: 16 her, do you take notes? 17 Q. What does she stale about that? 17 A. Yes. 18 MR PIKE: Font. 18 Q. And do you record those notes into the 19 THE WITNESS: That Mr. Epstein inserted 19 report itself in a timely manner? 20 his fingers in her vagina in an attempt to make 20 A. Yes. 21 her climax as she was masturbating him. 21 Q. If we look at the bottom of Page 40, does 22 BY MR. KUVIN: 22 to you anything with respect to 23 Q. All of this while she was how old? 23 and how Epstein and her may have met? 24 A. Sixteen. 24 MR PIKE: Form. 25 Q. All right. At some point you have to stop 25 THE WITNESS: She claimed that Epstein had Page 107 Page 109 1 the phone call; is that correct? 1 isp urchas from her family in 2 A. Correct. 2 3 Q. NAY? 3 BY MR. KUVIN: 4 A. She was unable to maintain her composure to 4 Q. Okay. /knight. Lees tum to Page 41. 5 talk to me. 5 Now, she recounts to you, or does she recount to you 6 Q. Did you make arrangements to meet with 6 whether she has actually seen Mr. Epstein's penis? 7 her? 7 MR. PIKE: Form. 3 A. Correct. 8 THE WITNESS: Yes, she did. 9 Q. You then meet up with her? 9 BY MR. KUVIN: 10 A. Correct. 10 Q. So, she tells you that she saw it? 11 Q. Where do you meet her? 11 A. Correct. 12 A. At a park in Jacksonville. 12 MR. PIKE: Form. 13 Q. Is she with someone at the time? 13 BY MR. KUVIN: 14 A. Yes. 14 Q. Did she see it once or numerous times? 15 Q. Who was she with? 15 THE WITNESS: Numerous times. 16 A. She was with a female friend. 16 MR. PIKE: Form. 17 Q. Does she describe for you her history with 17 BY MR. KUVIN: 18 Mr. Epstein? 18 Q. All right. And when she's discussing this 19 • MR. PIKE: Form. 19 with you, is she also, is she in an emotional state, 20 THE WITNESS: Yes. 20 upset, distraught about it at all? 21 22 23 si BY MR. KUVIN: itashe talk to you at all about when you met with her in person? 21 22 23 MR. PIKE: Form. THE WITNESS: Like I said, during the interview as we were getting more and more 24 A. Yes, she did. 24 information, she would get upset. We would 25 Q. Okay. And was thytpart!friar meefintin 25 gr. Allowed her to regain her con:i===,mc emld ,„ 28 (Pages 106 to 109) PROSE COURT REPORTING AGENCY, INC. EFTA00298287 Page 110 Page 112 1 we would continue. 1 BY hat. KUVIN: 2 BY MR. KUVIN: 2 Q. — any lawful reason why you could think 3 Q. All right. If we look at Page 41, you 3 of why a 16-year-old girl could desaibe 4 have there in the second paragraph an explanation of 4 Mr. Epstein's penis? 5 her description of Mr. Epstein's penis; is that 5 MR. PIKE: Form. 6 correct? 6 THE WITNESS: No. 7 THE WITNESS: Correct. 7 BY MR. KUVIN: 8 BY MR. KUVIN: 8 Q. Did Ms. ane Ike No. 103 describe whether 9 Q. And at the time that this was occurring, 9 or not she had an on in sexual relationship with 10 how old was she? 10 Mr. Epstein and Nie. at 11 MR. PUCE: Form. 11 A. Yes, she did. She Mated that — 12 THE WITNESS: Sixteen. 12 MR. PIKE: Form. 13 BY MB. KUVIN: 13 THE WITNESS: She stated that when she 14 Q. And could you tell us how she described 14 would come over, there was, she would have 15 Mr. Epstein's penis at the time? 15 either mla6ms with or — and at one 16 MR. PIKE: Form. 16 point she even stated there were some 17 THE WITNESS: She claimed that it was 17 photographs taken of her in the tub with 18 deformed. She called it egg-shaped. 18 MR. PIKE: Form. 19 BY MR. KUVIN: 19 BY MR. KUVIN: 20 Q. What description did she actually use? 20 Q. Did you ever recover those photographs? 21 MR. PIKE: Form, asked and answered. 21 A. No. 22 THE WITNESS: It was oval in shape. 22 MR. PIKE: Form, mmm to strike the 23 BY MR. KUVIN: 23 previous response. 24 Q. All right. If we look here, you have 24 MS. MIL: Mr. Kuvin, nnise me. I was 25 recorded exactly — well, let me ask you this: Did 25 trying to object to the form of the previous Page 111 Page 113 1 you record exactly what she had told you dicing the 1 question about how a I6-year-old girl would 2 interview? 2 know how to describe the penis. And I think my 3 A. Yes, I did. 3 phone was muted at the time. 4 Q. All right. If we look at Page 41, she 4 MR. KUVIN: It was, but thank you. 5 claimed when Mr. Epstein's penis was erect, it was 5 MS. B7MTI : That If I could just have 6 thick towards the bottom but was thin and small 6 that recorded. 7 toward the head portion. Do you see that? 7 MR. KUVIN: Sure. 8 MR. PIKE: Form, leading. 8 BY MR. KUVIN: 9 THE WITNESS: Yes. 9 Q. All right. If we look at your report on 10 BY MR. KUVIN: 10 Page 41. It appears that Ms. Jane Doe No. 103 11 Q. All right. Is that what she described to 11 describes an incident that occurred in the massage 12 you? 12 room. 13 A. Yes. 13 Do you see that, second paragraph 14 MR. PIKE: Form. 14 from the bottom? 15 BY MR. KUVIN: 15 MR. PIKE: Form, leadirkg. 16 Q. Were you the one that used the term 16 THE WITNESS: Yes. 17 egg-shaped. 17 BY MR. KUVIN: 18 MR. PIKE: Form. 18 Q. All right. Why don't you for a second, 19 THE WITNESS: No, she used egg-shaped. 19 read the second paragraph from the bottom, and then 20 BY MR. KUVIN: 20 I have a couple of questions to ask you about it. 21 Q. Okay. Any reason that you could think of 21 Go ahead. Just read the whole paragraph. I just 22 at the time of this interview why a 16-year-old girl 22 want to make sure and then I'm going to ask you 23 would know how to describe Mr. Epstein's penis — 23 about it. 24 MR. PIKE: Form, confusing. 24 A. Can I use her name? 25 THE WITNESS: No. 25 Q. No, no. I want ou to 'ust read the 29 (Pages 110 to 113) PROSE COURT REPORTING AGENCY, INC. EFTA00298288 Page 114 Page 116 1 second paragraph from the bottom. 1 BY MR. KUVIN: 2 A. I know, but do you want to me to use her name 2 Q. And she said no? 3 or use the redacted portions of it? 3 MR. PIKE: Hold on a second. The witness 4 Q. Yes. We're discussing Ms. Jane Doe No. 4 is answering the question. So if you would, 5 103 at this point. 5 rather than lead the witness through his answer 6 A. "Jane Doe No. 103 advised one day, Jane Doe 6 so he can answer the way that you would like, 7 No. 103 was unable to state the exact date this incident 7 would you please ensure that the witness is 8 occurred.' e finished with his answer before you follow 9 Q. I'm sorry. Read it to yourself and I will 9 through with the next question. 10 just ask you questions. 10 BY MR. KUVIN: 11 A. Okay. 11 Q. Did she explain whether or not she said 12 Q. Sorry about that. Okay. Did Ms. Jane Doe 12 no? 13 No. 103 describe to you an incident that occurred in 13 MR. PIKE: Form. 14 the massage room at Mr. Epstein's home? 14 THE WITNESS: Yes, she did. 15 A. Yes. 15 BY MR. KUVIN: 16 MR. PIKE: Form. 16 Q. And she said no? 17 BY MR. KUVIN: 17 A. Yes. 18 Q. And what did she describe to you with 18 MR. PIKE: Form. 19 respect to Epstein and her and any contact that he 19 BY MR. KUVIN: 20 may have had with her? 20 Q. Okay. And what did he do when she said 21 MR. PIKE: Form. 21 that? 22 THE WITNESS: She stated that she had gone 22 MR. PIKE: Form. 23 up to the bedroom and that both and 23 THE WITNESS: He apologized to her and she 24 Epstein were in the bedroom. They were already 24 stated that she had received 51,000 for that 25 naked. She had removed her clothing. That 25 visit. Page 115 Page 117 1 was an appointed time when her and began 1 BY MR. KUVIN: 2 kissing, touching on the massage table. She 2 Q. Did she say whether or not as a result of 3 stated that she had achieved climax. 3 the incident she was injured in any war! 4 All the while this was occurring 4 MR. PIKE: Form. 5 Mr. Epstein was masturbatingg. At one 5 THE WITNESS: I can't recall if - I know 6 point Mr. Epstein put her onto the massage 6 that during our conversations, during her 7 table and inserted his penis into her 7 visits going to the house and during the 8 vagina. different acts that occurred while she was at 9 BY MR. KUVIN: 9 the house, she claimed that she had left very 10 Q. Did she say whether or not this was 10 sore, but I don't recall her saying anything as 11 consensual or not? 11 to that particular incident 12 MR. PIKE: Form. 12 BY MR. KUVIN: 13 THE WITNESS: This was not consensual. 13 Q. All tight If we tum to the next page, 14 BY MR. KUVIN: 14 Page 42, Narrative 12, this narrative is reported by 15 Q. And what did she say occurred happened at 15 you? 16 that point? 16 A. Yes. 17 MR. PIKE: Form. 17 Q. All right. As a result of the interviews 18 THE WITNESS: She said this occurred for 18 that you bad done in the investigation up until this 19 very quick He removed himself from her 19 point, did you request a search warrant for the 20 nem 20 home? 21 BY MR. KUVIN: 21 A. Yes, I did. 22 Q. Did she say whether or not she told him 22 Q. And was a search warrant actually signed 23 no? 23 by the judge? 24 A. Yes. 24 A. Yes. 25 MR. PIKE: Form, move to strike. 25 Q. When was that warrant executed on the 30 (Pages 114 to 117) PROSE COURT REPORTING AGENCY, INC. EFTA00298289 Page 118 Page 120 1 home? 1 THE WITNESS: The CPU's were removed. The 2 A. Sometime in October. 2 CPU's being the computers. The towers were 3 Q. All right If we look at Page 42, it 3 removed. The wires were just left. The 4 says: "on October 18, 2005,1 met with Judge Laura 4 cabinet in which they claimed all the oils were 5 Johnson who signed the warrant" And then on 5 being kept were, was empty except for one 6 October 20, 2005, at approximatly 9:36 a.m., members 6 bottle that was way in the back The drawer in 7 of the police department investigation unit nee' lied 7 the bedroom where they claimed all the toys B the warrant? 8 were was empty. That's what I meant by -- 9 A. Correct. 9 MR. KUVIN: Sanitized? 10 Q. Is that in and about the time the warrant 10 THE WITNESS: (Witness nods head.) 11 was executed? 11 BY MR. KUVIN: 12 A. That's correct. 12 Q. Okay. During the inspection that you did 13 Q And this warrant, the execution of this 13 or the warrant, execution of the warrant, did you 14 warrant was videotaped? 14 determine whether or not there were any internal 15 A. The — it's our policy when the search warrant 15 security cameras in the borne? 16 is executed, we do entry/exit videos. 16 A. Yes, there were. 17 Q. Okay. That's what you did in this case? 17 MR. PIKE: Fonn. 18 A. Yes. 18 BY MR. KUVIN: 19 Q And you kept those videos at the 19 Q. And do you recall whether there were any 20 departMent? 20 located based on your inspection in the upstairs 21 A. Yes. 21 area of the home? 22 Q. They we a part of the investigation? 22 MR. PIKE: Fenn. 23 A. Yes, sir. 23 THE WITNESS: Not in the upstairs area. 24 Q. And the videos were taken, were they taken 24 There was a covert clock in the downstairs 25 by personnel working for the department? 25 office area and there was another covert clock Page 119 Page 121 A. Yes. 1 on the wall in the garage. 2 Q. All right. And you were present? 2 BY MR. KUVIN: A. Yes. 3 Q Okay. The one in the garage, what was it Q. Tell us, if you would, how you found the 4 pointing at? In other words what was it attempting 5 state of the home when you arrived on that date for 5 to see from that direction? 6 the inspection? 6 MR. PIKE: Form. MR. PIKE: Form. 7 THE WITNESS: I believe it was, it was the • MR. KUVIN: Or for the execution of the 8 overview of the vehicles kept in the garage, 9 warrant, excuse me. 9 bicycles, motorcycle, cars, garage doors, so... 10 THE WITNESS: It was determined, obviously 10 BY MR. KUVIN: 11 when we were in the house, that the house was 11 Q Okay. And the one in the office was 12 somewhat sanitized. 12 pointed at what? 13 MR. PIKE: Form. 13 MR. PIKE: Palm. 14 , MR. KUVIN: Describe what you mean. 14 THE WITNESS: The desk living room area. 15 • I think we just got disconnected. 15 BY MR. KUVIN: 16 • Ms. Ezell. 16 Q. Okay. Any other cameras that you can 17 (A brief recess was held.) 17 recall finding during the execution of the warrant, 18 MR. KUVIN: We lost you, Kathy. 18 either covert or overt? 19 MS. EMI • Sony. Lost you fora minute. 19 MR. ME: Form. 20 BY MR KUVIN: 20 THE WITNESS: Not that I can recall. 21 Q All right. You mentioned before we took a 21 BY MR. ICUVIN: 22 quick break there that you felt that the house was, 22 Q. Okay. And did you come to learn or 23 or you determined that the house was somewhat 23 discover any information about whether Mr. Epstein 24 sanitized. Can you describe what you mean by that? 24 may have been tipped off as to the execution of this 25 MR. PIKE: Form. 25 warrant? 31 (Pages 118 to 121) PROSE COURT REPORTING AGENCY, INC. EFTA00298290 Page 122 Page 124 1 WIPIKE:Fonn. 1 MR. PIKE: How much longer do you have? 2 THE WITNESS: i 'mow that some of the 2 MR. KUVIN: I have no idea. i have no 3 girls had maintained contact with IMIM. 3 idea 4 There was a couple of girls that stated that 4 But the question that's pending that 5 was calling to find out the status 5 I wanted an explanation or which you 6 or questions asked by us, the police 6 haven't explained is how long did it take 7 department. 7 you to execute this search warrant. 8 BY MR. KUVIN: 8 MR. PIKE: Form. 9 Q. This all occurred prior to the warrant? 9 MR. KUVIN: And the form would be? 10 MR. PIKE: Form. 10 MR PIKE: How long did it take to 11 THE WITNESS: Yes. 11 execute: What search warrant? When? When? 12 . MR. PIKE: Move to strike. 12 What time? Him? His officers? What 13 BY MR. KUVIN: 13 detective? I don'ticnow. Shall I go on? 14 Q. And by the titre you left the property was 14. MR. KUVIN: Actually, yeah, because it's 15 an attorney, did an attorney arrive? 15 kind of comical, but I will clarify because you 16 A. Yes. As we were leaving securing the 16 don't understand. 17 residence, a Guy Fronstin walked up onto the property. 17 BY MR. KUVIN: 18 Q. Okay. How long did the execution of this 18 Q. Detective Recarey, how long were you on 19 warrant take, roughly? 19 Mr. Epstein's property that day? 20 MR. PIKE: Form. 20 MR. PIKE: Form, predicate. You have 21 MR. KUVIN: What is wrong with that 21 actually even — here, let me help you out a 22 question? 22 bit. You have actually failed to lay the 23 MR. PIKE: It is depending on the 23 appropriate predicate and foundation that he 24 investigation. You're tip-toeing into a lot of 24 was the one that executed the search warrant or 25 hearsay testimony with these questions. I 25 whether it was his team that executed the Page 123 Page 125 1 don't know where it's corning from. You have 1 search warrant, so... 2 asked several questions here about- 2 BY MR. KUVIN: 3 MR. KUVIN: The outstanding question is 3 Q. Detective Recarey, did you go to 4 MR. PIKE: Wait, wait, wait one second. 4 Mr. Epstein's house that day? 5 MR. KUVIN: — how long did the execution 5 A. Yes, I did. 6 of the warrant take. 6 Q AM how long were you at his house that 7 MR. PIKE: I am going to answer your 7 . the 8 question. You have asked several questions 8 A. I believe we started around 9:30 and we 9 here today that involve hearsay opinion 9 concluded I want to say around 1:00. 10 testimony from others that Detective Recarey 10 ' Q. Okay. I have a whole bunch of property 11 allegedly spoke to others that spoke to, for 11 receipts that were turned over by the Town of Palm 12 instance, third parties that spoke to Detective 12 Beach. This was the property receipt turned over to 13 Recarey. 13 us the other day bye-mail. 14 And as a result you have very serious 14 MR. PIKE: This is not what we discussed 15 opinion and hearsay privileges that are 15 yesterday. 16 asserted here. And I really don't 16 MR. KUV1N: This is an e-mail from 17 understand the point of this deposition 17 Ms. O'Connor's office that was sent to 18 today because none of it is admissible. 18 everybody. 19 So, hopefully that helps you with 19 MR. EDWARDS: These were all in the 20 your question, and you can rephrase them 20 original production as well. 21 or, you know, just continue, 21 MR. PIKE: I have a copy. 'Blank you. 22 And while we're on that topic, let me 22 MR. KUVIN: I would blue to show you those 23 ask you this, it's 12:15 and — 23 property receipts. And just for the record, 24 MR. KUVIN: i was going to break at 12:30 24 let's mark all property receipts as Exhibit 4. 25 for lunch. 25 Do it as a composite exhibit. 32 (Pages 122 to 1 2 5) PROSE COURT REPORTING AGENCY, INC. EFTA00298291 Page 126 Page 128 1 (Plaintiffs Exhibit No. 4 was marked for 1 Q. It's got your ID number there. And what 2 identification.) 2 was your ID number at the time? 3 BY MR. KUVIN: 3 A. 7915. 4 Q. Can you tell by looking at the pmperty 4 Q. And the unit was what? 5 receipts what property was seized on the date of the 5 A. At that time I was Delta Unit. It was 6 execution of the warrant versus other property that 6 Delta EL 7 may have been obtained during the investigation? 7 Q. Okay. And the date that this property was 8 A. Yes. 8 recovered was when? 9 Q. All tight. Could you pull out the 9 A. October 20th, 2005. 10 property receipts regarding the property seized on 10 Q. All right. Let's go through some of these 11 the date of the execution of the warrant. Just 11 thing. It appears that you retrieved phone message 12 separate those out for us. 12 books from the kitchen area of the house; is that 13 A. PC affidavit would have actually written on it 13 correct? 14 search warrant return on the very top, so it's easy to 14 A. Correct 15 identify plus it would be notarized at the bottom. 15 MR. PIKE: Form. 16 Q. Great. Take a look then. 16 BY MR. KUVIN: 17 A. I have five here, but it looks like I am 17 Q. There seemed to be little bar codes next 18 missing one because it says one of six; two, three, 18 to some of the descriptions. I would ask you to 19 four, five. 19 describe what those are. 20 Q. Just if you would look through the 20 A. The bar codes is actually utilized by crime 21 remaining documents to make sure we're not missing a 21 scene to find the location of it. It's a — the 22 page. Yeah, keep those separate. 22 property itself and the property receipt has the same 23 Mk PIKE: Move to strike. 23 bar code, and it's to help them identify where it is in 24 THE WITNESS: Here we go. Page 6 of 6. 24 the evidence room. 25 MR.1CUVIN: Okay. Just put the rest of it 25 Q. Okay. Did you recover numerous different Page 127 PAT-, ". 1 back and I just want to make sure that I got phone message pads? 2 the entire — let's do this if you would: 2 MR. PIKE: Form 3 Stick 4, I am going to put 4-A on this document 3 THE WITNESS: Yes, I did. 4 just so that we can separate it out from the 4 BY MR. KUVIN: 5 rest of4. 5 Q. Les go to Page 2 along with phone 6 THE WETNESS: That was towards the back 6 message pads. Did you also recover CD's and — 7 MR. PIKE: Yes, I know. I have got it. MR. EDWARDS: We might have lost her 8 (Plaintiffs Exhibit No. 4-A was marked offain 9 for identification.) 9 MR. PIKE: Kathy, are you them? 10 MR. PIKE: And it's six pages, correct, 1 10 MR. EDWARDS: Were about to break anyway 11 through 6? 11 MR. KUVIN: Why don't we go ahead and 12 THE WITNESS: Yes, sir. 12 break. How long do you want for lunch? 13 MR. KUVIN: Mars correct. 13 MR. PIKE: Halfhour. 14 BY MR. KUVIN: 14 MR. KUVIN: Is that okay with you? Its 15 Q. Let's go through this fora moment. All 15 12:30. Let's do 30. 16 right. Is this a document that you fill out? In 16 MR. EPSTEIN: Back at 1:00? 17 other words is that your handwriting? 17 MR. KUVIN: Yes, back at 1:00. 18 A. It might have been crime scene's. 18 (A luncheonrecess was held.) 19 Q. Okay. Do you sign the document at all? 19 * • • • • 20 A. Yes, I do. 20 21 Q. All right. Where does your signature 21 22 appear? 22 23 A. It would be in the performance ofmy duties. 23 24 Q. Gotcha. In the bottom right corner? 24 25 A_ Yes. 25 33 (Pages 126 to :29) PROSE COURT REPORTING AGENCY, INC. ( EFTA00298292