EFTA00298293

Page 130 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME II 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 au& PROSE COURT REPORTING AGENCY, INC. Electronically signed by eynthla hopkins (601 Electronically signed by cynthia bodkins (601 Electronically signed by cynthia hopkins (601 ea2stiddbfaB1-4f16-b3b7deda51494142 EFTA00298293 EFTA00298294 Page 131 Page 133 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL t APPEARANCES CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 On bead( cflbe Plaintiffs, B3.CL 2 CASE No.502038CA0373I9/000CMB AB 3 SPENCER T. KUM!. ESQUIRE 3 LEOPOLD KUVIN 4 2925 PGA Bodevard B.B. Suite 200 4 5 Pam flaida 33410 Plaintiff Phone. S 6 6 -vs- VOLUMBIIOFII 7 On behalf et the Pin:dirk Ltd E.W and 7 Jane Doe: jA 121.11 9 BRADLEY J. EDWARDS, ESQUIRE 8 FARMER, JAFFE, WEISSING, EDWARDS Defendants. 10 FISTOS & LEHRMAN, P.L. 9 425 Rath Anikens Avenue 10 11 Stile 2 11 Fat 33301 12 DEPOSITION OF 12 Maw 13 On behalf ace a I Drench 8. DETECTIVE JOSEPH RECAREY 14 JESSICA ARDOUR. ESQUIRE 13 MERMELS1131N k HOROW112., P.A. 14 Friday, March 19, 2010 15 16205 Biscayne Boulevard 15 9:37 - 5:12 p.m. Suite 2218 16 250 Australian Avenue South 16 Miami, 3 60 Suite 1500 nom 17 West Palm Beach, Florida33401 17 &mad 18 18 Onbelsalf, t e 3Ulli..S s , and 103. 19 19 20 20 KAI/691M W EZELL, ESQUIRE 21 PODHURST ORSEOC 22 Reported By. 21 25 Wen Hagler Street Cynthia Hopkins, RPR, FPR SAC 800 23 Notary Public, State ofFlorida 22 Prose Court Reporting Moe: 24 23 (Via one) Job No.: 1509 24 25 25 Page 132 1 Appearances oonimued 2 UNITED STATES DISTRICT COURT 2 On behalf of the FlairditT, Ina Doe No.11: 3 IDDRO MANUEl. °ARM, ESQUIRE SOUITIIRN DISTRICT OF FLORIDA GARCIA ELKINS& BOEHRINCER 3 4 224 Diva Ann, Sale 900 CASE NO. 10.80309 Wen PUS& 33401 4 5 Phe 6 and 5 JANE DOE NO. 103, 7 TARA A FDDILGAN, ESQUIRE 6 Plabtiff, TARA A MINICAR. P A 7 -vs- VOLUMEII OF II 8 224 Dina Street 8 JEFFREY EPSTEIN, Suite 900 9 Defendant. 9 West tide 3340! Mae: 10 10 1/. Cte tehalfof the Defendant inlay Epstein: 11 12 MICHAEL PIKE, ESQUIRE 12 DEPOSITION OF BURMAN, ORITTON, LUIT1ER & COLEMAN, U.1) DETECTIVE JOSEPH RECAREY 13 303 Barn Bouienad Suite 4t0 13 14 West tads. 33401 14 Friday, March 19, 2010 Phone- IS 9-37 - 5:12 pm. 15 16 250 Australian Avenue South 16 and 17 AO; ALAN GOUAERGER, ESQUIRE Suite 1500 ATTERBURY, GOLDBERGER & WELSS, PA 17 West Palm Beach, Florida 33401 10 250 AttuWine Avenue Sash 18 Suite 1400 19 19 west P • 'dm 334014012 20 Phan' 20 21 21 and 22 Reported By: 22 lifiLTON G. wrgramo. ESQUIRE Cynthia Hopkins, RPR, FPR LAW OFFICE OF MILTON 0. WEIMER° 23 Notary Public, State ofFlorida 23 20 Pat Plaza Sine I COO, Prose Court Reporting 24 Boston. 02116 24 Mb No.: 1509 Phone 25 25 2 (Pages 131 to 134) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 na2a6ddb.fa81-41f6-b3b7-deda61494142 EFTA00298295 Page 135 Page 137 g Appearances continued... CONTINUED DIRECT EXAMINATION 2 On behalf of the Witness: BY MR. KUVIN: 3 JOANNE M. O'CONNOR. ESQUIRE 3 Q. All right. We were going over the JONES,}vs eft, JOHNSON & STUBBS, P.A. 4 property receipts for the search warrant when we 4 505 South Elegies Drive, Suite 1100 West Nitride 33401 5 left off. And specifically we were at Page 2. We 5 Phone: 6 were looking at some of the things that you took in. 6 7 Each item that you took dining the search warrant 7 Also Present: Jeffrey Epstein 8 was numbered; is that correct? 8. 9 A. Correct 9 INDEX 10 MR. PIKE: Foram. 10 11 BY MR. KUVIN: 12 EXAMINATION DIRECT CROSS REDIRECT 12 Q. And the item number appears where? 13 CONTINUED EXAMINATION BY 13 MR. PIKE: Form. 14 het ICUVIN 134 14 THE WITNESS: Under item number. 15 BY MR. EDWARDS 243 15 BY MR. KUVIN: 16 16 Q. All right And this is a standard form 17 • 18 EXHIBITS 17 wed by the police department? 19 18 A. That's correct. 20 19 MR. PIKE: Fonm 21 EXHIBIT DESCRIPTION PAGE 20 BY MR. KUVIN: 22 21 Q. All right If we look at Item Number 24, 23 PLARTI1FF'S EX. S SUPPLEMENT FOR CHAIN 151 22 what MS that? OF CUSTODY LOG 23 MR. PIKE: Form. 24 PLAINTIFFS EX. 6 PAGE FROM MESSAGE PAD 196 PLAINTIFFS EX. 7 PHONE MESSAGE 204 24 THE WITNESS: It was a twin torpedo in a 25 25 brown box. Page 136 Page 138 1 BY MR. KUVIN: EXHIBITS CCeITINUED 2 2 Q. What is that? 3 MONT DESCRIPTION PAGE 3 MR. PIKE: Form. 4 PLANETS EX S PHONE MESSAGE 205 PLAINTIFFS Ex 9 PHONE MESSAGE 208 4 THE WITNESS: It is a synthetic penis, $ PLAINTIFFS EC 10 PHONE MESSAGE 209 5 double, double sided. PLAINTIFFS EC 11 PHONE MESSAGE 211 6 PLAINTIFFS EX 12 PHONE MESSAGE 212 6 BY MR. KUVIN: PLAINTIFFS EX 13 PHONE MESSAGE 213 7 Q. Okay. Double sided meaning it has, what, 7 PLAINTIFF'S EX 14 PHONE MESSAGE 215 PLA/NIIFF'S EC 15 PHONE MESSAGE 215 8 two heads on it? 8 FIAINTIFFS EC 16 PHONE MESSAGE 217' 9 A. Yes. PLAINTIFFS EX 17 PHONE MESSAGE 219 9 PLAINTIFFS EX IS PHONE MESSAGE 220 10 MR. PIKE: Fonm. PLAINTIFFS EC. I9 PHONE MESSAGE 221 11 BY MR. KUVIN: 10 PLAINTIFFS DC 20 PHONE MESSAGE 222 PLAINTIFFS DC 21 PHONE MESSAGE 223 12 Q. How big is this? 11, PLAINTIFFS EC 22 PHONE MESSAGE 22$ 13 A. About 12 inches, 10, 12 inches. PLAINTIFFS DC. 23 AND 24 PHOTOS 227 12 PLAINTIFFS EX. 2$ PHo GE 230 14 MR. PIKE: Objection to the form of that PLABTTIFFSFX. 26MS. 240 15 question. 13 CELLINIONE LOG PLAINTIFF'S EC 27 LETTER DATED JULY 24, 241 16 BY MR KUVIN: 14 2006 17 Q. Do you know where it was taken from? PLAINTIFFS DC 28 INTELLIGENCE REPORT 243 15 DATED maw 18 MR. PIKE: Form. 16 19 THE WITNESS: It was in one of the 17 18 20 bedrooms. 19 21 BY MR. KUVIN: 29 • 21 22 Q. Do you know if any DNA analysis was done 22 23 on that? 23 24 24 MR. PIKE: Form. 25 25 THEE WITNESS: Not that I am aware of. r.), 1,1 .f7 01.1•1•11W*1 CFA, 3 (Pages 135 to 138 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2Mddb-fal31-4116-b3b7-dcda51494142 EFTA00298296 Page 139 Page 141 1 (Mr. Epstein returned the deposition 1 THE WITNESS: I believe so. 2 mom.) MR. PIKE: Move to strike. 3 BY MR. KUVIN: BY MR.!MIN: 4 Q. All right. Let's take a look at the next 4 . Q. Where in the house was this transcript 5 page. Item 27, what was that? 5 kelt 6 A. It was a high school transcript — 6 MR. PIKE: Form. 7 MR. PIKE: Form. 7 THE WITNESS: In the desk, the desk drawer 8 THE WITNESS: that was located in the 8 of the — there was a desk in the master 9 master bedroom. 9 bedroom. 10 ' BY MR. KUVIN: 10 BY MR. KUVIN: 11 Q. Appears to be something blacked out. What 11 Q. Okay; So, in the master bedroom? 12 is blacked out? 12 MR. PUCE: Form. 13' . A. The name of Jane Doe No. 103. 13 THE WITNESS: Yes, sir. 14 MR. PIKE: Form. 14 BY MR. KUVIN: 15 BY MR. KUVIN: 15 Q. Was there an office downstairs as well? 16 Q. Okay. Did you actually see this? 16 A. Yes. 17 A. Yes, I did. 17 Q. It was not found in the office? 18 Q. And can you describe for me what it was? 18 MR. PIKE: Form. 19 MR. PIKE: Form. 19 THE WITNESS: No.. 20 THE WITNE • was h hi school 20 BY MR. KUVIN: 21 transcript from High School. 21. . Q. The next thing, Item 28, what was that? 22 BY MR. KUVIN: .. 22. A. That was a bottle ofJoy Jelly. 23 Q. Now, it says "VALUE not" What does that• 23 Q Did you determine what that is? 24. mean? 24 MR. PIKE: Form. 25 MR. PIKE: Form. 25 THE WITNESS: It's a lubricant Page 140 Page 142 THE WITNESS: That was written by Greg 1 MR. KUVIN: Sexual lubricant? Parkinson, our crime scene manager, who was 2 MR. PUCE: Form. 3 filling the form as to, when we identified the •3 • THE WITNESS: That's correct 4 object we wanted to take, you would put it on . 4 BY MR. KUVIN: 5 the property receipt 5 Q. Where was that found? 6 BY MR. KUVIN: 6 A. In the credenza in the master bedroom. 7 Q. Okay. With respect to this particular 7 MR. PIKE Form. 8 transcript, was this taken by the FBI when they took' 8 BY MR. KUVIN: 9 all the evidence? 9 Q. Item 29 appears to be a bunch of 10 A. Yes. 10 videotapes? 11 MR. PIKE: Form. 11 A. Yes. 12 BY MR. KUVIN: 12 Q. There is one there called "I Love Lesbians 13 Q. Did you ever determine why her high school 13 Four." Do you see that? 14 transcript was found in Mr. Epstein's home? 14 A. Yes. 15 MR. PIKE: Form. 15 Q. Where was that found? 16 ME WITNESS: During my interview with' , 16 MR. PUCE: Form. 17 : het, she claimed that Mr. Epstein had said that 17 THE WITNESS: The master bedroom. 18. he was going to help her get into a good • 18 BY MR. KUVIN: 19. college and when she graduated to give him a 19 Q. Did you find massage tables during the 20 copy of the transcript to assist her in getting 20 search of the home? 21'. into a college. 21 MR. PIKE: Form. . 22 BY MR. KUVIN: 22 THE. WITNESS: Yes, we did. We found a 23 Q. Did the high school transcript show her 23 couple ofmassage tables. 24 date ofbirth? 24 BY MR. KUVIN: 25 MR. PIKE: Form. 25 Eyhere? 4 (Pages 139 to 142) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by Cynthia hopkins (601 Electronically signed by cynthia hopkins (601 ea2a6ddb-fa81.4lf6•b3b7•dcda51494142 EFTA00298297 Page 143 Page 145 MR. PIKE: Form. 1 in any format that you felt was useful evidence for THE WITNESS: One was in the master 2 Mr. Epstein's prosecution that was currently being 3 bedroom area. There was another one found in 3 investigated? 4 another bedroom area. There were different .4 MR. PIKE: Form. colors. There was like a green one, a white '5 THE WITNESS: There was a CPU that was in one, a peach one but -- 6. an office like the assistant's office. 7 BY MR. KUVIN: 7 MR. KUVIN: Okay. 8 Q. Okay. Did you, yourself, personally see 8 THE WITNESS: That was not connected. It 9 the massage tables in the home when you were-there 9 was an Older CPU which was taken to the 10. for the warrant? 10 Sheriffs Office for — to be analyzed. 11 MR. PIKE: Form. 11 MR. KUVIN: Okay. 12 THE WITNESS: That is correct. 12 THE WITNESS: They were able to retrieve 13 BY MR. KUVIN: 13 some images off that computer from that covert 14 Q. It appears that Item 34 was a number of 14 camera in the living room, in that office 15 CD's? 15 living room area. 16 A. Correct. 16 BY MR. KUVIN: 17 Q. Did you ever determine what was on them? 17 Q. And what did those images show? 18 A. Everything was viewed, some of the CD's were 18 MR. PIKE: Form. 19 empty. But at the time we didn't know, we just had to 19. THE WITNESS: It showed Mr. Epstein 20 take it and view it. 20 sitting at his desk. It was basically motion 21 Q. Items 34 through 40 on the list appears to 21 activated. When there was motion, it would 22 be a bunch of different medias such as ZIP CD's and 22 start to record. So, there was, there were 23 eight millimeter video, flash cards, ZIP CD's and 23 images of Epstein at his desk. There was 24 CD's. Did you view all those materials? 24 images of his assistant with Mr. Epstein 25 A. That is correct. 25 sitting at the desk. There were images of what Page 144 Page 14. 1 MR. PIKE: Form. 1. I believe to be also shown as 2 BY MR. KUVIN: 2 well. 3 Q. Was there anything on these materials that 3 Again, the lighting was poor so a, I 4 are listed on here, 34 through 40, that showed any 4 couldn't positively say 100 percent, okay, 5 girls that you determined to be underage? 5 that's so-and-so. I could say that was 6 MR. PIKE: Form. 6 Mr. Epstein because I have seen Mr. Epstein. I 7 THE WITNESS: Some of the items that we 7 know what he looks like. You know I can say 8 took from the guesthouse area were determined the female did appear to be one 9 to be Janusz's, the houseman, live-in houseman, 9 of the assistants appeared to be 10 items which was returned to him once we 10 You know, that kind of thing. 11. determined that it was his. 11 BY MR. KUVIN: 12 BY MR. KUVIN: 12 Q. All right. Did you see any other girls in 13 Q. Okay. Anything else that you found on 13 that video that was on the CPU? 14 there that you felt was of value for the prosecution 14 MR. PIKE: Form. 15 of Mr. Epstein? 15 THE WITNESS: There was someone else but 16 MR. PIKE: Form. 16 just can't recall who it was. 17 BY MR. KUVIN: 17 BY MR. KUVIN: 18 Q. That you can recall. 18 Q. Where is that CPU now if you knovfl 19 MR PIKE: Same. 19 A. With the FBI. 20 THE WITNESS: From the guesthouse? 20 Q. Was there any other digital information 21 BY MR. KUVIN: 21 that was seized that you were able to see that you 22 Q. Well let me ask it this way, a little bit 22 felt was helpful in any way to the investigation? 23 broader: Based on the information that you 23 MR. PIKE: Form. 24 confiscated from the home during the warrant, search 24 THE WITNESS: Not off the computer. 25 warrant, did you find any cons uterized r nf 5 (Pages 143 to 146) (561) 832-7500 PROSE COURT REPORTING'AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-fa81-4116-b3b7-dcda51494142 EFTA00298298 Page 147 Page 149 1 BY MR. KUVIN: 1 BY MR. KUVIN: 2 Q. What about on any of the CD's or 2 Q. I want to come back to that fora minute. 3 flashcards that were taken? 3 How many CPU's did it appear to you were missing? 4 MR. PIKE: Form. 4 MR. PIKE: Form and speculation. 5 THE WITNESS: There was a video. It 5 THE WITNESS: There was one missing from 6 appears to be, it appears to be in the private 6 the desk area in the living room with the power 7 island of Mr. Epstein when you see a helicopter 7 cords — all the cords were there. The CPU was 8 coming in, and there was some females there gone. 9 dancing 9 MR KUVIN: Okay. 10 BY MR KUVIN: 10 THE WITNESS: There was one from the pool 11 Q. Was this on a computer format like a CD or 11 house where the cords were there, the monitor 12 a flash drive or — 12 was there, the keyboard, the mouse. The CPU 13 A.. I believe it was an — 13 was gone. I would say two. 14 Q. — an eight millimeter? 14 BY MR. KUVIN: 15 A. I might have been an — 15 Q. Okay. Did you ever come to team during 16 MR. PIKE: Form. 16 the investigation where those CPU units were? 17 THE WITNESS: Eight millimeter. 17 MR. PIKE: Form. 18 BY MR. KUVIN: 18 THE WITNESS: I believe I was told that 19 Q. Okay. Any other media information that 19 those CPUs were actually sitting in an 20 you can recall after having reviewed all of the 20 attorneys safe. 21 things that you confiscated from the home that you 21 BY MR. KUVIN: 22 found was helpful in the investigation? 22 Q. Okay. Did you come to learn that they, 23 MR. PIKE: Form. 23 that Guy Fronstin had actually taken possession of 24 THE WITNESS: Not that I can recall. 24 those? Does that refresh your recollection at all, 25 25 or was it another attorney? Page 148 Page 150 1 BY MR. KUVIN: 1 MR. PIKE: Forst 2 Q. Now, it appears that you confiscated as 2 THE WITNESS: I was told it was Roy 3 part of the search warrant a number of CPUs and 3 Black's office that had them. 4 their power cords; is that correct? 4 BY MR. KUVIN: 5 A. Yes. 5 Q. Gotchat. All right. Let's keep going 6 MR. PIKE: Form. What page are you on? 6 here. Item 58 was another massage table that was 7 MR. KUVIN: It looks like 43 and 44. 7 taken as evidence? 8 Items 43 and 44 are the first power cords and 8 A. Correct. ' 9 CPU. Items 54 and 55 are the second power cord 9 MR_ PIKE: Form. 10 and CPU. 10 BY MR. KUVIN: 11 BY MR. KUVIN: 11 Q. You saw that massage table? 12 Q Do you recall how many CPUs you took into 12 A. Yes, sir. 13 custody? 13 Q: Okay. La look at the next page, six of 14 • A. We took a couple but obviously one of them 14 six. It says a green photograph with a naked girl. 15 was positive that it belonged to Janusz because it had 15 Do you recall where that was taken from? 16 all his personal stuff; his personal photographs of he 16 A. That was taken out of the, I believe, master 17 and his wife. So those were returned to him. 17 bedroom. 18 Q. Okay. 18 MR. PIKE: Form. 19 MR. PIKE: Form to that question. 19 BY MR. KUVIN: 20 BY MR. KUVIN: 20 ' Q. Could you tell by looking at the 21 Q You mentioned at the beginning when you 21 photograph whether it was an underage girl? 22 executed the search warrant that you felt in your 22 MR. PIKE: Form. 23. opinion the house had been sanitized because you 23 BY MR. KUVIN: 24 noticed things that appeared to be missing. 24 Q. I mean, was it a young girl, a mature 25 MR. PIKE: Form. 25 girl, old? •••••••••••sts•n eV1---, 204aV vie lS4LS .o.,..., 6 (Pages 147 to 150 ) PROSE COURT REPORTING AGENCY,' INC. Electronically signed by cynthla hopkins (601 Electronically signed by eyntiga hopkins (601 Electronically signed by cynthla hopkins (601 aa2a6ddb-fal11-4116-b3b7-dcda61494142 EFTA00298299 Page 151 Page 153 A. No, it was a young girl. 1 touched on this briefly in the beginning, but what 2 MR. PIKE: Same objection. 2 happened with the investigation once you filed the 3 THE WITNESS: Very young girl. 3 probable cause affidavit and got the warrant? At 4 BY MR. KUVIN: 4 what point did you turn it over to the State 5 Q. Could you tell the age from the photo? 5 Attorney's Office? MR. PIKE: Form. 6 A. Once I filed the arrest warrant for .7 THE WITNESS: Younger than ten. 7 Mr. Epstein, there were actually three warrant requests 8 BY MR. KUVIN: to be honest with you. There was a warrant raLmt for Q. Could you find any photographs of girls 9 Je in, I want to say =, and 10 that were victims during the investigation? Did you 10 11 find any photographs of girls that were victims 11 Q. Okay. What happened with those arrest 12 during the investigation? 12 warrants for all three of them? 13 MR. PIKE: FOUR 13 MR. PIKE: Form. 14 THE WITNESS: There were photographs taken 14 THE WITNESS: Once they were turned over 15 during the search warrant, topless females that 15 to the State Attorney's office, I was notified 16 were taken. But no, I did not locate one of 16 several days later that they were going to be 17 the victims in the photos. 17 requesting a grand jury to listen to the case. 18 MR. KUVIN: Okay. If we look at what 18 BY MR. KUVIN: 19 we'll mark as Exhibit 5, appears to be a 19 Q. Okay. And did a grand jury hear the case 20 supplement of the chain of custody log. two 20 as far as you know? 21 pages. Make sure I have got it. Ifs three 21 A. Eventually they did. 22 pages actually. 22 Q. And do you know what occurred after the 23 (Plaintiffs Exhibit No. 5 was marked for 23 grand jury heard the case? 24 identification.) 24 MR. PIKE: Form. 25 25 THE WITNESS: It was true bill. Page 152 Page 154 1 BY MR. KUVIN: 1 BY MR. KUVIN: 2 Q. We have got what appears to be a four-page Against? 3 document which happens to be called a chain of 3 A. Mr. Epstein. 4 custody. I just have a couple quick questions about 4 Q Just for people that may not know what a 5 this. 5 true bill is, can you explain briefly what that If you would look at the last entry in the 6 means? 7 • chain of custody, I just wanted to coafum where all 7 A. Grand jury found sufficient evidence to charge 8 the evidence went according to the documentation. 8 Mr. Epstein. 9 A. Everything went TOT, to the FBI. 9 Q What was he charged with? 10 Q. I am sorry, what were the initials? 10 MR. PIKE: Form. 11 A. TOT. THE WITNESS: I think it was, it was a 12 Q. What does that mean? 12 procurement for prosecution. 13 A. Given to the FBI. 13 BY MR. KUVIN: ' . 14 Q Okay. So the chain of custody which we 14 Q. Have to do with minors? 15 have marked as Exhibit 5 shows that all the evidence 15 A. Yes. 16 you had in this case was given over to the FBI; is 16 MR. PIKE: Form. 17 that correct? 17 BY MR. KUVIN: 18 MR. PIKE: Form. 18 Q All right. After the execution of the 19 THE WITNESS: The items that were returned 19 search warrant, your investigation continued; is 20 to Janusz were returned to Janusz (sic). The 20 that correct? 21 items that were not returned were given to the 21 A. Correct 22 FBI. 22 Q. And during the investigation, did you have 23 BY MR. KUVIN: 23 occasion to speak with or meet with a gentleman by 24 Q. Okay. Great. All right. Ultimately what 24 the name of Juan Alessi? 25 happened with respect to the investigation, and I 25 A. Juan Alessi, yes. 7 (Pages 151 to 154) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddbifa81-4116-b3b7-dcda51494142 EFTA00298300 Page 155 Page 157 1 Q. Who was that? 1 THE W/TNESS: No. 2 A. He was the former houseman of Mr. Epstein. 2 BY MR. KUVIN: 3 MR. PIKE: Form. 3 Q. Narrative 18, it looks like you matte 4 BY MR. KUVIN: 4 telephone contact with another white, looks like WF, 5 Q. Did he give you information that you felt 5 I assume it means white female, on November 8. Do 6 was helpful in the prosecution of Mr. Epstein? 6 you recall which girl that may have been? 7 MR. PIKE: Form. 7 MR. PIKE: Form. 8 THE WITNESS: He described, he described 8 BY MR. KUVIN: 9 washing off the vibrator massagers after the 9 Q. Let me ask it this way: Was this a 10 massage incidents. He recalled having young 10 recounting of the incident with Ms. Jane Doe No. 11. girls coming in to do the massages. 11 103? 12 BY MR. KUVIN: 12 A. No. 13 Q. Did he mention that he, whether he 13 Q. This is a different girl? 14 witnessed that? 14 A. Ibis is a different girl. 15 MR. PIKE: Move to strike witness's last 15 MR. PACE: Form to both questions. 16 statement pending hearsay and form. 16 THE WITNESS: This was a different girl 17 Mr. Kuvin, next question if he has 17 and I am trying to remember who it was. 18 completed it. 18 BY MR. KUVIN: 19 BY MR KUVIN: 19 Q. Do you recall the name M? 20 Q. Did he mention whether or not he had 20 A. Yes. 21 witnessed young girls coming to the house? 21 Q. Is that who this was? 22 MR. PIKE: Same objection. 22 MR. PIKE: Form. 23 THE WITNESS: Yes. 23 THE WITNESS: Yes, it was. 24 BY MR. KUVIN: 24 BY MR. KUVIN: 25 Q. If we look back at the incident report 25 Q. Okay. And apparently she had reported Page 156 Page 158 1 Page 47 — got it there — it looks like you made 1 sexual intercourse with Mr. Epstein? 2 contact, telephone contact with another girl on 2 A. That is correct. 3 November 7 of 2005, and took another taped 3 MR. PIKE: Form, leading. 4 statement, sworn taped statement. Can you determine 4 BY MR. KUVIN: by looking at your swnmary there in Narrative 16 of 5 Q. Did she report any sexual contact with 6 November 7,2005, which girl that was? 6 Mr. Epstein? 7 MR. PIKE: Form. 7 A. Yes, she did. 8 THE WITNESS: I believe that was■ 8 Q. What type? 9 MR. KUVIN: 9. MR. PIKE: Form. 10 THE WITNESS: 10 THE WI NESS: She was paid to have vaginal 11 BY MR. KUVIN: 11 intercourse. 12 Q. Do you recall wha.s state of mind or 12 MR. PIKE: Form, move to strike. 13 emotional condition was when she spoke to you about 13 BY MR. KUVIN: 14 this event? 14 Q. Did you determine how old she was when she 15 MR. PIKE: Form. 15 reported having this vaginal intercourse with 16 THE WITNESS: I can't recall. 16 Mr. Epstein? 17 BY MR. KUVIN: 17 MR. PIKE: Form. 18 Q. Let's take a look at Narrative 17. It 18 THE WITNESS: Sixteen years of age. 19 looks like you made contact with someone else, you 19 MR. PIKE: Spencer, can you hold on? 20 along with Detective Dawson made contact with 20 MR. KUVIN: Yes, sir. 21 somebody and left a business card at the front door. 21 MR. PIKE: Letts go off the record for a 22 Do you see that? 22 second. 23 A. Yes. Yes,' do see it. 23 (A discussion was held off the record.) 24 Q. Do you recall which girl that was? 24 MS. EZELL: If I could interject, I was 25 MR. PIKE: Form. 25 fumblin on mute and I wanted to move to strike ••••••••••••• 8 (Pages 155 to 158) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a6ddb•fa81-4ff6•b3b7-dcda51494142 EFTA00298301 Page 159 Page I(_ 1 the witness's comment that she was paid to have 1 MR. PIKE: Form. 2 vaginal intercourse with Mr. Epstein. 2 BY MR. KUVIN: 3 MR. KUVIN: Okay. 3 Q. Does she describe whether or not she had 4 BY MR. KUVIN: 4 gone to Mr. Epstein's home? 5 Q. Do you recall the demeanor ofM when 5 A. Yes. 6 she was recounting this for you? 6 MR. PIKE: Form. 7 MR. PIKE: Form. 7 BY MR. KUVIN: 8 BY MR. KUVIN: 8 Q. Did she describe whether or not she 9 Q. Was she upset, calm? How did she appear brought anyone with her during that time? 10 to you? 10 MR. PIKE: Form. 11 MR. PIKE: Form. 11 THE WITNESS: If I can read — 12 THE WITNESS: She did — I recall her 12 MR. KUVIN: Yes. You can refer back to it 13 being upset, talking to me. Occasionally 13 if you need to. 14 crying. It wasn't like a hysterical cry but MR. PIKE: For the record you're referring 15 she was visibly upset 15 back to Exhibit 1, correct? 16 BY MR. KUVIN: 16 THE WITNESS: Correct. Yes, she did. 17 Q. Okay. Do you recall Ms. Ms date of 17 BY MR. KUVIN: 18 birth? 18 Q. Okay. Now, if we look at Page 16 of 22 19 A. Not off the top of my head. 19 there with respect to Ms.■ it mentions 20 MR. KUVIN: All right. Let me see if I 20 something about a Christmas bonus. Do you see that? 21 can help you here. It looks like we have an 21 A. Yes. 22 unredacted copy of the PC affidavit That will 22 Q Can you explain to us what she told you 23 help. This document will remain sealed 23 about that? 24 pursuant to all previous agreements in the case 24 MR. PIKE: Form. 25 with respect to any documents that we referred 25 THE WITNESS: She received a wire, a Page 160 Page 162 to. 1 Western Union wire to what she referred to as a 2 THE WITNESS: That's Exhibit 1? 2 Christmas bonus. 3 MIt KUVIN: Bingo. Do you have a copy? 3 Q. Who did it come from? 4 MR. PIKE: Thank you. 4 A. Mr. Epstein. 5 MR. KUVIN: If you turn to Page 15 of 5 MR. PIKE: Form. 6 22 — 6 BY MR. KUVIN: 7 MR. EDWARDS: I have one thanks. 7 Q. All right. On November 15 you met with 8 BY MR. KUVIN: 8 someone with the initials= is that correct? 9 Q. Do you have Page 15? 5 A. Correct. 10 A. Uh-huh. 10 Q. Do you agawho that was? 11 Q. If we look there, what was Ms date of 11 A. Yes, it's= 12 birth? 12 Q. . What was her date of birth? 13 A. 13 MR. PUCE: Form. 14 MR. PIKE: Form. 14 THE WITNESS: 15 BY MR. KUVIN: 15 • BY MR. KUVIN: 16 Q. All right Let's go to, let's stay with 16 Q • Did she recall going to Mr. Epstein's 17 this because it's unredacted because it will be a ' 17 bony? 18 little gasier. November 15 you apparently met 18 MR. PIKE: Form. 19 withE is that correct? 19 • THE WITNESS: Yes. 20 PIKE: Form. 20 BY 1ViR. KUVIN: 21 THE WITNESS: 14th I believe it was. 21 Q. What was her emotional state when you 22 BY MIt KUVIN: 22 'talked to her? 23 Q. 14th, correct. Thank you. And her date 23 ' A. She was nervous, scared, and embarrassed. :2she 24 Q Okay. Did she recount going to 25 . A. 25 Mr. E • tein's home? 9 (Pages 159 to 1 62) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia Hopkins (601 Electronically signed by cynthia hooking (601 Electronically signed by cynthia Hopkins (601 aa2a5ddb.fa81-4116-b3b7-ckda51494142 EFTA00298302 i-age 163 Page 165 A. Yes. 1 that would swing open and it led you up a stairwell that 2 MR. PUCE: Form. 2 just went up and around. 3 BY MR. KUVIN: 3 Q. All right. And bottom paragraph on 4 Q. Was she underage? 4 December _ ? SI_Detective and I met within Do you 5 MR. PIKE: Form. 5 recall whonis? THE WITNESS: Yes. 6 A. Yes, Jane Doe No. 2. 7 BY MR. KUVIN: 7 Q. What was her date of birth? 8 Q. Do you recall how old she was when she MR. PIKE: Form. 9 went there? 9 THE WITNESS: 10 MR. PIKE: Form. 10 BY MR. KUVIN: 11 12 13 THE WITNESS: Sixteen. BY MR. KUVIN: Q. Okay. Much like all the other occasions 11 12 13 to Q. And it say.' made arrangements to take the house. Did that mean to Mr. Epstein's 14 that we have talked about today, was Mr. Epstein 14 MR. PIKE: Form. 15 naked and received a massage from her? 15 THE WITNESS: Correct. 16 A. Correct. 16 BY MR. KUVIN: 17 MR. PIKE: Form. 17 Q. Who is 18 BY MR. KUVIN: 18 A. Jane Doet. 3. 19 Q. She was given money like all the other 19 . Q. Did you determine whether or not e, 20 girls for that massage? 20 Ms. Doe No. 2, was taken to Mr. Epstein's home when 21 MR. PIKE: Form. 21 she was minor, in other words under the age of 18? 22 THE WITNESS: Yes. 22 MR. PIKE: FOrM. 23 BY MR. KUVIN: 23 THE WITNESS: Correct 24 Q. And also much like all the other girls, 24 BY MR. KUVIN: 25 was there also a massager and vibrator involved in 25 Q. And once again didErecount a sexual Page 164 Page 166 1 that incident? 1 encounter with Mr. Epstein while at his home? 2 MR. PIKE: Form. 2 A. That's comet. 3 THE WITNESS: I believe so. 3 MR. PIKE: Form. 4 BY MR. KUVIN: 4 BY MR.. KUVIN: 5 Q. Next page, 18 — one thing I forgot to ask 5 Q. Once again encountered Mr. Epstein where a 6 is during the execution of the warrant, if we look 6 massage took place? 7 then at Line 4 it says: "Numerous photographs of 7 MR. PIKE: Form. 8 naked young females, some of which appeared to be 8 THE WITNESS: Correct. 9 the girls I previously interviewed, were on display 9 BY MR. KUVja 10 throughout the house.' Do you see that? 10 Q. When recounted her incident to you, 11 A. Yes, 11 what was her demeanor? 12 Q. Do you resell that? 12 MR. PIKE: Form. 13 MR. PIKE: Form. 13 THE WITNESS: Crying, upset, embarrassed. 14 THE WITNESS: That was on the photos 14 BY MR. KUVIN: 15 hanging on the way up the stairwell to the 15 Q. Did she mention whether or not she told 16 second floor. Some appeared to be the girls 16 Mr. Epstein where she was attending school? 17 but under closer observation, no. 17 MR. PIKE: Form. 18 BY MR. KUVIN: 18 THE WITNESS: I believe she did. I 19 Q. But they were naked, or pictures of naked 19 believe she did. 20 girls leading up that stairwell? 20 BY MR. KUVIN: 21 MR. PIKE: Form, asked and answered. 23. Q. And Pm looking at Page 19 of 22. It 22 THE WITNESS: Yes. 22 appears there is an encounter she describes where 23 BY MR. KUVIN: 23 Epstein rubbed her breasts and asked her if she 24 Q. And the stairwell, where was it located? 24 liked having her breasts rubbed. Do you recall 25 A. Off the kitchen. There was apassage door 25 that? —ter® - I"aft' llis00..."..•4.1 10 (Pages 163 to 166) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-fa81-4116-b3b7-dcda51494102 EFTA00298303 Page 16'• Page 169 MR. PIKE: Form, move to strike. 1 his fingers out. Pm trying to recall. THE WITNESS: Yes. 2 MR. PIKE: Form, move to strike, 3 BY MR. KUVIN: 3 nonresponsive. 4 Q. What did ML say to you with respect to 4 BY MR. KUVIN: 5 that issue? 5 Q. Do you recall anything else? 6 MR. PIKE: RPM 6 A. No. That would be a no. I'm sony. 7 THE WITNESS: I believe she didn't, she 7 MR. PIKE: I'm sony. I didn't hear the 8 didn't want to have her breasts touched, if I 8 question. recall. 9 MR. KUVIN: You didn't recall anything 10 BY MR. KUVIN: 10 else (sic)? 11 Q. It says here — well, let me ask you this: 11 MR. PIKE: Form. Was this interview recorded? 12 BY MR. KUVIN: • • 13 A. Yes, 13 Q. All right. Let's talk about the next 14 Q. And during the entire interview was she 14 entry in some detail here. The next entry is an 15 upset, crying? 15 interview that took place on January 9 of 2006; is 16 MR. PIKE: Form. 16 that correct? 17 THE WITNESS: I wouldn't say the entire 17 A. Yes. 18 interview. There was times she would cry. She 18 Q. Was that a taped interview? 19 would regain her composure, continue. 19 A. Yes, taped. 20 BY MR. KUVIN: 20 thsakay. And the initials•are used. Is 21 Q. Okay. It says here that she told you 21 22 Epstein had moved her thong panties to one side and 22 MR. PIKE: Form. 23, began stroking her clitoris, andlEsaying he 23 THE WITNESS: ThaVs correct. 241 commented on how hard my cht was. Do you see that? 24 BY MR. KUVIN: 25 MR. PIKE: Form 25 Q. What wasins date of birth? Page 168 Page 110 1 MR. KUVIN: Right in the center of the 1 A. 2 paragraph. 2 Q. Okay. How did you identify her as a 3 THE WITNESS: Yes. 3 potential victim or witness? 4 BY MR. KUVIN: 4 MR. PIKE: Form. 5 Q. Did she ten you that? 5 THE WITNESS: It was during an interview 6 A. Yes, she did. 6 of another, of another female that was 7 MR. PIKE: Form. 7 interviewed. Told me thatM was brought to 8 BY MR. KUVIN: 8 the house if I can recall. 9 Q. Did she appear upset when she was BY MR. KUVIN: 10 describing that to you? 10 Q. And do you recall where you initially 11 MR. PIKE: Form. 11 interviewed her? 12. . THE WITNESS: Yes. 12 A. I went to her school. She was attending a — 13 BY MR. KUVIN: 13 it was not like a regular school. It was a different 14 Q. Did she then describe whether or not 14 school, as I recall. 15 Mr. Epstein penetrates her with his fingers? 15 Q. And when you went to that school, describe 16 MR. PIKE: Form. 16 for us what you saw. !don't vault to hear anything 17 THE WITNESS: Digitally, yes. 17 about statements, just what you witnessed when you 18 BY MR. KUVIN: 18 first went there. 19 Q. What was Mr. Epstein's response when she 19 MR. PIKE: Form. 20 voiced concern about that maneuver? 20 THE WITNESS: I identified who I was and 21 MR. PIKE: Form. 21 my purpose for being there, and I wanted to 22 THE WITNESS: I think originally he told 22 talk to her about this ongoing investigation. 23 her he was not going to go inside and began 23 She started to cry. She got visibly upset, 24 touching her. Once his fingers were inside of 24 shaking. 25 her I think she tried to back • to to net 25 11 (Pages 167 to 170) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 easaddb-fa81-06-b3b7-dcdo61494142 EFTA00298304 Page 171 Page 173 1 BY MR. KUVIN: 1 have asked, because you have literally objected 2 Q. Did you, in fact, conduct the interview on 2 to eves), question I have asked. 3 that initial occasion? 3 MR. MICE: I have. A. No, I did not. 4 MR. KUVIN: And if that's the standing for 5 Q. How come? 5 the objection, you can have a standing 6 A. Because of the fact that she was a minor and I 6 objection as to all of that And then what I 7 was at the school. 1 wanted to inform her father or her 7 would I like to know is with each individual 9 parents that I was going to be conducting an interview. 8 question, if there is a way that I can fix the 9 Q. Okay. Did she appear to you in a physical 9 form of that question because of some reason 10 or mental state capable of discussing anything with 10 that you think is objectionable, I would like 11 you at that point based on just what you witnessed, 11 to know that so Jean try to fix it 12 not what she may have said but just what you were 12 MR. PIKE: Well, let me also say that the 13 able to witness? 13 form elicits third-party testimony. Almost 14 MR. PIKE: Form. 14 every one of your questions here today, every 15 THE WITNESS: No. 15 one of them elicit third-party testimony which 16 BY MR. KUVIN: 16 is hearsay and opinion. 17 Q. Can you describe why? 17 And no, I will not agree, although I 18 MR. PIKE:. Same objection. 18 appreciate your offer to have a standing form 19 THE WITNESS: She was shaken. She was 19 objection, I think that each objection needs be 20 physically upset. 20 to raised individually based upon the tenor and 21. BY MR. KUVIN: 21 structure of your questions. 22 Q. Okay. Did you have to then follow-up? 22 Some of your questions I have not objected 23 A. Yes, I did. 23 to form because the question is was there an 24 Q. Tell me about that. 24 • investigation. Okay. I am not going to object 25 MR. PiKE: Form. 25 to form. Page 172 Page 174 1 MR. KUVIN: Hang on one second. Objection 1 But when you get into what occurred during 2 to form to 'tell me about that"? 2 that investigation, how he learned of it, who 3 MR. PIKE: It's an investigation and jam 3 he spoke to, and how many third parties 4 not going to waive anything I want to preserve. 4 discussed it with the first person that he 5 MR. KUVIN: is there a particular form 5 spoke to, and how those individuals learned the 6 that I can fix? 6 information, I must assert the form and 7 MR. PIKE: Quite frankly I am not quite 7 preserve. sure you can fix any of this deposition today. a MR. KUVIN: All right. Les talk about 9 I believe that this deposition, once again, is 9. this though for a minute because this is • 10 completely - 10 important And I'm sorry for taking up your 11 MR. KUVIN: • The question. 11 time, Detective, but these questions — 12 MR. PiKE: -- completely fruitless because 12. THE WITNESS: No. 13 it is involving an investigation. None of it, 13 MR. KUVIN: — involve my client= so 14 in my research or understanding is admissible 14 any statements that she made to this Officer 15 in the civil cases.' So, there are various 15 • are admissions by a party opponent obviously 16 things that while your questions in and of 16 are admissions by a party. So the hearsay 17 themselves may seem correct, the background in 17 issue is frivolous. 18 which you're eliciting them from is not 18 With respect to anything that she said to 19 admissible, so as a result it makes the 19 him is completely admissible in this proceeding 20 form incorrect. 20 and clearly what he witnessed is admissible 21 MR. KUVIN: Let's do this then, why don't 21 because that is eyewitness. He witnessed it 22 we do a standing objection as to all questions 22 himself. 23. during the deposition as to the taking of 23 So anything with respect to what he saw 24 anything regarding statements, so that you 24 and what he witnessed, any objections regarding 25 ct to every don't hannio2liec........a _,...aI that 25 .......2Ljarsa abot that is comletel frivolous. h a. 12 (Pages 171 to 174) (561) 8-32-7500 PROSE COURT REPORTING AGENCY, :INC. Electronically signed by synth's hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by Cynthia hooklike (601 aa2a5ddb.fa81-4H6-b3b7-dcda51494142 EFTA00298305 Page 1', Page 177 1 What I need to know is when' THE WITNESS: Yes, she did. 2 questions specifically with respect BY MR. KUVIN: 3 which I am about to do, I need to know ether Q. And did she tell you how old she was when 4 or not there is a particular objection to the she went to Mr. Epstein's home? 5 form of my question that is specific to that MR. NICE: Form. 6 question as opposed to the structure of the 6 THE WITNESS: Yes, she did. 7 deposition, which if you want to object 7 BY MR. KUVIN: 8 generally, then that's fine. I need to know 8 Q. How old did she tell you that she was when 9 that because if I ask a question specific to my 9 she went to it. Epstein's home? 10 client, l want to know if there is a way that 10 MR. PIKE: Form. 11 you feel that it needs to be fixed that I can 11 THE WITNESS: I believe she said she was 12 take care of and fix presently with Detective 12 15. 13 Recarey in the room. 13 BY MR. KUVIN: 14 MR. PIKE: Okay. As to your statements 14 Q. Okay. And did she tell you who took her 15 regarding the frivolous hearsay objections, you 15 to Mr. Epstein's home? 16 seem to forget that this deposition has been 16 MR. PIKE: Form. 17 cross-noticed by several attorneys who are 17 THE WITNESS: I believe, `-I 18 sitting here today. So, as a result you're 18 think it was. 19 taking this deposition, but this is a 19 BY MR. KUVIN: 20 cross-noticed deposition. And as a result I 20 Q. Did she recount to you what-explained 21 have to maintain the form assertions as well as 21 about this visit to Mr. Epstein's home? 22 various privileges for these other individuals 22 MR. PIKE: Form. 23 who are representing several other alleged 23 MR. KUVIN: And if you can't recall, you 24 Plaintiffs in these cases. That's Number 1. 24 can refer to the probable cause affidavit, 25 So, just because you're asking the 25 Pages 19 and 20. Page 176 Page 178 1 questions here today, Mr. Kuvin, maybe you 1 MR. PIKE: Just for purposes of the record 2 should talk to your co-counsel about 2 something else just came to mind is that you 3 cross-noticing these depositions because maybe, 3 said s line of questioning is to your 4 in fact, it is prejudicing your case. That's 4 client h ied case against 5 Number I. 5 Jeffrey Epstein, an has not provided any 6 As Number 2, with regard to his eyewitness 6 sort of information re anve to she being, her 7 accounts, whether or not he observed someone's 7 being your client 8 mental state or whether or not they were in a 8 So, in that regard I also have to assert 9 specific state when he spoke to them, he is not 9 form and preserve. 10 an expert. So, you andllcnow, you and I try 10 MR. KUVIN: She will. 11 several cases, and we know good and well that 11 MR. PIKE: I know. 12 police officers are not‘xpcilb when it comes 12 BY MR. KUVIN: • 13 to the psychological state and mental condition 13 Q. Okay. Did she explain what Ms. old 14 - of a particular person on a particular time or 14 her about the visit to Mr. Epstein's home? 15 a particular day, how did they feel, how did 15 k Ifl can refer to the — 16 they look, you know, layperson observations. 1.6 Q. Please do. 17. But how did they feel, their mental state, I am 17 MR. PIKE: Form. 18 going to preserve the form. 18 THE WITNESS: She was to model lingerie 19 MR. KUVIN: Okay. 19 . for a wealthy person in Palm Beach. 20 MR. PIKE: Thanks. 20 BY MR. KUVIN: 21 BY MR. KUVIN: 21 Q. Okay. Was there any notice given 22 Q. With respect to this July 9,2006, 22 according to what Ms. told you that she would 23 interview that you took of C.I.. did she provide to 23 have to get naked or doing anything sexual? 24 you the date of her birth? 24 MR. PIKE: Form.. 25 MR. PIKE: Form. 25 13 (Pages 175 to 178) PROSE COURT REPORTING AGENCY, INC; :(5'61) 832.7506 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a6ddb-ta81 -4116-b3b7-dcda51494142 EFTA00298306 Pagc: Page 181 1 BY MR. KUVIN: 1 THE WITNESS: Yes, he did. 2 Q. And you can refer to your tcpo, t if you 2 BY MR. KUVIN: 3 don't recall. 3 Q. Where? 4 A. Ism going to have to refer. 4 A. I believe he stroked her vagina. 5 Q. That's fine. 5 Q. Do you recall whether she discussed if he 6 A. It was some time ago, so... 6 touched her breasts as well? 7 Q. When described what she was supposed 7 MR. PIKE: Form. 8 to do at the home of Mr. Epstein, was there any 8 THE WITNESS: He may have. I'm trying to 9 discussion about being naked or having a massage or 9 recall. I believe so. 10 anything like that? 10 BY MR. KUVIN: 11 MR. PIKE: One second becaace I don't 11 Q. Okay. What did she tell you Mr. Epstein 12 understand the question. When MI described 12 was doing during this massage? 13 to or to Detective Recarey? 13 MR. PIKE: Form. 14 MR. KUVIN: Correa. 14 ME WITNESS: Masturbated. 15 BY NIR. KUVIN: 15 BY MR. KUVIN: 16 Q. When= talked to. about what to 16 Q. Did he, did she tell you whether he 17 expect at Mr. Epstein's home, was there any 17 ejaculated eventually? 18 discussion about getting naked initially? 18 MR. PIKE: Form. 19 MR. PIKE: Form 19 THE WITNESS: I believe he did. 20 THE WITNESS: Not initially. 20 MR. PIKE: And leading. 21 BY MR. KUVIN: 21 BY MR. K Silk: 22 Q. All right. What clic=tell you 22 Q. Did •'scuss anything with you about 23 happened when she got at the home, got to the home? 23 threats made . Epstein to hell 24 MR. PIKE: Form. 24 MR. PIKE: Form. That would be double 25 THE WITNESS: I believe the private chef 25 hearsay. Page 180 Page 182 1 prepared dinner for them. At the conclusion of 1. /vM. KUVIN: Actually double admission, so 2 dinner, they went upstairs to do the massage. 2 it comes in. 3 (Mr. Epstein left the deposition room.) 3 MR. PIKE: Well, only now you bring up 4 S: And that was the time that I 4 another whole point which is why I keep 5 believe anted of this massage. 5 objecting to form, just so the record is clear 6 BY MR. KUVIN: 6 is only admissions against interest are 7 Q. And how did-initially react to that? 7 admissible, and you have been talking about 8 MR. PIKE: Form. 8 your client and other alleged victims. And I 9 THE WITNESS: She had ask why they 9 haven't heard any admissions — or let me not 10 were going to do the massage instead 10 identify them — but I haven't heard you 11 modeling. 11 specifically identify admissions against 12 BY MR. KUVIN: 12 interest to survive my form objection. So you 13 Q. . All right MIN have to get or did 13 can proceed. 14 she get undressed according to her? 14 MR. KUVIN: It's actually a commonly 15 A. Yes, she did. 15 misinterpreted concept in the law. And it's 16 MR. PIKE: Form. 16 not admission against interest. It's actually 17 BY MR. KUVIN: 17 admission by a party opponent. Under the 18 Q. And did she tell you whether or not she 18 Florida Rules it doesn't have to be against 19 gave Mr. Epstein a massage while he was naked? 19 interest, but we can research that later. 20 MR. PIKE: Form. 20 BY MR. KUVIN: 21 WE WITNESS: Yes. 21 g All right With respect to Mr. Epstein's 22 BY MR. KUVIN: 22 threats did Mr. Epstein, did -- let me clarify. Did 23 Q. Did she explain to you whether Mr. Epstein 23 say whether Mr. Epstein threatened her after 24 touched her? 24 the massage took place? 25 MR. PIKE: Form. 25 MR. PIKE: Form. 14 (Pages 179 to 182) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb.fa81-466-b3b7.dcda51494142 EFTA00298307 Page 183 Page 185 1 THE WITNESS: She stated that if she spoke 1 THE WITNESS: Well, she, when she went she 2 of this to anyone, bad things could happen 2 was 15. 3 BY MR. KUVIN: 3 BY MR. KUVIN: 4 Q. Did Ms.. tell you that she was afraid? 4 Q. Okay. The second time she went though, 5 MR. PIKE: Form. 5 did she describe that it occurred, you know, a year o THE WITNESS: Yes. 6 later, weeks later, a month later? 7 BY MR. KUVIN: MR. PIKE: Form. 8 Q. Did she explain why she was afraid? THE WITNESS: I'm trying to recall. I 9 MR. PIKE: Form. don't believe it was hie a year later. It was 10 THE WITNESS: Yes, she did. She explained 10 more. lam trying to recall exactly. Could 11 that because he was very wealthy, you know, 11 have been a week, two weeks, a month. I'm not 12 that he could pay someone to hurt her or her :2 100 percent certain but I know it wasn't a year 13. family. 13 later. 14 BY MR. KUVIN: 14 BY MR. KUVIN: 15 Q. Did Ms explain whether or not she 15 Q. All right. So, did you determine how old 16 received any atonal contact from Mr. Epstein or 16 she was that second time she returned? 17 one of his agents? 17 MR. PIKE: Form. 18 MR. PIKE: Form. 18 BY MR. KUVIN: 19 THE WITNESS: I believe she went another 19 Q. In other words was she still 15? Had she 20 time to the house. 20 turned 16 by then? 21 BY MR. KUVIN: 21 MR. PIKE: Form. 22 Q. All fight. If you wovulel ice a look at 22 THE WITNESS: I can't recall without 23 Page 20 of 22. It says here: stated that 23 looking at the report 24 sever he recei a telephone call 24 MR. KUVIN: Take a look if you would. 25 from MEM who coordinated for= to return 25 MR. PIKE: And just so we're clear, while Page 184 Page 186 to, quote, work Do you see that? 1 he is looking, the other issue I have is that a 2 A. Yes. 2 lot of these questions, for instance the first 3 egjaii ever able to verify and document 3 time, the second time, the third time, it deals 4 that actually contacted.by 4 with not onlyIII but in some of your 5 telephone records? 5 questions these deal with other third parties 6 were obtained 6 and there is no predicate or foundation having 7 8 Il ranced joilt ne lerdsduring the investigation. I believe that, yes, through the — I believe I remember 7 8 been laid relative to the dates these individuals actually or allegedly came to the seeing individual girls' cellphone numbers off 9 home. 10 cellphone record. 10 So, then the follow-up question of how did 11 Q. Okay. 11 you determine how old they are, ! don't believe 12 MR. PIKE: Form, move to strike. 12 the proper predicate is there. So, that's 13 BY MR. KUVIN: 13 another basis. I mean, you asked, right? 14 Q. And did Ms.Mreturn, did she tell you 14 MR. EDWARDS: Predicate is there to 15 that she returned to Mr. Epstein's home — 15 detennine her age at the time; is that what you 16 MR. PIKE: Form. 16 are saying? 17 BY MR. KUVIN: 17 MR. PIKE: Yes, proper predicate had not 18 Q. — a second time? 18 been laid. 19 A. Yes. I believe so. 19 BY MR. KUVIN: 20 Q. The second time that she returned to the 20 Q. All right. With respect to the second 21 home, was she still a minor? In other words, how — 21 time she went to the home, let's talk about that: 22 well, let me ask it this way: When she returned 22 Did you determine how old she was the second time 23 according to her to Mr. Epstein's home, how old was 23 she came to the home? 24 she? 24 A. It would have been several days later. 25 MR. PIKE: Form. 25 MR. PIKE: Form. 15 (Pages 183 to 186) (561) S32-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5cldb-fa81-4116.b3b7,dcda51494142 EFTA00298308 Page Page 189 1 BY MR. KUVIN: 1 MR. PIKE: Form. 2 Q. And what occurred during this second time 2 BY MR. KUVIN: 3 she was at the home — 3 Q. What was her demeanor dining this 4 MR. PIKE: Form. 4 interview with you? 5 BY MR. KUVIN: 5 A. She was scared. She was nervous. Obviously 6 Q. —according to her? 6 she was still crying. 7 A. She returned to the home wittMand another 7 Q. If we look at Page 21. You met with a 8 massage was conducted. 8 gentleman by the name of Alfredo Rodriguez -- 9 Q. All right. And did this massage involve 9 A. Yes. 10 Mr. Epstein again getting naked? 10 Q. — who was the houseman? 11 A. Correct. 11 A. Yes. 12 MR. PIKE: Form. 12 MR. PIKE: Form. 13 BY MR. KUVIN: 13 BY MR. KUVIN: 14 Q. Did this massage, according to her, 14 Q. Have you come to learn recently that he 15 involve any touching by Mr. Epstein of ha? 15 was arrested by federal authorities? 16 MR. PIKE: Form. 16 A. Correct 17 THE WITNESS: Yes. 17 Q. Did you also come to learn recently that 18 BY MR. KUVIN: 18 he has pled guilty? 19 Q. Where did she tell you that Mr. Epstein 19 A. I have not seat I heard it. It was in, I 20 touched her? 20 guess, the news either last night or this morning. 21 MR. PIKE: Form. 21 Q. Do you know what he pled guilty to? 22 THE WITNESS: She informed me that her 22 A. No. 23 vagina was touched digitally while he was 23 Q. Are you aware that — well, when you met 24 masturbating. 24 with him, did he explain to you whether or not he 25 25 had any telephone books or telephone logs or any Page 188 Page 190 BY MR. KUVIN: 1 kind of information of girls that had come to the Q. Okay. Did she describe during the second 2 home? 3 time whether or not Mr. Epstein climaxed? 3 MR. PIKE: Form. 4 MR. PIKE: Form. 4 MR. KUVIN: Documents in other words. 5 THE WITNESS: Yes, she did. 5 THE WITNESS: When I spoke with him, he 6 BY MR. KUVIN: 6 had advised that he had a, originally he stated 7 Q. And did she recount for you whether or not 7 journal. But what he provided me was a green 8 Mr. Epstein made another threat to her at the 8 folder with different pieces of papers inside 9 conclusion of this massage? 9 the folder. 10 MR. PIKE: Form. Who are we talking 10 BY MR. KUVIN: 11 about? 11 Q. Did he ever give you any kind of a journal 12 MR. KUVIN: 12 or binder of names? 13 THE WITNESS: Yes. 13 A. No. 14 BY MR. KUVIN: 14 Q. Are you aware as you sit here today that, 15 Q. What did she tell you? 15 in fact, he did possess such a journal of names? 16 MR. PIKE: Form. 16 A. Yes, I did. 17 ME WITNESS: She said that she was not to 17 MR. PIKE: Form. 18 speak of this to anyone; bad things could 18 BY MR. KUVIN: 19 • haPPen. 19 Q. How did you team that? 20 BY MR. KUVIN: 20 MR. PIKE: Form. 21 • Q. When you talked to her, was she afraid, 21 THE WITNESS: I read it through the 22 bless you, was she afraid that Mr. Epstein would do 22 newspapers. 23 something to her or her family? 23 BY MR. KUVIN: 24 A. Yes. She was afraid that someone would hurt 24 Q. Did you ever see that journal? 25 either her or her family. 25 A. No. 16 (Pages 187 to 190) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia honking (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-fa81-4f16-b3b7-dcda51494142 EFTA00298309 Page 193. Page 193 1 MR. PIKE: Form. 1 has flipped through that document les not a 2 MR. KUVIN: Let me show you a stack of 2 big deal. You can mark it as an exhibit. It 3 message books that were apparently — well, let has none of your attorney notes on it, none of 4 me ask you about them. It's all of them. your work product on it. It's been in the 5 (A discussion was held off the record.) witness's possession, and as a result, I am 6 BY MR. KUVIN: entitled to it pursuant to the law. 7 Q. Ni going to show you a stack first and 7 MIL KUVIN: This is Mike Pike on the law. 8 then what I'll do is I'm not going to mark the 8 MR. PUCE: Well, then this is what I am 9 entire stack, but I will pull out individual ones so 9 going to instruct you to do, preserve that 10 I'll ask you about them. Just take a look at the 10 document in whole. 11 stack of documents I am showing you. 11 MR. KUVIN: Sure. 12 Do you recognize what it is? And if you 12 MR. PIKE: Mark it as an exhibit in whole, 13 do, then if you could just describe it for us. 13 preserve it Okay. 14 A. These are copies of the, some of the phone 14 MR. KUVIN: Why don't you just do a 15 pads, of phone message pads taken from the home. 15 request to produce the phone logs if you don't 16 Q. Okay. Let me take it and I will just ask 16 have these already? 17 you some individual questions. 17 MR. PIKE: Why should I wait 30 days for 18 MR. PIKE: One second. I want that entire 18 something? I don't know exactly what's in 19 document marked as an exhibit And it's clear 19 there, Mr. Kuvin. There could be -- I could 20 that the witness just refreshed his 20 have all of that in full. I 'could be missing 21 recollection based upon your past questioning 21 one document I don't know what it is that you 22 regarding trash pulls and documents that were 22 have. So, if you just want to move forward, 23 allegedly taken from the home. 23 you can move forward and you can mark the 24 So, I want that entire — he has looked at 24 document, or I am going to move to strike 25 it. Ifs in his possession. I want the entire 25 because you haven't marked it as an exhibit. Page 192 Page 194 1 document, put a clip on it and have the court 1 MR. KUVIN: You do whatever you feel 2 reporter mark it. 2 appapriate. 3 MR. EDWARDS: Are you talking about the 3 BY MR. KUVIN: 4 Page I that he looked at? 4 Q. Do you ver come to learn who a woman was 5 MR. PUCE: He didn't just look at Page 1. 5 by the name of 6 You should ask him that. He's flipping through 6 A. No, I ' not 7 the documents. 7 Q. What about a Dr. Jarecki, J-a-r-e-c-k-i, 8 MR. EDWARDS: Every single page? We had 8 did you ever learn who that was? 9 this discussion in your client's deposition as 9 A. No. 10 well. 10 Q. What about a Jane Doe, (Spells first 11 MR. PIKE: Yeah, that was my 11 name). 12 attorney-client work product for that witness. 12 A. No. Some people were not identified off those 13 So I just want the document marked. That's 13 phone logs. 14 all. 14 Q. Okay. It appears that some of the phone 15 KUVIN: It's not going to be turned 15 logs are, the names of the individuals are whited 16 over. It's my document. 16 out. Was that done at some point by the department? 17 MR. PIKE: The witness has just looked at 17 MR. PIKE: Form. 18 it. 18 THE WITNESS: No, nothing was ever whited 19 MR. KUVIN: He looked at the first couple 19 out 20 pages, so I am not turning it over. I am 20 BY MR. KUVIN: 21 turning over the documents that I marked from 21 Q. On the phone logs, no? 22 my stack of documents. 22 A. No, not by me. 23 MR. PUCE: Thai I am going to move to 23 Q. Okay. Did you ever come to learn who the 24 strike every question relative to the documents 24 gentleman by the name of Jean Luc was? 25 that the witness looked at. The witness 25 A. Jean Luc had a modeling enc , I believe. 17 (Pages 191 to 194) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkIns (601 aa2a5ddb-fa81-4ff6-b3b7-dcda51494142 EFTA00298310 Page 195 Page 197 1 MC2. 1 Q. Let me take a quick look. 2 Q. Did you ever determine whether or not 2 A. 1 don't know if you saw this one. 3 there was any connection between Mr. Epstein and 3 Q. Let me take a quick look. All right. 4 that modeling agency of MC2? 4 Just so the record is clear, this message appears to 5 MR. PIKE: Form. 5 say: Ile has a teacher for you to teach you how to 6 THE WITNESS: I recall a phone message, 6 speak Russian. She is two times eight years old. 7 duplicate phone message to Mr. Epstein from 7 Not blonde. Lessons are free, and you can have 8 Jean Luc which said I have a girl for you and 8 first today if you call." Did I read that 9 then it had two times eight. 9 correctly? 10 MR. KINN: Let me see if I can find that 10 MR. PIKE: Form. 11 one. 11 THE WITNESS: That is correct. 12 MR. PIKE: Form to that, the other 12. BY MR. KUVIN: 13 question. 13 Q. Okay.- Did you ever determine what that 14 MR. KUVIN: This one I will mark. 14 meant? 15 MR. PIKE: Well, I just want it clear for 15 MR. PIKE: Form. 16 the record that there is a difference between 16 THE WITNESS: I never spoke with Jean Luc 17 looking at a document and refreshing your 17 but it appears that two times eight is 16. 18 recollection on a document. And it's clear 18 BY MR. KUVIN: 19 under Florida Jur. 19 Q. Could it mean two 8-year-old girls? 20 So, what I would like you to do, 20 MR. PIKE: Form, move to strike the 21 Mr. ICuvin, before you categorize these 21 witness's testimony. • 22 documents, is I would like you to mark this 22 . MR_ EDWARDS: He hasn't said anything yet 23 document in full. You can keep it in your 23 MR. PIKE: Two times eight equals 16. You 24 possession. All right And then we can talk 24 didn't hear him say that I don't thinlc you 25 about it later instead ot you know, marking 25 did, and I move to strike it. Page 196 Page 198 1 several different documents. 1 Mr. Edwards, this is, if you, if you find 2 Maybe it would be easier if you just 2 something funny here, then maybe we can take a 3 marked it and we took it up with the cote 3 4 later. Otherwise you're going to, you're going 4 MR EDWARDS: You're striking things that 5 to kind of mess with the structure of the 5 were not said, funny. 6 document as the witness has utilized to refresh 6 MR. PIKE: You didn't hear something said 7 his recollection. 7 and it was said. I move to strike it. 8 MR. KUVIN: Okay. I appreciate your 8 MR. EDWARDS: It was the previous 9 objection. 9 ' question. I get it. I'm with you. 10 (Plaintiffs Exhibit No. 6 was marked for 10 MR PIKE: Were going to take a break. 11 identification.) 11 Mr. Edwards needs a break, because there is, by 12. BY MR. KUVIN: 12 no stretch of the imagination — lam not here 13 Q. Him going to give you what1marked as 13 all day to hear Mr. Edwards laugh over there in 14 Exhibit 6. Is that the message that you're 14 the corner trying to do a job. 15 referring to? 15 MR. KUVIN: To that extent I am not here 16 A. Yes. 16 to hear Mr. Epstein laugh about questions that 17 Q. And that message or that photocopy page 17 I am asking either. But he is over here 18 appears to have four messages in it; is that 18 snickering, and I don't mention it every time 19 correct? 19 he snickers at one of the sexual questions that 20 MR. PIKE: Form. 20 I ask. 21 THE WITNESS: Correct. 21 MR. EDWARDS: I was laughing because I 22 BY MR. KUVIN: 22 thought you were objecting to the witness's 23 Q. Where does the message you're referring to 23 answer and he hadn't yet answered. I 24 appear on the document? 24 understand now. You're objecting to the 25 A. Top left. 25 vious answer then fine. 18 (Pages 195 to 198) PROSE COURT REPORTING - AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a6eldb.ta81-4H6-b3b7-dcda51494142 EFTA00298311 Page 199 Page 201 1 MR. PIKE: Lets just take a break 1 make the record clear you spoke to 2 MR. EDWARDS: I'm fine. 2 Ms. O'Connor, correct, at the beginning of 3 MR. PIKE: Let's take a break and everyone 3 today? 4 can gather their senses and everyone can get MR. KUVIN: It was actually a discussion 5 back to doing their job on each side of the 5 with Kathy Ezell as to whether or not they 6 table: 6 would get to her, and that's where the 7 (A brief recess was held.) 7 discussion went 8 MR. KUVIN: Are you ready? C MR. PIKE: I just want to make sure that 9 MR. PIKE: Let's go back on the record. discussion wasn't with me, because I am here 3.0 Mr. Kuvin, do you have any idea how much 10 for as long as it takes to get everyone done. 11 longer? I am trying to get an idea as to 11 But it's clear that I guess Ms. O'Connor and 12 whether or not we want an opportunity to 12 the witness need to be done at 5. So, 5 is 5. 13. question the witness today. And there are 13 MR. EDWARDS: Right And given that it's 14 other lawyers. I know Mr. Edwards wants an 14 already pretty late, I know that we're not 15 opportunity to go after you, Pm sure. . 15 going to get it done, so that's why — 16 I don't know if Ms. Finnigan is going to 16 MR. PIKE: Understand. 17 be asking questions or Ms. Arbour. 17 MR. EDWARDS: Do you want to ask 18 So, I would like to get an idea as to how 18 questions, that's fine, whatever. 19 much time you have and then Mr. Edwards and 19 MR. PIKE: Can I speak with my client for 20 Ms. Finnigan and Ms. Arbour. 20 a minute? 21 MR. KUVIN: I'm almost done. I'm going to 21 MR. EDWARDS: Let's take two minutes. 22. go through some of the messages and then I have 22 MR. PIKE: Just while we're still on the 23 got some probation violation stuff I want to 23 record, Mr. Kuvin, you have agreed not 24 talk about. So, once I am done with that, I 24 necessarily today but with regard to the 25 should be about done. 25 message pads, you have agreed to go ahead and Page 200 Page 202 1 And then I don't know, we can talk about 1 flip through them. I don't know — 2 this, whether or not you-all can go before the 2 MR. KUVIN: I have agreed, you're going to 3 rest Of the Plaintiffs go. I don't know their 3 get a copy of them all. 4 feelings on that, but we'll leave it up to 4 MR. PIKE: I am going to get a copy of 5 them. 5 them all? 6 MR. PIKE: We're fine with letting them 6 MR. KUVIN: Yes. 7 go. 7 MR. PIKE: Thank you. 8 MR. EDWARDS: I am going to try to make 8 (A discussion was held off the record.) 9 this easy for you. I think we talked earlier 9 MR. PIKE: We are going to go back on the 10 that the deposition has to end today at 5. And 10 record. 11 given those parameters, there is no way that I 11 MR. KUVIN: Okay. 12 can get through my questions. We're going to 12 MR. PIKE: We're going to just go ahead 13 need a second day for this deposition anyway. 13 and follow foam with regard to the Plaintiffs 14 I am assuming that it's because 14 finishing, and we'll come back later on. 15 lit Weinberg is down from Massachusetts today 15 MIL KUVIN: Okay. 16 and he wants to ask questions. I don't care 16 MIL PIKE: That way you guys can keep that 17 what order I go in. 17 order going. • ' 18 So, if you want to ask questions next, 18 MIL KUVIN: All light. Just keep the 19 that's perfectly fine with me. It doesn't 19 phone stuff separate because I only have one 20 really matter. Whatever is easiest. I am 20 copy of that and I just want to make sure I 21 amenable to whatever your suggestion is. That 21 -don't lose it. 22 really is fine. 22 THE WITNESS: Okay. 23 MR. PIKE: hut for the record when you 23 MR. KUVIN: Lefinext Mark this one as 7. 24 say you spoke to, when you said you spoke 24 That's the next one I am going to ask him 25 recarxiine the deposition ending at 5, just to 25 about. —4 19 Rages 199 to 202 ?ROSE COURT REPORTING AGENCY, INC. • Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia bodkins (601 aa2a5ddb-la81-4116.1,3b7-dcda51494142 EFTA00298312 Page 203 Page 205 BY MR. KUVIN: 1 A. No. 2 Q. And while they are looking at that one, 2 MR. KUVIN: This is what we'll mark as 8. 3 let me ask you about the last one we were talking 3 (Plaintiffs Exhibit No. 8 was marked for 4 about which is Exhibit 6. Jean Luc Brunel, did you 4 identification.) 5 ever establish any, or did you ever determine 5 BY MR. KUVIN: 6 whether there was any connection between Mr. Brunel 6 Q. All right. Take a look at what I've 7 and John Casablancas? Did that name ever ring a 7 marked as Exhibit 8 with two messages on the 8 bell? 8 right-hand side. Let me ask you about those for a 9 A. No. I have heard of the modeling firm. 9 moment. Do you see one there from David 10 Q. Eight. 10 Copperfield? 11 A. But, no, no connection. 11 A. Yes. 12 Q. That you were able to determine? 12 Q. What does it say in the text of the 13 A. Right. 13 message? 14 Q. Okay. With respect to Mr. Brunel, did you 14 A. "Magic David called." 15 ever determine whether or not Mr. Brunel had ever 15 Q. Did you come to learn that this was, in 16 stayed at Mr. Epstein's home on occasion? 16 fact, David Copperfield the magician? 17 A. I can't recall. 17 A. Yes. 18 Q. Did you ever determine whether or not 18 Q. When you went through the phone message 19 Mr. Brunel was present when any underage girls were 19 pads did you find a number of messages from 20 performing sexual acts for Mr. Epstein? 20 Mr. Copperfield to Mr. Epstein? 21 MR. PIKE: Form. 21 A. Yes. 22 THE WITNESS: Not that I'm aware of. 22 MR. PIKE: Form. 23 BY MR. KUVIN: 23 BY MR. KUVIN: 24 Q. Did you ever determine whether or not 24 Q. Did you become aware during the 25 Mr. Brunel was, in fact, providing underage girls to 25 investigation that Mr. Copperfield was, in fact, Page 204 Page 206 1 Mr. Epstein — 1 charged with raping a girl? 2 MR. PIKE: Form. 2 MIt PIKE: Form. 3 BY MR. KUVIN: 3 THE WITNESS: I recall reading through the 4 Q. - for sexual activities? 4 media that I know that they executed search 5 MR. PIKE: Same objection. 5 warrants either at his home or hotel room, one 6 THE WTINESS: Based on the phone message 6 or the other. 7 it appears that it may be someone. 7 BY MR. KUVIN: 8 BY MR. KUVIN: 8 Q. Okay. Did you learn that prior to this 9 Q. Anything else other than Exhibit 6? 9 investigation or did that, is that something you 10 MR. PIKE: Wait one second. Move to 10 learned subsequent to this pending investigation? 11 strike witness's last testimony as 11 MR. PIKE: Form. 12 nonresponsive, and then form to Mr. Kuvin's 12 THE WITNESS: It was during the 13 follow-up question. 13 investigation. 14 MR. KUVIN: You can answer. 14 BY MR. ICUVRsl: 15 'IRE WITNESS: Outside of the phone 15 Q. Did you ever have conversations with the 16 message, no. 16 federal authorities about Mr. Copperfield that you 17 (Plaintiffs Exhibit No. 7 was marked for 17 can recall? 18 identification.) 18 A. Not that I can recall. 19 BY MIt KUVIN: 19 Q. Okay. Do you recall whether or not you 20 Q. All right. Let me show you what we have 20 learned about the federal investigation regarding 21 marked as Exhibit 7. There appears to be three 21 Mr. Copperfield before or after the Feds took your 22 messages regarding someone with the last name 22 information of Mr. Epstein's investigation? 23 Meister. Do you see those? 23 (Mr. Goldberger entered the deposition 24 A. Yes. 24 room) 25Sfinesvho that was? 25 THE WITNESS: I want to saz it was just 20 (Pages 203 to 206) PROSE COURT REPORTING AGENCY, INC.. Electronically signed by cynthia hopkins (801 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 sa2a5ddb•fa81-41f6-b3b7-dcda51494142 EFTA00298313 Page 207 Page 209 after. 1 MR. PIKE: Form. 2 MR. KUVIN: Okay. 2 THE WITNESS: Not really. i didn't get 3 THE WITNESS: Just after everything was 3 involved in any of the political aspects of 4 given to the FBI. 4 that. 5 BY MR. KfJViN: 5 BY MR. KUVIN: 6 Q. Do you know whether or not the FBI 6 Q. Okay. Do you recall ever having any 7 utilized any of the information that they may have 7 conversations directly with Mr. Goldsmith about the 8 obtained from your investigation such as message Epstein case? .. 9 pads in the prosecution of Magician David 9 A. No. 10 Copperfield? 10 MR. KUVIN: Okay. This is 10. 11 A. I have no idea. 11 (Plaintiffs Exhibit No. 10 was marked Ihr 12 Q. Do you know whether or not Mr. Epstein and 12 identification.) 13 Mr. Cooperfield were, in fact, sharing underage 13 BY MR. KUVIN: 14 girls for sexual acts? • 14 Q. All right. Let me show you what we marked 15 MR. PiKE: Form. 15 as Exhibit 10. There mars to be a message there 16 THE WITNESS: I do not know. 16 from someone named Do you see that? 17 BY MR. KUVIN: 17 A. Yes. 18 Q. Do you know whether or not Mr. Epstein and 18 Q. What's the date of that message? 19 Mr. Copperfield were, in fact, sharing information 19 A. March, it looks Bice 19th of '05. 20 about girls for sexual acts? 20 MR. PIKE: Form. 21 MR. PIKE: Form. 21 MR. KUVIN: What is wrong with the form? 22 THE WITNESS: That 1 don't know. 22 MR. PIKE: That's what the message pad 23 BY MR. KUVIN: 23 says. Whether or not it came through or not, 24 Q. Did you ever interview Mr. Copperfield? 24 I'm not sure. 25 A. No. 25 MR. KUVIN: Okay. Page 208 Page 210 Q. All right. 1 MR. PIKE: Form. 2 MR. PiKE: May I see Exhibit 7? Just give 2 BY MR. KUVIN: 3 me one second, Spencer, before you start. 3 Q. Okay. Could you take a look for me at 4 MR. KUVIN: Sure. 4 Exhibit 1 which is the PC affidavit. 5 MR. PiKE: Can i see 6? Thank you. 5 A. Yes. 6 MR. KUVIN: No problem. 6 Q. And tell us, if you would remind us again 7 (Plaintiffs Exhibit No. 9 was marked for 7 what was the date that the investigation of 8 identification.) B Mr. Epstein began? 9 BY MR. KUVIN: 9 A. -March 15th. 10 Q. Here is 9. All right. Take a look at 10 Q. Of? 11 Exhibit 9. It appears to be a message there from 11 A 2005. 12 Jerry Goldsmith. Do you see that? 12 Q. This message from occurred according 13 A. Yes. 13 to the document, occurred when? 14 Q. Do you know who that is? 14 A. March 19th, 2005. 15 A. He is a town resident. 15 Q. All right. And what was the message that 16 • Q. Do you know whether he ran for office in 16 was taken down and written on that phone message 17 the Town of Palm Beach. 17 pad? 18 • A. Yes, he did. He ran for mayor. 18 A "She will be here at 4:00 p.m. but she needs 19 Q. And during the deposition with Chief 19 to talk to you before that. Please call her back." 20 Reiter in this case, Chief Reiter testified that he 20 MR. PIKE: Form. 21 had some communications with Mr. Goldsmith about 21 BY MR. KUVIN: 22 Mr. Epstein. 22 Q. Did you ever come to learn what- 23 And my question to you is do you know 23 wanted to talk to Mr. Epstein about just days after 24 anything about those conversations that may have 24 the investigation began of him? 25 taken lace? 25 A. No. 21 (Pages 207 to 210) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801 Electronically signed by cynthia hopkins (801 Electronically signed by cynthia hopkins (801 sa2a5ddb-fa81-4f16-b3b7-dcda51494142 EFTA00298314 Page 21i Page 213 1 MR_ KUVIN: This one is II. 1 A. April 1st, 2005. 2 (Plaintiffs Exhibit No. 11 was marked for 2 Q. Had the investigation begun against 3 identification.) 3 Mr. Epstein at that time? 4 BY MR. KUVIN: 4 A. Yes. 5 Q. While they are looking at that, were these 5 Q. Do you know why Mr. Goldsmith, did you 6 message pads taken from Mr. Epstein's home during 6 ever learn why Mr. Goldsmith was contacting 7 the search warrant? 7 Mr. Epstein about a month after the investigation 8 A. Correct. 8 began? 9 MR. PIKE: Form. 9 MR. PIKE: Form. 10 BY MR. KUVIN: 10 THE WITNESS: No, I did not. 11 Q. And what was done with them when they were 11 BY MR. KUVIN: 12 taken from his home? In other words once they were 12 Q. .Did you ever get a chance to talk to 13 taken into custody, what did you-all do with them? 13 Mr. Goldsmith about the Epstein investigation at 14 A. We reviewed them for evidentiary purposes. 14 all? 15 Q. Okay. 15 A. No, I did not. 16 A. Provided the State Attorney's Office with a 16 MR. KUVIN: Exhibit 13. 1.7 copy; obviously, with the filing packet for the arrest 17 (Plaintiffs Exhibit No. 13 was marked for 18 warrants, and eventually turned over to the FBI. 18 identification.) 19 Q. Okay. All right. Take a lookat Exhibit 19 BY MR. KUVIN: 20 11. It appears to be a message from Jean Luc again. 20 Q. Let me show you Exhibit 13. Does that 21 Take a look at that message. 21 appear to be another message by Mr. Goldsmith on 22 A. Okay. 22 that message pad? 23 Q. Did you ever determine whether or not 23 A. Correct. 24 Mr. Epstein ever had any sexually transmitted 24 Q. What is the date of that message? 25 diseases? 25 MR. PIKE: Form. Page 212 Page 214 1 MR. PIKE: Form. 1 THE WITNESS: 12/4/04. 2 THE WITNESS: I was not aware. 2 BY MR. KUVIN: 3 BY MR. KUVIN: 3 Q. This was before the investigation began? 4 Q. Okay. Let me take a look real quick at 4 A. Coffees. 5 Exhibit 11. There was something in this note that 5 Q. And Exhibit 14, while they are looking at 6 talks about Mr. Jean Luc speaking to a doctor about 6 that, did you also find that them were messages 7 symptoms which can shorten your sex life. Did you 7 from Mr. Leslie Wexner contained within the message 8 see that in the message? 8 pad at Mr. Epstein's home? 9 A. Yes, I did. A. Yes. 10 MR. PIKE: Form. 10 Q. Did you come to learn who that was? 11 BY MR. KUVIN: 11 A. Yes 12 Q. Were you ever able to determine what he 12 MR. PIKE: Form. 13 was talking about in that. message? 13 BY MR. KUVIN: 14 MR. PIKE: Form. 14 Q. Who? 15 THE WITNESS: No. 15 MR. PIKE: Form. 16 MR. KUVIN: All right. Exhibit 12. 16. THE WITNESS: He is the CEO of Express, 17 (Plaintiff's Exhibit No. 12 was marked for 17 Victoria Secrets. 18 identification.) 18 BY MR. KUVIN: 19 BY MR KUM: 19 Q. Okay. Did you ever get a chance to 20 Q. Does this appear to be more messages from 20 interview Mr. Wexner? 21 Mr. Goldsmith? 21 A. No. 22 A. Correct 22 MR. KUVIN: Exhibit 14. 23 Q. Are those dated at all? 23 (Plaintiffs Exhibit No. 14 was marked for 24 A. One is and one is not. 24 identification.) 25 O. What was the date of the one that is? 25 22 (Pages 211 to 214 (561) 83277500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 ea2a5ddb-fa81.4n6-b3b7-dcda51494142 EFTA00298315 Page 215 Page 217 1 BY MTh KUVIN: in the operation of the modeling agency? 2 Q. Take a look at 14. Okay. Does that 2: A. That I don't know. 3 appear to be a another message from Mr. Goldsmith? 3 MR. PIKE: Form. . 4 A. Correct. 4 MR. KUVEN: Okay. Let's mark 16. 5 Q What is the date of that message? 5 (Plaintiffs Exhibit No. 16 was marked for 6 A. The date of the message is 12/14/04. 6 identification.) • 7 Q. Prior to the beginning of the 7 BY MR. KUVIN: 8 investigation? 8 Q. Take a look at Exhibit 16. 9 A. Correct. A. Yes. 10 (Plaintiffs Exhibit No. 15 was marked for 10 Q. What is the date of the message according 11 identification.) 11 to the pad? 12 BY MR. KUVIN: 12 A. 12/9/04. 13 Q. Let me take a look at that real quick. I 13 Q. Before the investigation began? 14 would like you to take a look at what we have marked 14 A Correct. 15 as Exhibit 15 at the top right message. Do you see 15 Q. When you were conducting the investigation 16 that? 16 of Mr. Epstein and interviewing all of these girls 17 A. Yes, sir. 17 that you interviewed; did you learn of events, of 18 Q. AU right. Who does that message purport 18 any events that were occurring involving underage 19 to be from? 19 girls going back into 2004 and 2003? 20 A. Jean Luc. 20 MR. PIKE: Form. 21 Q. And we talked before about Jean Luc. Did 21 BY MR. KUVIN: 22 you come to learn during your investigation whether 22 Q. In other words did all these events that 23 or not he had or worked with a modeling agency? 23 were described in the probable cause affidavit occur 24 MR. PIKE: Form. 24 in 2005 or did they occur prior to that? 25 THE WITNESS: I believe so, ma which was 25 A. They occwred prior to that. Page 216 Page 218 1 the modeling agency. 1 MR. PIKE: Form. 2 BY MR KUVIN: 2 BY MR. KUVIN: 3 Q. Okay. Did you ever learn why the name . 3 Q. Okay. So, is it safe to say that when 4 ?Apr 4 Mr. Goldsmith is calling Mr. Epstein in roughly 5 MR. PIKE: Form. 5 December of 2004, that that period of time is within 6 THE WITNESS: No. 6 the time frame that some of the girls described that 7 :BY MR. KUVIN: 7 Mr. Epstein was bringing underage girls to the 8 Q. Okay. Mr. Epstein's initials are house? 9 • obviously E, right? 9 MR. PIKE: Form. • 10: A. Yes. 10 THE WITNESS: anted. 13. Q. Okay. Do you know what E equal ma means? 11 BY MR. KUVIN: 12 Did you ever hear that phrase before? 12 Q. Did you ever come to learn whether or not 13 A. Yes. 13 Mr. Goldsmith was at Mr. Epstein's home when 14 Q. Okay. Now, with respect to the message in 14 underage girls were there? 15 the top-right corner of Exhibit 15, what is the 15 MR. PIKE: Form. 16 content of the message there? 16 THE WITNESS: That never came up. 17 MR. PIKE: Form. 17 BY MR. KUVIN: 18 THE WITNESS: It says LC2models.com; 18 Q. Okay. Did you ever come to learn why 19 . MC2models can was already taken. 19 Mr. Goldsmith was calling Mr. Epstein so much — 20 BY MR.1CUVIN: 20 MR: PIKE: Form. 21 Q. Okay. Do you know whether or not Jean Luc 21 MR. KUVIN: During this period of time 22 was working on his modeling agency with Mr. Epstein? 22 from December through March. 23 MR. PIKE: Form, speculation. 23 MR. PIKE: I'm sorry. 24 BY MR. KUVIN: 24 BY MR. KUVIN: 25 Q. In other words whether they were partners 25 Q. - from December through March of 2004 and 23 (Pages 215 to 218) . "(561) 832-750.0 PROSE COURT REPORTING AGENCY, INC. •' Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-1081-016-b3b7.dcda51494142 EFTA00298316 Page 219 Page 221 1 2005? 1 BY MR. KUVIN: .2 MR. PIKE: Fomi. 2 Q. Mere are two of them I wanted to ask you 3 THE WITNESS: No. 3 about. The bottom left corner, it's another message 4 (Plaintiffs Exhibit No. 17 was marked for 4 from Mr. Goldsmith, correct? 5 identification.) 5 A. Yes, sir. 6 MR. KUVIN: Let's take a look at 17. 6 Q. What's the date of that — 7 MR. PIKE: Can I see that for a second? 7 MR. PIKE: Form. 8 BY MR. KUVIN: 8 BY MR. KUVIN: 9 Q. Exhibit 17. 9 Q. — according to the message pad? 10 A. She may be gone. 10 A. According to the pad it states January 25th, 11 MR. PIKE: Kathy, are you gone? 11 2005. 12 BY MK KUVIN: 12 Q. And the message to the right, do you see 13 Q. Looking at Exhibit 17, does it appear that 13 that? 14 there was another message from Mr. Goldsmith? 14 A. Above it? 15 A. Yes, sir. 15 Q. To the right. 16 Q. What was the date of that one? 16 A. To the right. 17 MR. PIKE: Form. 17 Q. Do you see how there is a section that 18 THE WITNESS: January 9th, 2005. 18 appears to be whited out? 19 (A discussion was held off the record.) 19 A. Yes, sir. 20 MR. KUVIN: Okay. Let's take a look at 20 Q. Do you remember whether or not the 21 Exhibit 18. 21 original of that actually had someone's name there? 22 (Plaintiffs Exhibit No. 18 was marked for 22 A. It might have. We — I didn't white anything 23 identification.) 23 out. 24 BY MR. KU-VW: 24 Q. Do you know if the State Attorneys may 25 Q. Let me take a quick look and see why I was 25 have whited stuff out? Page 220 Page 222 1 asking about that one. There is a massage there on 1 MR. PIKE: Form. 2 the left from David Copperfield. Do you see that? 2 THE WITNESS: It's possible. I 3 MR. PIKE: Forth. . 3 MR. KUVIN:. Okay. 4 171E WITNESS: Yes, sir. 4 (Plaintiffs Exhibit No. 20 was marked for 5 BY MR. KUVIN: 5 identification.) 6 Q. What's the content of the message? 6 MR. KUVIN: 20. You can put that with the 7. MR. PIKE: Form. 7 rest. THE WITNESS: "It's Jackpot." 8 MR. PIKE: I think Mr. Edwards wanted to 9 BY MR. KUVIN: 9 take a look at that. 10 Q. It's Jackpot, correct? 10 MR. KUVIN: Do you want to see this? 11 A. Yes, sir. 11 (Telephone interruption.) 12 Q. Did you ever come to learn what that might 12 MR. KUVIN: We kept going, sorry. 13 be referring to? . 13 MS. EZELL: No, I want you to. I'm sony. 14 A. No. 14 My phone is just copping out today. 15 Q. What's the date of that message? 15 MR. KUVIN: That's all right We're still 16 A. January 22nd, 2005. 16 going. 17 MR. PIKE: On the pad. 17 MS. EZELL: Good. 18 BY MR. KUVIN: • 18 MR. KUVIN: Take a look at what we have 19 Q. According to the pad, correct? 19 marked as Exhibit 20. 20 A. Yes, sir. 20 THE WITNESS: Yes, sir. 21 MR. KUVIN: Okay. 19. 21 BY MR. KUVIN: • 22 (Plaintiffs Exhibit No. 19 was marked for 22 Q. All right. In the top right corner there 23 identification.) 23 is a message there. Could you tell us what that 24 MR. KUVIN: Let me take a look at it. 24 message according to the pad is? 25 THE WITNESS: Yes. sir. 25 MR. PIKE: Form. 24 (Pages 219 to 222) PROSE COURT REPORTING 'AGENCY, INC. . ' Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 lia2;15ddb-fa81-4ff6-1)3b7-dcda51494142 EFTA00298317 Page 223 1 THE WITNESS: The top right coma is a 1 be an A. 2 message from the Duchess of York. 2 BY MR. KUVIN: 3 MR. PIKE: Kathy, can you hit mute on your 3 Q. Can you tell whether or not ifs the 2 or 4 phone? 4 the letter A? MS. EZELL: I can't on this one. I'm 5 A. It looks like a 2 that I would write so... 6 going to another room. 6 Q. Okay. 7 MR. KUVIN: All right 7 A. I don't know. 8 MS. EZELL: Okay. MR. KUVIN: All right. Fair enough. 9 BY MR. KUVIN: 9 We'll let the document speak for itself on that 10 Q. And the date on that message is what? 10 issue. Let me show you what we'll mark as 22. 11 A. January 25th, 2005. 11 (Plaintiffs Exhibit No. 22 was marked for 12 Q. And is there a number left there? 12 identification.) 13 A. Yes. 13 BY MR. KUVIN: 14 Q. And what's the content of the message? 14 Q. 22 appears to be any additional messages 15 • A. She's expecting your call. 15 according to the pad for Mr. Goldsmith. 16 Q. Did you ever come to learn why the Duchess 16 A. Yes. 17 of York may be contacting Mr. Epstein? 17 Q. Is it Goldsmith or Goldberg? I've 18 A. No. 18 forgotten now. 19 MR. KUVIN: rn show you what we'll mark 19 A. Goldsmith. 20 as Exhibit 21. 20 Q. Goldsmith, thank you. All right. At some 21 (Plaintiffs Exhibit No. 21 was marked for 21 point last year did you come to learn — well, let 22 identification.) 22 me back up. Eventually did you come to learn that 23 BY MR. KUVIN: 23 Mr. Epstein pled guilty to certain charges — 24 Q. If you take a look at Ethibit 21, message 24 A. Yes. 25' on the bottom. It looks like the person who it came 25 Q. — criminal charges — Page 224 Page 226 1 from has been deleted, but is there a date on there? 1 A. Yes, sir. 2 A. Yes, sir. 2 Q. — against him where he was put in jail 3 Q. What's the date according to the pad? 3 fora period of time? 4 A. According to the pad it states 1/29/05. 4 A. Yes, sir. 5 Q. And what is the content of the message at 5 Q. And after that point in time, did you conic 6 the bottom there? 6 to leant that he was on supervised release with 7 A. I have 2 females for him. 7 probation? 8 MR. PIKE: May I see that? 8 MR. PIKE: Fenn. 9 THE WITNESS: Yes, sir. 9 THE WITNESS: Yes, sir. 10 MR. PIKE: I believe that that 10 BY MR. KUVIN: 11 mischaracterizes the language of the exhibit 17. Q. And did you come to leant the terms of 12 Just for purposes of the record, it says: I 12 that probation; in other words what he could or 13 have a female for him. 13 could not do as far as the community control was 14 THE WITNESS: A? 14 concerned? 15 MB. PIKE: There is no Son female. 15 A. I believe it was house arrest. 16 BY MR. KUVIN: 16 Q. All right_ At any time that you can 17 Q. Take a look. Do you agree with that? 17 recall in 2009, did you cornett:deem that 18 MR. PIKE: There is still a form objection 18 Mr. Epstein was not at his house? 19 to the question, so I am not waiving„ and I am 19 MR. PIKE: Form. 20 just correcting the language of the exhibit 20 THE WITNESS: Yes. 21 because it's clear there is no S on the end of 21 BY MR. KUVIN: 22 the word female to make it plural. 22 Q. Tell me about that. 23 MR. KUVIN: And it uses the singular A if 23 A. While driving in the Town of Palm Beach down 24 you wanted to be grammatically correct about 24 along South Ocean Boulevard, I saw Mr. Epstein and his 25 it. I don't know. It could be a 2 or it could 25 bodyguard walking along South Ocean Boulevard along, 25 (Pages 223 to 2 2 6) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkIns (601 Electronically signed by cynthla hopkIns (601 aa2a5ddb-fa81.4ff6•b3b7-dcda51494142 EFTA00298318 Page 227 Page 229 1 along South Ocean Boulevard. 1 MR. PIKE: Form. 2 Q. All right. Did you notify Captain Frick? 2 MR. KUVIN: — on that day? 3 A. I notified my supervisor, Sergeant Silvestri 3 MR. PUCE: Form. 4 who was with Captain Frick at the time. 4 THE WITNESS: I believe he stated he was 5 Q. Okay. Did you take any photographs of 5 walking to work. 6 Mr. Epstein when you saw him? 6 BY MR. KUVIN: 7 A. Yes, sir, I did. 7 Q. Do you knovv how far it is from 8 MR. KUVIN: All right. Let's go ahead and 8 Mr. Epstein's home on El Brillo way to the building, 9 well mark Exhibits 23 and 24. 9 we're at today where he supposedly has an office? 10 (Plaintiff's Exhibit No's 23 and 24 was 10 A. I'd have to say several miles. 11 marked for identification.) 11 Q. Is Ocean Drive in the direction of his 12 BY MR. KUVIN: 12 house and this building here? 13 Q. All right. Take a look at what we have 13 A. No. 14 marked as 23 and 24. Are those copies of 14 Q. Is it, in fact, in the opposite direction 15 photographs that you took? 15 towards the ocean? 16 A. Yes, sir. 16 A. Yes. 17 Q. All right. Do those photographs show 17 Q. And Mr. Epstein's home is on the Bay? 18 Mr. Epstein as you saw him that day? 18 A. On the Intracoastal side. 19 A. Yes. 19 Q. Gotcha. Based on where you saw 20 Q. And where did you see him? 20 Mr. Epstein walking, did you believe that this was a 21 A. This was taken in the area of Australian 21 violation of his probation? 22 Avenue and South Ocean Boulevard. 22 MR. PIKE: Form. 23 Q. Okay. South Ocean Boulevard being along 23 THE WITNESS: That's what I had thought 24 the ocean? 24 which is why I notified my supervisor. 25 A. Yes. Asa matter of fact I was standing right 25 Page 228 Page 230 1 on the ocean wall when this one was taken. 1 (Plaintiffs Exhibit No. 25 was marked for 2 Q. That one being 24? 2 identification.) 3 A. Correct. 3 BY MR. KUVIN: Q. Did Mr. Epstein see you taking the 4 Q. All right. Let me show you what we have 5 photographs as far as you know? S marked as Fathibit 25. • 6 A. I have no idea. 6 MR. PIKE: Wait a second. Did you fmish 7 Q. Okay. Was there a memorandum to the town 7 your response? 8 that was issued as a result of this incident? 8 THE WITNESS: Yes. 9 A. I know that Captain Frick spoke with 9 BY MR. KUVIN: 10 Mr. Epstein at Clark and South Ocean, Clark Avenue and 10 Q. While they are looking at that, do you 11 South Ocean in the Town ofPalm Beach. And I understand 11 know how far Mr. Epstein's home is from any church 12 that Captain Frick spoke with, I don't know her fast 12 or school? . 13 name, but 1know her last name is Sloan (phonetic). 13 MR. PIKE: Fonn. 14 Q. Okay. 14 THE WITNESS: Ifs over a thousand feet. 15 A. From the Department ofCorrections. 15 I blow that. 16 MR. PIKE: Form. 16 BY MR. KUVIN: 17 MR. KUVIN: Okay. 17 Q. Do you know what the closest church or 18 BY MR. KUVIN: 18 school is in that area of the island? 19 Q. Did you come to team - 19 MR. PIKE: Form. 20 ' MR. PIKE: Sony, Spencer, I want to get 20 THE WITNESS: The school would be, the 21 form to that. It's kind of like a race between 21 closest school would be Crippled Children's 22 question and answer. So form to that one. 22 Society which is on Royal Palm Way. The church 23 BY MR. KUVIN: 23 would be Bethesda by the Sea. 24 Q. Did you come to learn what excuse 24 MR. KUVIN: Okay. 25 Mr. Epstein gave for being along Ocean Drive -- 25 THE WITNESS: Which is further, even 26 (Pages 227 to 230 PROSE COURT REPORT ING . AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb•fa8141f6-b3b7-dcda51494142 EFTA00298319 Page 23'1 Page 233 1 further north. 1 BY MR. KUVIN: 2 BY MR. KUVIN: Q. Do you remember the content of that 3 Q. Further north. Do you know if part of his letter, generally what it said? 4 conviction as a sexual offender prevents him from A. It was basically — 5 being a certain distance from schools or churches? . MR. PIKE: Fonn. 6 MR. PIKE: Form. 6 THE WITNESS: II minter looking at it. I 7 THE WITNESS: I believe so. But his 7 looked it over prior to delivering them. It 8 residence is within compliance. 8 mentioned that the case would probably — this 9 BY MR. KUVIN: 9 is after the grand jury, after the arrest 10 Q. Okay. During your investigation, while 10 MR. KUVIN: Right 11 they are still looking at that, did you ever speak 11 THE WITNESS: That the case would be 12 with a girl by name of that you can recall? 12 referred to the FBI to see if there was any 13 A. No. 13 federal nexus to it. 14 Q. Did you ever discuss with, all of the 14 BY MR. KUVIN: 15 girls that she may have brought? you ever have 15 Q. So this was after the referral to the FBI? 16 a chance to get into that conversation with her? 16 A. Yes. 17 MR. PIKE: Form. 17 Q. Befogsget back to Exhibit 25, just 18 THE WITNESS: Obviously I asked that same 18 briefly again= that name in particular, do you 19 question to everyone I interviewed. 19 know whether she was a part of any of the federal 20 MR. KUVIN: Right. 20 investigation? 21 THE WITNESS: Some girls I was able to 21 A. I have no idea. 22 identify. And other girls I couldn't identify. 22 Q. All right If she was not of your 23 The name was so common I couldn't pinpoint, 23 investigation and not a part of the federal 24 but, no, the name does not ring a bell. 24 investigation, as you sit here today do you know 25 25 whether or not additional charges may be brought Page 232 Page 234 1 BY MR. KUVIN: 1 against . Epstein based upon the acts alleged by 2 Q. Okay. Are there any additional 2 Ms. 3 conversations that you can recall having withM 3 MR. PIKE: Form. 4 that we haven't already discussed? 4 BY MR. KUVIN: 5 We've recounted two conversations that you Q. Do you know? 6 can recall with her. 6 A. 'have no idea. 7 A. Right. 7 Q. Do you know what the Statute of 8 Q. One is at the school where we talked about 8 Limitations is for a sexual assault or a sexual 9 where she broke down. The second one is when she 9 battery?' 1o.• explained to you the circumstances that you had in 10 A. I )(now under 12 there is no statute of 11 the probable cause affidavit. I was wondering if 11 limitations, however — 12 there was anything else. 12 Q. We're talking about 15. 13 MR. PIKE: Form, move to strike. 13. MR. PIKE: Form. 14 THE WITNESS: I spoke, 1believe, briefly 14 MR. KUVIN: With person over the age of 15 with her father. I delivered a letter to her 15 15. 16 home and hand delivered it to her father. 16 MR. PIKE: Wait a second. I believe the 17 BY MR. KUVIN: 17 witness is attempting to respond. So if he has 18 Q. • And what was that letter? 18 a response, please less him respond and don't 19 A. It was letter drafted by former Chief Reiter. 19 inte.nupt him. 20 Q. What did it discuss? 20 BY MR. KUVIN: 21. A. It was a letter — 21 Q. Fair enough. I am looking for whether or 22 • MR. PIKE: Form. 22 not you know the Statute ofLimitations for the 23 THE WITNESS: — that he had generated to 23 prosecution fora person over 15. 24 the parents of the victims. 24 A. I believe it's five years. 25 25 Q. Okay. Am I correct in sayinetaszou sit te illaNACEISaaa•MKAMA .,„ 27 (Pages 231 to 234) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a6ddb-141-4(16-b3b7-dcda51494142 EFTA00298320 Page 235 Page 237 1 here today you don't know whether or not was a 1 Q. Do you know if the U.S. Attorney's Office 2 part of the ultimate nonprosecution agreement that 2 has developed any additional new information with 3 was entered into with Mr. Epstein and the federal 3 respect to new charges to be brought against 4 authorities? 4 Mr. Epstein? S . A. I have no idea. 5 A. I have no idea. 6 Q. Okay. All right. Take a look at Exhibit 6 Q. Has anyone shared with you information 7 25. Let me ask you generally while you're looking 7 with respect to what the U.S. Attorney's Office may 8 at that, have you ever seen that before today? 8 have generated through conversations with 9 A. No. 9 Mr. Rodriguez who just pled guilty? 10 Q. Then that's going to limit a lot of my . 10 A. No,J do not. 11 questions. Do you appear anywhere in that summary 11 Q. • Do you know whether he cut a deal and gave 12 that you can tell? 12 over additional information to the U.S. Attorney's 13 MR PIKE: I am sorry, what exhibit number 13 Office to bring additional charges against 14 is that? 14 Mr. Epstein? 15 MR. KUVIN: Twenty-five. 15 A. No, sir. 16 THE WITNESS: Twenty-five. 16 Q. Are you aware of any girls that 17 MR. PIKE: I just want the record to 17 Mr. Epstein has trafficked across state lines? 18 reflect it. 18 MR. PIKE: Form. 19 BY MR. KUVIN: 19.. THE WITNESS: No,.sir. 20 Q. And I may have missed it, but I don't see 20 BY MR. KUVIN: 21 • your name in there so — 21 Q. Are you aware of any young girls wider the 22 . • A. No, I don't see it in there either. 22 age of 18 that he may have brought onto his jets or 23 Q. Were you, in fact, the one, though, that 23 planes? 24 saw Mr. Epstein walking along Ocean Drive? 24 .MR. PIKE: Form. 25 A. Yes, sir. 25 THE WITNESS: No, sir. Page 236 Page 238 1 MR. PIKE: Fonn, asked and answered. 1 BY MR. KUVIN: 2 BY MR. KUVIN: 2 Q. Okay. Do you know whether or not the U.S. 3 Q. And you called it into your superior at 3 Attorney's Office has that type of information one 4 the time? 4 way or the other? 5 MR. PIKE: Asked and answered. 5 MR. PIKE: Form. 6 THE WITNESS: Correct 6 THE WITNESS: I have no idea. 7 BY MR. KUVIN: 7 BY MR. KUVIN: you know a woman by the name of 8 Q. Okay. Do you know whether or not 10 8 ill at the State Attorney's office? A.. Yes. 9 ' 10 Mr. Epstein Ina a security company now working at his house called Wackenhut? 11 Q. Did you speak with her at the U.S. 11 A. Yes. 12 Attomey's.Office about your investigation? 12 Q. Do you know when they were retained? 13 A. One time I spoke with her. 13 A Shortly, shortly after. his release from the 14 Q. Okay. Has she contacted you at all 14 county jail. 15 recently? 15' Q. Okay.. 16 A. No. 16 A Or just prior to his release. One or the 17 Q. Do you know whe an r w girls 17 • other. 18 have met with or spoken to with the 18 . Q. During the search warrant, was any terminal 19 U.S. Attorney's Office? 19. used to chock for DNA throtighout the house? 20 MR. PIKE: Form. 20 MR. PIKE: Form. • • 21 THE WITNESS: Not that I am aware of 21 THE WITNESS: Not 100 percent, not in the 22 BY MR KUVIN: 22 . house. I believe the massage table. 23' Q. Do you know whether B.B. has now spoken 23 BY MR. KUVIN: 24 and interviewed with the U.S. Attorney's Office? 24 Q. How were the massage tables checked? 25 A. Not that Pm aware of. 25 MR. PIKE: Fonn. 28 (Pages 235 to 238) .1561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601 Electronically signed by cynthla hopkins (601 Electronically signed by cynthla hopkins (601 aa2a6ddb.fa81-4f16-b3b7-dcda51494142 EFTA00298321 Page 239 Page 241 THE WITNESS: That you will probably have 1 Q. All right. What's beneath the blacked out 2 to refer to Mr. Parkinson on that, Greg 2 portions since you created this document, if you 3 Parkinson, 3 know? 4 BY MR. KUVIN: 4 A. The names and cellular phone numbers of the Q. And he is who? 5 girls that were interviewed. 6 A. The manager at the crime scene unit. 6 jail So, did you confirm that, in fact, 7 Q. Okay. Do you know whether the FBI also 7 was calling some of the girls you 8 took video surveillance at all of Mr. Epstein? 8 interviewed? 9 Mk PIKE: Form. 9 MR.PLICE: Form. 10 THE WITNESS: I have no idea. 0 THE WITNESS: Yes. 11 BY MR. KUVIN: 11 MR. KUVIN: Let's mark this as 27. I 12 Q. Did any of the surveillance video that you 12 think 27 — I will have you explain it — is a 13 or your department took of Mr. Epstein show any of 13 copy of the letter that you delivered that you 14 the potential victims that are listed in your 14 mentioned before to C.L. 15 probable cause affidavit? 15 (Plaintiff's Exhibit No. 27 was marked for 16 MR. PIKE: Form. 16 identification.) 17 THE WITNESS: The surveillance log, i 17 BY MR. KUVIN: 18 remember there were some people that were 18 Q. Take a look at Exhibit 27. Is that a copy 19 interviewed because of their recent visits to 19 of the letter you hand delivered to C.L.? 20 Mr. Epstein's home that appeared to be young 20 MR. PIKE: Form. 21 females. 21 THE WITNESS: That is correct. 22 BY MR. KUVIN: 22 BY M. KUVIN: 23 Q. On the surveillance video? 23 Q. Okay. All right, I think I am about done 24 A. Yes. Well, it would have been under the 24 but I just have to ask: Did you have anything to'do 25. surveillance of either B.S.F. or surveillance video, one 25 with the incident involving Gerald() Rivera? Page 240 Page 242 or the other. 1 MR. PIKE: Form. 2 Q. Who is Michelle Pagan? 2 THE WITNESS: No. 3 A. Michelle Pagan is an officer with the Town of 3 BY MR. ICUVIN: 4 Palm Beach Police Department. 4 Q. No. Did you come to team at any time 5 Q. That's right. I'm sorry. I forgot. 5 that Gerald° Rivera was standing outside of 6 (Plaintiffs Exhibit No. 26 was marked for 6 Mr. Epstein's home -- 7 identification.) 7 MR. PIKE: Form. 8 BY MR. KUVIN: 8 BY MR. KUVIN: 9 Q. Let's take a look at what's been marked as 9 Q. And someone called 911? Did you hear 10 Exhibit 26, and if you could explain what this 10 about that? 11 document is. Would you explain what that document 11 MR. PIKE: Form. . 12 is, Exhibit 26? 12 THE WITNESS: Iheard rumors about that in 13 A. That was a document I created just to show 13 the police department, but no, I had no 14 der rs, either called in or called out 14 involvement or knowledge of that. 15 from cellular phone. 15 BY MR. KUVIN: 16, Q. Okay. There are some things blacked out 16 Q. Okay. Do you know if that occurred while 17 on there. Why are they blocked out? 17 he was in jail or after he had been released on 18 MR. PIKE: Form. 18 house arrest? 19 BY MR. KUVIN: 19 A. I have no idea. . 20 Q. Let me ask you this: Did you black them 20 MR. KUVIN: Okay. All right. I 21 out? 21 appreciate it. That's all the questions I have 22 A. No, l did not. 22 at this time. 23 Q. Does the original of this document have 23 MR. EDWARDS: Who is up? 24 that information on it? 24 MR. PIKE: Take a quick break off the 25 A. Yes. 25_ at, Jeard. Everybody agree? 29 (Pages 239 to 242) PROSE COURT REPORTING AGENCY, INC.: Electronically signed by cynthla hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthla hopkins (801 aa2a5ddb.to81-4I16-b1b7-dcda51494142 EFTA00298322 Page 24 Page 245 MR. EDWARDS: Yes. 1 Epstein; is that correct? 2 (A brief recess was held.) 2 MR. PIKE: Form. 3 (Plaintiffs Exhibit No. 28 was marked for 3 THE WITNESS: Knowledge to me. 4 identificatica.) 4 MR. EDWARDS: Okay. 5 CROSS (DETECTIVE JOSEPH RECAREY) 5 THE WITNESS: lam — as far as the police 6 BY MR. EDWARDS: 6 department I have no idea when. Obviously this 7 Q. Good afternoon, Detective. 7 was prior to the investigation; however, this 9 A_ Good afternoon. 8 was not a public record report that was passed 9 Q. I have just handed you what we have marked 9 around from officer to officer to officer. 10 as Plaintiffs Exhibit 28. And I will show it to 10 MR. EDWARDS: All right. So — 11 defense counsel. Have you seen that document 11 THE WITNESS: When this is evaluated by 12 before? 12 the supervisor and submitted, this actually 13 A. Yes. 13 goes to independent units. 14 Q. What's the date on that? 14 BY MR. EDWARDS: 15 A. 11/28/04. 15 Q. And do you know what supervisor that 16 Q What is that document? 16 particular November, 2004 — what are we calling it 17 A. The Palm Beach Police Department Intelligence 17 again? 18 Report. 18 A. Intelligence report 19 Q. What is an Intelligence Report? 19 Q. Intelligence report. Do you know who the 20 A. It is a report that is generated by an officer 20 supervisor would have been at the time? 21 on any information received not deemed to be an incident 21 A. It looks like it might have been at that point 22 report; something for detectives to follow-up on. 22 Sergeant Maio. That looks like his initials. 23 Q. Okay. Who's the officer that was the 23 Q. Is Sergeant Maio somebody that you have 24 author of that report? 24 had any conversations with related to the 25 A. It would be Keith Munyan. 25 investigation into Jeffrey Epstein? Page 244 Page 246 1 Q. And have you spoken with Keith Munyan, 1 A. No. 2 fist question is about anything related to Jeffrey 2 Q. All right. The first time that you saw 3 Epstein or the investigation? 3 that particular report that you're looking at, 4 A. I know fora time there was a time where he 4 Plaintiffs Exhibit 28, do you remember when that 5 was on B.S.F., the Burglary Strike Force, that conducted 5 was? 6 the surveillance. 6 A That would have been after my investigation 7 Q. Okay. 7 began. 8 A. But actual conversation with him regarding the 8 Q. Okay. After your investigation began 9 investigation, no. 9 which would have been September of 2005? 10 Q. Did you ever have a conversation with 10 A Correct. 11 Officer Munyan at any time from the beginning of the 11 Q. Do you know if -- well, when you reviewed 12 world until today about that particular report that 12 all of the materials to catch yourself up to speed, 13 was authored in November of 2004? 13 I believe you testified that that was initially done 14 A. No, I did not. 14 by Officer Pagan? 15 (Mr. Epstein entered the deposition room.) 15 A. Correct. 16 BY MR. EDWARDS: 16 Q: When you reviewed all of the materials to 17 Q. From my understanding of the previous 17 catch yourself up to speed with the investigation, 18 testimony, the investigation of Mr. Epstein began 18 was that particular report included in those 19 sometime in March of 2005 upon a telephone call by 19 materials? 20 some relative o1 20 A. No, it was not 21 A. Correct. 21. Q. So Plaintiffs Exhibit 28 is something 22 Q. And it's also my understanding that your 22 that was produced to you or shown to you sometime 23 testimony was it was your belief that that was the 23 after your investigation into Jeffrey Epstein began 24 first knowledge that the police department had of 24 in September of 2005? 25 possible interactions with underage girls by Jeffrey 25 A. Correct 30 (Pages 243 to 246) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb fa81-016.b3b7-dcda51494142 EFTA00298323 Page 247 Page 244 1 Q. And do you remember if it was before or I tour. It might be just after the ending of their tom. 2 after the execution of the search warrant in October 2 They're jotting information down. They provide it to 3 of 2005 that you first saw that document? 3 the supervisor. The supervisor then initials off on the 4 A I don't know the exact date that I was shown 4 bottom of it. 5 this document, but I )(now that I would have liked to 5 And then it gets disseminated to what is 6 have it prior to my interview with the person that I 6 now the Organized Crime/Vice and Narcotics Unit. It 7 interviewed on this case. 7 is the sergeants responsibility then of that unit 8 Q. Are you talking about Jane Doe No. 103? 8 to disseminate it to other units depending on the 9 A. Correct. 9 information provided. 10 Q. She's the person that was allegedly, 10 Obviously, if it, if this contained 11 according to this report that's been marked as 11 information on narcotics, it would stay with 12 Plaintiffs Exhibit 28, was at Jeffrey Epstein's 12 Organized Crime/Vice, and Narcotics. If it had 13 house in November of 2004? 13 information on gypsy thefts, it would go to the 14 MR. PIKE: Form. 14 detective bureau. If it had an officer safety 15 THE WITNESS: That is correct. 15 information, you know, I stopped a kid and he had a 16 BY MR. EDWARDS: 16 necklace with a, if you pulled it apart and it 17 Q. And from what I understand based on the 17 became a knife, then it would go to the entire 18 report, house manager Alfredo Rodriguez, calls the 18 police department. 19 police because of a suspicious vehicle in Jeffrey 19 Q. Okay. And do you know how that document 20 Epstein's driveway? 20 was disseminated or to which department it went? 21 MR. PIKE: Form. 21 A. This was disseminated to the Organized 22 THE WITNESS: Correct. 22 Crime/Vice and Narcotics Unit. 23 BY MR. EDWARDS: 23 Q. Why is that? 24 Q. Officer Munyan is the one reporting to the 24 A. I don't know. 25 scene and finds Jane Doe No. 103. 25 MR. PIKE: Form. Page 248 Page 250 1 A. Correct. 1 THE WITNESS: I don't know. That was — 2 MR. PIKE: Form. 2 the supervisor at that particular time kept it 3 BY MR. EDWARDS: 3 within Organized Crime. 4 Q. Then you read the officer's comments 4 BY MR. KUVIN: 5 within the report about, you know, what muscle is 5 Q. Do you know if there was any internal 6 she massaging. And maybe that's not a direct quote 6 follow-up to that report done by the Palm Beach 7 but that's from memory. 7 Police Department? 8 Seems like there is some idea on his 8 MR. PIKE: Form. 9 behalf that something was going on inside the house 9 THE WITNESS: Not that frn aware of. 10 that may not be correct, is that right? 10 BY MR. KUVIN: 11 MR. PIKE: Form, move to strike, compound, 11 Q. You have obviously seen that intelligence 12 confusing, leading, speculative. 12 report You have been presented with that 13 MR. EDWARDS: If you understand that bad 13 intelligence report sometime after your 14 question, go ahead. 14 investigation. Have you ever gone back to look was 15 l'HE WITNESS: ft appears that he came up 15 there a follow-up to that report? 16 with his own opinion. 16 A. I did look to see if there was a follow-up on 17 BY MR. EDWARDS: 17 that report, and there was not much of a follow-up done 18 Q. Okay. And when a report like that is 18 on it. 19 drafted, and you say is it always turned ova to the 19 Q. Did you see any follow-up that — 20 captain or the sergeant? 20 A. I — 21 A. Usually when an officer completes an 21 Q. —at all? 22 intelligence report in the Palm Beach Police Department, 22 A. I believe that they attempted to contact 23 they give it to their direct supervisor or the next 23 Ms. Jane Doe No. 103 several times with negative 24 oncoming shift supervisor. The intelligence report may 24 results. 25 or may not be completed during their shift, during their 25 Q zw•Yel•MI.ms.A.VIC4C.C..“MVO.. •Yi•••••, :•, "., ....•••..S•b1•14[10•••••Saillia 31 (Pages 247 to 250) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-fa81-4116-b3b7-tkda51494142 EFTA00298324 Page 251 Page 253 MR. PIKE: Form. 1 BY MR. EDWARDS: BY MR. EDWARDS: 2 Q. Okay. So, 1 am just going to direct your 3 Q. Is there any documentation memorializing 3 attention to the document that is tabbed 2001 on 4 those telephone calls? 4 Page 2. 5 MR. PIKE: Form. 5 A. Correct. 6 THE WITNESS: I don't believe so. 6 Q. So flip it to Page 2, and just read that 7. BY MR. EDWARDS: 7 paragraph that begins with the information in 2001. 8 Q. Why do you believe that they attempted to 8 Okay? 9 contact her with negative results? A. Okay. 10 MR. PIKE: Form. 10 Q. Have you seen that information before? 11 THE WITNESS: Because the person that was 11 A. Like I said, I had heard that there was 12 assigned to this, I spoke with who is now 12 previous indications of young females frequenting the 13 sergeant, Sergeant 'Crawl. And he said he 13 house, but it was my understanding that it was Palm 14 attempted to contact her on several times to 14 Beach Atlantic college girls coming over. 15 discuss with her this case. 15 Q. And would there be a file with the Palm 16 BY MR. EDWARDS: 16 Beach Police Department related to any 17 Q. I don't know that I can put my finger on 17 investigation, interviews, surveillance, or any 18 the exact document right now, but I believe I read 18 other evidence that was discovered during that 2001 19 something and Fm not sure if it was authored by 19 investigation? 20 you or Chief Reiter about information back as early 20 A. Not that I am aware of. 21 as 2001 of young females frequenting Mr. Epstein's 21 Q. It appears from reading that document that 22 house. Do you recall seeing something like that? 22 there were interviews taken, correct? 23 MR. PIKE: Form. 23 MR. PIKE: Form. 24 THE WITNESS: Them may have been some 24 THE WITNESS: It appears. 25 information received. There may have been some 25 Page 252 Page 25 1 information received as to females young in 1 BY MR. EDWARDS: 2 appearance visiting or frequenting 2 Q. It also appears that there was 3 Mr. Epstein's home earlier than that, but I 3 surveillance? 4 believe that was deemed to be Palm Beach 4 A. Correct 5 Atlantic College kids back then. 5 MR. PIKE: Fonn. 6 BY MR. EDWARDS: 6 BY MR. EDWARDS: Q. Okay. And as early as 2001 it was 7 Q. And thafs a document that's being 8 reported to the Palm Beach Police Department there 8 generated years later, correct? 9 were numerous young women visiting his residence. 9 MR. PIKE: Form. 10 And you're testifying that those youth women, to the 10. THE WITNESS: Yes, sir. 11 best of your knowledge, were determined to be 11 BY MR. EDWARDS: 12 college kids? 12 Q. So, just based on your knowledge and 13. MR. PIKE: Form. 13 experience as a police officer or a detective, do 14 THE WITNESS: I believe so. 14 you have any idea where that information or evidence 15 BY MR. EDWARDS: 15 would be kept or stored if at all? 16 Q. So, there were interviews taken into the 16 A. I have no idea. 17 • 2001 information that was delivered to the police 17 Q. Okay. If I wanted to find out related to 18 department related to these young women, correct? 18 that specific incident, terntse I know we did a 19 MR. PIKE: Form. 19 Florida request, and I believe it was all 20 THE WITNESS: I'm not sure. 20 information related to Mr. Jeffrey Epstein. And for 21 MR. EDWARDS: All right. Might as well go 21 the most part we only got information related to 22 ahead and use a couple of stickers that we have 22 this particular investigation that you were a part 23 there. You might want to show him Page 2. 23 of. 24 3/28/02 is the date on this. 24 Is there some other designation that I 25. 25 need to send to the Palm Beach Police nt to 32 (Pages 251 to 254) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801 Electronically signed by cynthia hopkIns (801 Electronically signed by cynthia hopkins (801 aa2a5dclb-th81-4n4037-ciccia514941412 EFTA00298325 Page 255 Page 257 1 get information about a 2001 investigation? 1 BY MR. EDWARDS: 2 MR. PIKE: Form. 2 Q. Okay. And I believe you told us in your 3 THE WITNESS: I have no idea. You might 3 background you worked in narcotics before? 4 want to check with the custodian of records, 4 A. Yes, sir. 5 Laura Oregero. 5 Q. in narcotics specifically, are there code 6 BY MR. EDWARDS: 6 words that are used related to criminal activity? 7 Q. Okay. And why do you believe that this 7 MR. PIKE: Form. 8 particular 2001 investigation related to college 8 111E WITNESS: Yes. 9 students? 9 MR. PIKE: Relevance. 10 MR. PIKE: Form. 10 BY MR. EDWARDS: 11 THE WITNESS: Because I recall, I recall 11 Q. When people talk over the telephone about 12 someone, and I can't, I don't know who exactly 12 what kinds of drugs they are selling and things like 13 stated that there was information years prior 13 that, is it your training and experience that code 14 of girls going to the house, but it turned out 14 words are often used? 15 it was all college girls coming to work for 15 A. Correct 16 Mr. Epstein at the residence. 16 MR. PIKE: Form 17 MR. PIKE: Form, move to strike. 17 BY MI!: EDWARDS: 18 BY MR. EDWARDS: 18 Q. In this particular case regarding Jeffrey 19 Q. And are you aware of what these college 19 Epstein, the words work and massage in your training 20 girls were doing in terms of work? 20 and experience, are those code words that were used 21 A. I have no idea. 21 by Jeffrey Epstein and the other people working for 22 MR. PIKE: Form. 22 him? 23 BY MR. EDWARDS: 23 MR. PIKE: Form. 24 Q. All right. The term work and the term 24 - THE WITNESS: As far as I know the girls 25 matcnee has been used by you and many other 25 all referred to it as work. I don't ;mow if Page 256 Page 258 1 witnesses in this particular case. And by that, by 1 that is a specific code word. 2 those terms is it your understanding that those 2 BY MR, EDWARDS: 3 terms refer to the scenario wherein Jeffrey Epstein 3 Q. Do you know where they learned that word 4 pays underage girls to ;Amorally assault them? 4 front? 5 MR. PIKE: Form. 5 MR. PIKE: Form. Were you finished with 0 THE WITNESS: As far as the case that I 6 your response? 7 investigated, 05368, the girls referred to it 7 THE WITNESS: Yes. 8 as work. And when I asked, because i, in my 8 MR. PIKE: Okay. 9 interviews I asked them what do you mean work, 9 THE WITNESS: NorI have no idea. 10 and that's what they referred it to. 10 BY MR. EDWARDS: 11 BY MR. EDWARDS: 11 Q. Well, you've looked at several message 12 Q. When you say that's what — I mean I was 12 pads today and the word work is used on those, 13 trying to shorten it because I have listened to you 13 correct? 14 testify about many girls, the same scenario over and 14 A. Correct. 15 over again. But are we talking about — well, I 15 Q. And those, that was not written by the 16 will let you put it in your own words. 16 girls. Those are things that are written by Jeffrey 17 When the girls said I am going to Jeffrey 17 Epstein's assistants to the best of your knowledge; 18 Epstein's house to work, what did they ultimately 18 is that correct? 19 elaborate and tell you what that meant? 19 A. Yes. 20 . MR. PIKE: Form, move to strike, narrative 20 MR. PIKE: Form. 21 and leading. 21 BY MR. EDWARDS: 22 THE WITNESS: Providing massages whether 22 Q. Regarding the message pads, were those 23 them being naked or partially clothed, and some 23 taken, were all the message pads taken at the same 24 obviously being fondled or touched. 24 time? 25 25 MR. PiKE: Form. 33 (Pages 255 to 258) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aaiascIdo-la81-488-b3b7-dcda51494142 EFTA00298326 Page 259 Page 261 1 THE WITNESS: Yes. 1 during the investigation? 2 BY MR. EDWARDS: 2. A Correct. 3 Q. And by taken i mean retrieved at the same • 3 Q. So, if it came down to trial would it be, 4 time? 4 would you be the person that would be able to say 5 A. During the search warrant. 5 this is a fair and accurate representation of what 6 Q. All right. Were any the message pads, and 6 was taken into evidence at this particular time? 7 that is what in reading the report I have had a 7 MR. PIKE: Form. 8 tough time deciphering, were some taken from the 8 THE WITNESS: Based on the trash pulls 9 trash pulls and some from the house or were they all that I requested, that I conducted, yes, I 10 taken Ia the search.warrant? 10 would be the one. I could tell you I could see 13. MR. PIKE: Form. 11 it, and that's the one that I put into 12 'THE WITNESS: The message pads were 12 evidence. • • 13 double-sided. You would write the message onto 13 BY MR. EDWARDS: 14 its pad.. The top layer would peal off 14 Q. And with respect to the message pads that 15 depending on who the message was for, and then 15 were retrieved during the search warrant, would you 16 there would be a carbon copy kept underneath. 16 also be able to identify them and indicate whether 17 And the pads that you're seeing, the majority 17 they are a fair and accurate representation of what 18 of those messages were carbon copies. 18 was taken into evidence? • 19 BY MR. EDWARDS: 19 • A. 'Yes. 20 Q. And taken when? 20 ' MR PIKE: Form. 21 A. During the search warrant. 21 THE WETNESS: Yes. 22 Q. All right. Were any of the messages that 22 BY MR. EDWARDS: 23 we have copies of taken from trash pulls where it's 23 Q. And not only with respect to the message 24 the actual message that's been crumpled up and 24 pads, but with all the evidence that is listed on 25 thrown away? 25 your property receipt, assuming that one day we get Page 260 Page 262 1 MR. PIKE: form. 1 to see the evidence, would you be the one to 2 THE WITNESS: Correct. 2 identify it? 3 MR. PIKE: You're talking about messages. 3 A. Yes. 4 Are you talking about the 2-inch stack of 4 MR. PIKE: Porta 5 documents that Mr. Kuvin earlier showed the 5 BY MR. EDWARDS: 6 witness? And I am not talking, Mr. Kuvin 6 Q. And I know you have testified that the FBI 7 MR. EDWARDS: The format is similar to 7 took possession of all of the documents and items 8 that. 8 that are listed in the property receipt, right? 9 MR PIKE: Mr. Kuvin has already agreed to 9 A That is correct? 10 produce them to us. Ifs not a trick. I just 10 . MR. PIKE: Form. 11 want to understand what we're talking about. 11 BY MR. EDWARDS: 12 Is it those message pads? 12. Q. Did you or your department — 13 MR. EDWARDS: Right 13 A.. Let me, let me correct that. 14 BY /vfR. EDWARDS: 14 'Mar. 15 Q. Are those the message pads that you were 15 - A. The items that were returned to Janusz had 16 referring to? 16 nothing to with the FBI. That was determined that he 17 A. Yes. 17 was the rightful owner of the items collected, and that 18 Q. I want to make sure that we're on the same 18 was !chimed back to him and it contained no contraband 19 page. Were communicating. 19 or any kind of images or anything like that. 20 A. But to answer your previous question from the 20 Q. No evidence of any criminal activity that 21 trash pulls, we did obtain originals, the top layer of 21 you could tell? . 22 the message. 22 A Correct •• 23 Q. Okay. And when documents, any papers, any 23 MR. PIKE: Form. 24 documents were retrieved from trash pulls and taken 24 BY MR. EDWARDS: 25 into evidence, were those taken into evidence by you...m."22_ 2:_ o with !......Sumn to items TLI.LtaLIA2re 34 (Pages 259 to 262) PROSE COURT REPORTING AGENCY.i:: INC. - Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-fa81-41f6-b3b7-ticda51494142 EFTA00298327 Page 263 Page 265 1 determined to be evidence and listed on the property 1 A. No. 2 receipt, and just so that we're clear, the documents 2 MR. PIKE: Form. 3 that were not Janusz Banasiak, did you or your 3 BY MR. EDWARD& 4 office make any copies of any of that material? 4 Q. Were you aware of any of donations that he 5 A. No, because I actually signed out the message 5 has ever made? 6 pads to review them. I know that the State Attorney's 6 A. I recall a donation he made to purchase 7 Office was provided a copy with the filing packet. equipment, video enhancing equipment shortly thereafter 8 Q. Okay. Do you know approximately -- well, 8 that case. 9 not approximately. Do you know how many messages, Q. Okay. Are you aware of a 550,000 donation 10 how many message squares were retrieved or how many 10 back in 2002 by Mr. Epstein that was delivered 11 pages from the message pads were retrieved during 11 personally to Chief Reiter by Gerald Goldsmith? 12 the search warrant? 12 A. No. 13 MR. PIKE: Form. 13 Q. Has anybody ever made you aware that he 14 THE WITNESS: I couldn't give you an 14 donated $50,000 to the Palm Beach Scholarship fund 15 accurate number. I know some were. 15 April 1st, 2002? 16 BY MR. EDWARDS: 16 MR. PIKE: Form. 17 Q. More than one message pad? 17 THE WITNESS: No. 18 A. As far as carbon copies are concerned? 18 BY MR. EDWARDS: 19 Q. Right. 19 Q. Has anybody ever made you aware that he 20 A. The carbon copies, there were several books 20 donated $36,000 to the purchase of a forensic video 21. taken. 21 analysis system in October of 2003? 22 Q. That's what I am asking. 22 A. That, that was the — .23 A. There were several books taken. If you look 23 MR. PIKE: Form. 24 at the property receipt, it will say phone message book, 24 THE WITNESS: — video enhancing 25 phone message book and the location where it was taken 25 equipment Page 264 Page 266 1 from. 1 BY MR. EDWARDS: 2 Q. Okay. The way that they have been 2 Q. Okay. That's what you were just talking 3 presented to us, at least the copies, are four per 3 about? 4 page. Is that how it appears on the book? 4 A. Yes, sir. 5 A. Yes. 5 Q. And these donations, when they have been 6 Q. When is the first time that you had any 6 made, is it your understanding that they are made 7 contact with Jeffrey Epstein? 7 through a company owned or controlled by Jeffrey 8 A. I met Mr. Epstein during an investigation 8 Epstein, COUQ Foundation, Inc.? 9 where someone had broken into his home and stolen money 9 MR. PIKE: One second. Can you repeat 10 and I believe a firearm. And, ifl recall, I came over 10 that for the record? 11 to assist other detectives to install a covert camera in 11. MR. EDWARDS: Sure. 12 hopes to catch the person breaking into the house. 12 BY MR. EDWARDS: . . • 13 Q. Okay. And I have seen that report 13 Q. When the donationthat you're aware of was 14 somewhere. And 1 think that will take a long time 14 made, was it your understanding that it was made 15 to get into, and I don't believe we have that much 15 through the COUQ Foundation, Inc., a company 16 time, but that was sometime in 2003; is that 16 controlled by Jeffrey Epstein? 17 correct? 17 MR. PIKE: Form. 18 A. That's correct. That's the fast time I met 18 THE WITNESS: I have no idea. 19 Mr. Epstein. 19 BY MR. EDWARDS: 20 Q. Had you heard of him or known of him prior 20 Q. When these donations are made, who 21 to that time? 21 receives the donation? • 22 A. No. 22 A. The chief or the town manager. . 23 Q. All right. Arc you aware of various 23 Q. Okay. So if the chief is the one writing 24 • donations that he has made to the Palm Beach Police 24 letters thanking Mr. Epstein, the chief would be the 25 over the years? 25 best person to ask about these donations? 35 (Pages 263 to 266 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia bodkins (601 Electronically signed by cynthia hopkins (601 matatddb4014fle-Mblada514.4142 EFTA00298328 Page 267 Page 269 1 A. Correct 1 over the telephone prior to your investigation that 2 Q And in terms of how the records are kept, 2 began in September of 2005? 3 copies of the checks and things ince that, that's 3 MR. PIKE: Form. 1 something for a record custodian or the chief, not 4 THE WITNESS: No. Like I said, l may have 5 for you? 5 introduced myself to him when I came over to 6 A. Not forme. Tints way above my pay grade. 6 assist to install the camera during the 7 Q. We talked about this November 2004 report. 7 burglary investigation, but other than that... 8 You were not aware of that until sometime in 2005 or 8 BY MR. EDWARDS: 9 2006, correct? 9 Q. When you first arrived to the house back 10 MR. PIKE: And for the record yotfre 10 in 2003 related to the burglary, were there already 11 talking about Exhibit 28, right? 11 cameras in place? 12 THE WITNESS: Exhibit 28. 12 MR. PIKE: Form. 13 MR EDWARDS: I believe so. 13 THE WITNESS: I do not believe so. 14 BY MR. EDWARDS: 14 BY MR. EDWARDS: 15 Q. Were you made aware that December, 15 Q. All right So when you arrived, Jeffiey 16 December 14th, 2004, 15 or 16 days after that report 16 Epstein was asking for your assistance in helping 17 is generated, Jeffrey Epstein donates $90,000 for an 17 set these cameras up? 18 electronic firing range technology? Were you aware 18 A. I take that back It might have been, the 19 of that? 19 cameras might have already been installed as far as the 20 A. No. 20 covert clock in the office area because that was the 21 MR. PIKE: Form. 21 area that was burglarized. 22 BY MR. EDWARDS: 22 . Q. Okay. 23 Q. Do you know who it is that Jeffrey Epstein 23 A. And the only reason why I remember that is 24 talks to, if anybody, within the Palm Beach Police 24 because I had interference between his system and our 25 Department back in 2004 to ultimately donate money? 25 system. Page 268 Page 270 1 A. Again, it would have to be the chief of police 1 Q. All right. I am going to go back to 2 or the town manager or — 2 Plaintiffs Exhibit 29, same page that we looked at 3 Q. 'guess what I am asking is there any 3 last time related to a 2001 investigation, and ask 4 coordinator of donations -- 4 you to read the paragraph just above of that 5 A. No. 5 paragraph we reviewed before. 6 Q. — that works -- okay. And do you know 6 A. Yes, sir. This paragraph we're talking about, 7 what was done with the December 14th, 2004, donation 7 September 2005? 8 made by Jeffrey Epstein? 8 Q. Yes. Are you ready? 9 MR. PIKE: Form. 9 A. Yes, sir. 10 THE WITNESS: I believe that the donations 10 Q. Do you remember speaking with the Chiefor 11 were returned to him, I believe. 11 to Jeffrey Einstein or any of his representatives 12 BY MR. EDWARDS: 12 directly about a 2005 donation that Jeffrey Epstein 13 Q. And by returned, they would have been 13 was calling to make? 14 returned back to whatever company they were written 14 A. No.' 15 from, COUQ Foundation? 15 Q. All right When is the first time that 16 MR. PIKE: Font. 16 you learned that sometime around September of 2005 17 THE WITNESS: I believe. I have no idea. 17 Jeffrey Epstein was calling the police department 18 BY MR. EDWARDS: 18 make a donation? 19 Q. And do you know if Chief Reiter and 19 MR. PIKE: Form. 20 Jeffrey Epstein had a relationship where they spoke 20 THE WITNESS: I didn't even know he was 21 with each other back in 2004 and 2005 — 21 calling in 2005 to make a donation. Like I 22 A. I have no idea. 22 said, I have no, no involvement in that 23 Q. -- on any type of frequent basis? 23 whatsoever. 24 A. I have no idea. 24 BY MR. EDWARDS: 25 Q. Did ou ever speak with Jetitial sw ein 25 Q. Okay. That's not something that Chief 36 (Pages Z67 to 270 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia honking (601 aa2a5ddbra81-4fra-b3b7-dcda6149410 EFTA00298329 Page 273 1 Reiter ever talked to you about? 1 THE WITNESS: No. 2 A. No. 2 BY MR. EDWARDS: 3 Q. So, right now is the first time that 3 Q. Did you know that Jeffrey Epstein received 4 you're learning that? 4 a January 2005 citizen award? 5 A. Yeah. 5 A. Not that I am aware of. I don't blow. Lite I 6 Q. Okay. Well, it looks like based on this 6 said, these are things that I don't get involved with. 7 report that it was discussed with Epstein that his 7 You know, that's strictly the Chief and way above my pay a potential donation of funds to purchase an Automated 8 grade. 9 Fingerprint Identification System for approximately 9 Q. If awards like that are given out, are 10 $130,000 was never made; is that correct? 10 they given out directly by the chief? 11 MR. PIKE: Form. 11 A. Yes. 12 THE WITNESS: Correct. I know we're 12 Q. I apologize for my ignorance. I am just 13 not — we don't have any system. We go to the 13 not sue exactly what goes on in the police 14 Sheriffs office to input fingerprints. 14 department and whose role it is to do that. So 15 BY MR. EDWARDS: 15 you're not the right person. We'll just keep moving 16 Q. And Epstein's response was that was not 16 on. 17 exactly what he hoped to donate as he wanted to 17 Some of the documents that we have talked 18 donate something that would provide some direct 18 about today have been redacted. I think the 19 benefit to police officers such as the services of a 19 explanation is they are minor victims. My question 20 chiropractor fora year. 20 is if we wanted an unredacted version and if we 21 Were you ever aware that Jeffrey Epstein 21 agree that we're entitled to it, would that be 22 was trying to get chiropractic services for the 22 something that would be in the possession of the 23 police officers for a one-year period? 23 Palm Beach Police Department? 24 MR. PIKE: Form. 24 MR. PIKE: Form. 25 THE WITNESS: No. 25 THE WITNESS: I would assume so. Page 272 Page 274 1 BY MR. EDWARDS: 1 BY MR. EDWARDS: 2 Q. Today is the first day you're learning it? 2 Q. Okay. The information that was provided 3 A. Yes, sir. 3 this week tots, most of which is redacted, is 4 Q. Any reason that you can think of that that 4 something and was redacted recently for the purpose 5 information was not conveyed to you during the time 5 of producing it to us, is that what you think? 6 that you're the lead detective on the case against 6 MR. PIKE: Form. 7 him? 7 THE WITNESS: Correct. 8 MR. PIKE: Form. 8 BY MR. EDWARDS: 9 THE WITNESS: Well, because that's 9 Q. Somewhere there is an unredacted version? 10 something that really has no —1mean, I have 10 A. Correct. 11 no direct involvement with any donations to the 11 Q. And if I wanted to discuss the 12 police department, nor would that have made a 12 investigation of Jeffrey Epstein between March of 13 diffeleme in the investigation. 13 2005 and September of 2005, is Officer Pagan the 14 BY MR. EDWARDS: 14 person to speak with? 15 Q. You testified earlier the search warrant 15 A. Yes. 16 was executed October 21st, 2005; is that correct? 16 Q. With Mr. Kuvin you spoke about many 17 MR. PIKE: Form, asked and answered. 17 different young females that were at Jeffrey 18 THE WHNESS: The 20th, I believe. 18 Epstein's home. And you interviewed numerous of 19 BY MR. EDWARDS: 19 those females, correct? 20 Q. Were you aware of a tel one call made 20 A. Correct. 21 from somebody named in November of 2005 21 MR. PIKE: Form. 22 asking to get a copy of the January 2005 citizen 22 BY MR. EDWARDS: 23 award that was given to Jeffrey Epstein and ■ 23 Q. And did you record those interviews? 24. (phonetic)? 24 MR. PIKE: Asked and answered. 25 MR PIKE: Form. 25 THE WITNESS: I believe so, yes, the 37 (Pages 271 to 2 7 4) PROSE• COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 es.2a6ddb-fatil-4114-tab74ede51494142 EFTA00298330 Page 275 Page 277 majority of them. 1 manner, but you are saying that you may have jotted BY MR. EDWARDS: 2 down some 3 Q. And do you have any copies of those tapes 3 A. Correct 4 of the interviews? 4 Q. Where would that, where would that diagram 5 MR. PIKE: Form. 5 be? 6 THE WITNESS: They were all turned over to 6 A. All that went over to the FBI. .7 the FBL 7 Q. Okay. That stuff that's obviously not in 8 BY MR. EDWARDS: 8 the property receipt but that's additional stuff 9 Q. They are not backed up on a computer or 9 that has gone to the FBI? 10 anything? 10 A. Correct. Like I said, they wanted everything 11 A. No, sir. They were microcassettes. The ones 11 including my working files, my — anything that I may 12. that were conducted at the police department were video 12 have jotted just so I can keep record of who brought 13 cassettes, but all those as well were turned over to the 13 who. 14 FBI. 14 Q. And again is that information that you Q. Is it your.understanding that Jeffrey 15 never made a personal copy of either? 16 Epstein pled guilty to two felonies related to 16 A. It was all in my thumb drives which I had to 17 - restitution, correct? 17 actually hand over to them. 18 MR. PIKE: Asked and answered. 18 Q. Okay. • 19 THE WITNESS: Contl 19 MR. PIKE: Form to that question. 20 BY MR. EDWARDS: 20 BY MR. EDWARDS: 21 Q. In your interviews of these young females, 21 Q. What about any notes that you took during 22 were any of those females prostitutes prior to 22 the entire course of the investigation, do you have 23 meeting Jeffrey Epstein — 23 any of those? 24 • MR. PIKE: Fonn. 24 A. Once I transcribed them onto the rcµnt, those 25 25 were shredded and discarded. Page 276 Page 278 BY MR. EDWARDS: 1 MR. PIKE: Form. 2 Q. — to your knowledge? 2 BY MR. EDWARDS: 3 A. No. 3 Q. What did you do today to prepare for the 4 MR. PIKE: Pm sony. I don't understand 4 deposition, If anything? 5 the answer. So maybe you can follow-up with 5 A. I read over the redacted incident report. 6 that. Tell you what, we'll just keep it at 6 That's basically it. 7 form. 7 Q. Okay. And the redacted incident report, 8 BY MR. EDWARDS: 8 you have been asked questions about who is this 9 Q. • In organized crime you've seen these 9 person that's underneath the redacted portion. And 10 diagrams where it has a mob boss? 10 for the most part you haven't been able to identify 13. A. Organizational chart. 11 a lot of those people. So, am I correct in 12 Q. Yes, organizational chart. Did you ever 12 understanding that you never went back and looked at 13 prepare any diagrams or charts like that for this 13 the unredacted version? 14 case related to which girl brought another girl 14 MR. PIKE: Form. 15 brought, another girl, the organizational chart 15 BY MR. EDWARDS: 16 so-to-speak? 16 Q. At least to prepare for this deposition? 17 MR. PIKE: Form, move to strike. 17 A. I believe there was just one girl thatl 18 • THE WITNESS: Not a chart, per se, but 18 wasn't 100 percent certain. 19 perhaps Tye done like this person brought 19 Q. Okay. 20 these throe girls, this person brought these 20 A. But on the others I was able to based on the 21 two girls, this person brought five girls. But 21 body ofit identify who the girls were. 22 That a, you know, like an L.C. chart where 22 Q. Okay. During these interviews, how long 23 you've.got the mob boss, the under-boss. 23 did you spend with each person? 24 • BY MR. EDWARDS: 24 A. Depends on the length of the videos, of the 25 Q. You never tried to do it in a formal 25 interviews. Some were an hour. • WO%SIZ.0•••••••••• 001... 38 (Pages 275 to 278) .(5.61) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hooking (601 aa2a5ddb-fa81-4tt6.b3b7-dcda51494142 EFTA00298331 Page 2 Page 281 Q. I mean, I'm sorry for such a bad question, 1 A. I remember getting doctunents from Alan 2 but in looking at these property receipts, I just 2 Dershowitz which were flight logs pertaining to 3 don't see where it tells me how much time each 3 • Mr. Epstein's plant And I subpoenaed the information 4 interview had taken. So, l mean, is there an 4 from Jet Aviation, but I don't, I don't recall preparing 5 average? a flight log. 6 A. That's not going to indicate on any property 6' • • Q. Okay. Do you remember receiving 7 . receipt. There is no... 7 information from Jet Aviation directly? Q. Right Okay. Have you ever seen the 3 MR. PIKE: Form. 9 nonprosecution agreement? 9 -THE WITNESS: Jet Aviation does not keep 10 A. No. . 10 records according to them as to who flies on 11 Q. Have you ever seen the attached list of 11 what plane. I guess you can just drive up to a 12 victims that was attached as an addendum to the 12 plane, board it. They have no idea who's on 13 nonprosecution agreement? 13 the, who is flying on the plane. They have 14 MR. PIKE: Form. 14 records of when the plane comes in, if the 15 THE WITNESS: I believe the Chief had a 15 plane is serviced, and when the plane leaves. 16 copy of it. He may have, you know, done one of 16 BY MR. EDWARDS: 17 these, but, no, not in my physical hands. 17 Q. Did you over attempt to check with customs 18 MR. PIKE: And just for the record when 18 or FAA on any of the passengers that have ever been 19 the witness said -- 19 on international flights with Jeffrey Epstein or on 20 THE WITNESS: I held it up. 20 his planes? 21 MR. PUCE: — one of these, he held up 21 MR:PIKE: Form. • 22 Exhibit 29. 22 THE WITNESS: I'm trying to recall. 23 MR. EDWARDS: Which said memorandum. 23 BY MR. EDWARDS: 24 MR. PIKE: Memorandum. 24 Q. At the current time do you have any 25 THE WITNESS: I just held it up. 25 knowledge of that being done by either the U.S. Page 280 Page 282 1 BY MR. EDWARDS: 1 Attorney's office or the FBI? 2 Q. If a memorandum exists and it is the 2 A. I have no idea what the FBI does. They are 3 attached addendum to the nonprosecution agreement 3 primarily one way. You give them the information and 4 containing the names of the underage victims, would 4 nothing comes back, so... 5 that be something in the possession currently of the 5 Q. I am starting to get that idea. I am 6 Palm Beach Police Department? 6 understanding that. Okay. 7 MR. PIKE: Form. 7 A. But you know, and I work with them almost on a 8 THE WITNESS: I don't believe so. 8 daily basis, so I am in direct contact with them. And 9 BY lvflt EDWARDS: still I have yet to see information come back the other 10 Q Is that something that's been destroyed or 10, way. 11 also - 1I Q. Just so the record is clear, when you say 12 • MR. PIKE; Form. 12 you're working with them on a daily basis, when 13 THE WITNESS: I never received a copy of 13 you're in the Organized Crime Unit on other cases, 14 it so... 14 correct? 15 BY MR. EDWARDS: 15 A. Yeah, and I am also assigned to the MT, the 16 Q. Have you ever seen it? 16 Joint Terrorism Task force here in West Palm Beach. 17 A. Like I said, I may have seen it. I may have 17 Q. My understanding from reading your reports 18 been shown it, you know, and just by holding it up and I 18 is that you also subpoenaed phone records of 19 am only using this exhibit as an example. It may have 19 numerous individuals, correct? 20 been just shown to me like this but not in my hands 20 A. Correct. 21 where I actually read the entire document. 21 Q. One of those individuals is Jeffrey 22 MR. PIKE: Move to strike. 22 Epstein? 23 BY MR. EDWARDS: 23 A. I believe so. 24 Q. In your investigation, did you prepare a 24 Q. =='? 25 flight log summary? 25 A. Yes. liSVA•c•TWAOZPIA 39 (Pages 279 to 282) PROSE COURT REPORTING. AGENCY, INC. Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 ea2a5ddb-14181-4116.63b7-dcda51494142 EFTA00298332 Page 283 Page 285 1 him contacted any of these underage females? 2 A. Yes. 2 A. Yes. 3 Q. Some of the other victims? 3 . MR. PIKE: Form. 4 MR. PIKE: Fan .4 BY MR. EDWARDS: S THE WITNESS: (Witness nods head.) 5 Q. And when you say that you were able to THE COURT REPORTER: Is that a yes? 6 make that determination, was the determination that 7 THE WITNESS: Yes. sorry. 7 Jeffrey Epstein or one of his assistants had 8 BY MR. EDWARDS: 8 contacted on the telephone these underage females? 9 Q. If you were shown those well, did you 9 A. Correct. 10 issue the subpoena — 10 Q. And where would I be able to find that 11 A. Yes. 11 information to say which underage females were 12 Q. — personally? 12 contacted by Jeffrey Epstein and/or his employees? 13 A. Yes, I did. I requested it. 13 MR. PIKE: Form. 14 MR. PIKE: Porn. 14 THE : I believe on one of these 15 BY MR. EDWARDS: 15 exhibits was the phone log, 16 Q. And did you receive it directly from the 16 • Exhibit 26. 17 carrier? 17 BY MR. EDWARDS: 18 A. Yes. 18 Q. Okay. And as has been pointed out before, 19 MR. PIKE: Form. 19 many of those names have been redacted. Am I 20 BY MR. EDWARDS: 20 correct in understanding there was an unredacted 23. Q. And when you received it, were you the 21 version that if we're able to get pursuant to court 22. person to review that material? 22 order or agreement, it's something that could be 23 MR. PIKE: Form. 23 provided by your office? 24 THE WITNESS: Yes. 24 A. Not by my office. Again everything was turned 25 25 over to the FBI. Page 284 Page 286 1. BY MR. EDWARDS: 1 Q. Okay. So, all of the documents that you 2 Q. And as part of your investigation, did you 2 have kept in your possession — strike that. I 3 look at that material and match it up to the 3 thought that in the documents that we received this 4 interviews that the young females had given and the 4 week pursuant to the public records requaLlhe 5 accounts they had given you? 5 telephone incoming-outgoing calls from 6 MR. PIKE: Form. 6 was within those documents. Is that not your 7 THE WITNESS: Some of the carriers don't 7 understanding? a keep information longer than so long. So, MR. PIKE: Form. • 9 based on the information that I was able to 9 THE WITNESS: There may have been e-mail 10 acquire, I attempted to match up the 10 to Nidde Altomat•o to put into the incident 11. information. 11 report. 12 BY MR. EDWARDS: ' 12 MR. EDWARDS: Okay. 13 Q. And with certain telephone records, were 13 ME WITNESS: And like I said, that was a 14 you able to corroborate portions of the victims or 14 document created by me as I was subpoenaed, 15 witness's testimony? 15 subpoenaing different phone numbers to identify 16 MR. PIKE: Form. 16 who these persons were. So that was just a 17 BY MR. EDWARDS: 17 little log that I created. 18 Q. or interview statements that they 18 BY 'MR. EDWARDS: 19 provided you? • 19 Q. Let me do it this way then because it 20 MR.. PIKE: Same objection. 20 sounds like you haven't looked through this 21 MR. EDWARDS: Okay. I will withdraw the 21 voluminous materials that was produced this week 22 question. Poor question. 22 pursuant to a public records request to the Palm 23 BY MR. EDWARDS: 23 Beach Police Department, correct? 24 Q. Were you able to determine whether or not 24 MR. PIKE: Form. 25 JeflreY F steinand/or one of the le empl2ild b 25 THE WITNESS: I don't know. 40 (Pages 283 to 286) PROSE COURT REPORTING AGENCY,' INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-falill -4f16.b3b7-deda51494142 EFTA00298333 Page 287 Page 289 1 MS. O'CONNOR: Correct. Why don't we do 1 investigation? 2 it this way: Tell me or I'll look through them 2 A. There were several. 3 and if there are things I know we have that are 3 Q. And on those surveillance videos were you 4 tmredacted, I will tell you whether or not we 4 able to identify underage minor females going to 5 have them, and then we can fight about whether 5 Jeffrey Epstein's home? 6 we can unredact them. 6 MR PIKE: Object to the form. 7 MR. EDWARDS: Sounds good. !just didn't 7 THE WITNESS: We were able to identify not 8 want to get into a fight if it doesn't rods'. through the video surveillance but through 9 MS. O'CONNOR: Right. 9 physical surveillance the actual person 10 • BY MR. EDWARDS: 10 standing out there watching the car pull in, 11 Q. Evidence that you collected that is not in 11 jotting down the tag number, that kind of 12 this property rillithe taped, the wired 12 thing. The video surveillance was a, was a 13 vehicle where was in the back seat 13 vehicle that we had parked and ran a video 14 talking, is that information that was also forwarded 14 camera from it just to show the traffic in and 15 to the FBI too? 15 out. 16 MR. PIKE: Form, asked and answered. 16 BY MR. EDWARDS: 17 THE WITNESS: Yes. 17 Q. Okay. And did that video camera capture 18 MR. PIKE: Can you give me a minute? 18 the traffic that was going in and out of Jeffrey 19 MR. EDWARDS: Sure. 19 Epstein's house; is that what you are telling me? 20 (A brief recess was held.) 20 MR. PIKE: Form. 21 BY MR. EDWARDS: 21 THE WITNESS: Yes, that's what it was 22 Q. The originals of the propel y were handed 22 intended for. However, for identification 23 over to the FBL But where it indicates that this 23 purposes it's difficult because of the lighting 24 material was copied, were all the copies also handed 24 situation. 25 over to the FBI? 25 Page 288 Page 290 1 A. Yes, sir. 1 BY MR. EDWARDS: 2 MR. PIKE: Form. 2 Q. Where was that car positioned? 3 BY MR- EDWARDS: 3 MR. PIKE: Form. 4 . Q. Even the copies that were made for 4 THE WITNESS: Flintier up the block from 5 P.B.S.O., that was handed over, turned over to the 5 the house, towards by the Intracoastal. This 6 FBI as well? 6 was parked up the block. 7 MR. PIKE: Form. 7 BY MR. EDWARDS: 8 THE WITNESS: For P.B.S.O., I don't know 8 Q. Did you do any of the personal 9 what copies were made for P.B.S.O. 9 surveillance writing down tags and whatnot? 10 BY MR. EDWARDS: 10 A. No, that would have been, that would have been 11 Q. Where it would indicate hard drive copied 11 the Burglary Strike Force. 12 from Number 55 to P.B.S.O., isn't that indicating 12 Q. Did you ever speak with Ghislaine Maxwell? 13 that the hard drive is being copied for the Palm 13 A. No. 14 Beach Sheriffs Office? 14 Q. Did you ever attempt to speak with her? 15 A. The hard drive was taken over by now Sergeant 15 A. No. 16 Krouel. That was to be analyzed. If you see further 16 Q. Did her name come up during your 17 down CPU was actually returnod. 1? investigation? 18 Q. All right. You obviously looked at all 18 • MR. PIKE: Form. 19 the evidence that was taken from the house; is that 19 THE WITNESS: I researched her based on 20 correct? 20 the media that I had found dining her 21 MR. PIKE: Form. 21 association with Mr. Epstein. 22 THE WITNESS: Yes, sir. 22 MR. PIKE: Move to strike. Go ahead. 23 BY MR. EDWARDS: 23 BY MR. EDWARDS: 24 Q. And do you remember how many surveillance 24 • Q. During your investigation did — • 25 videos were made by eur office in relation to this 25 MR. KUVIN: What was your response? .a j 41 (Pages 287 to 290) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601- Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb.14181-4(16-b3b7-dcda61494142 EFTA00298334 Page 291 Page 293 1 THE WITNESS: I researched her based on 1 MR. EDWARDS: Correct. 2 her association. 2 THE WITNESS: I remember she said he kept 3 BY MR. EDWARDS: 3 some of her art He inspired her to create 4 Q. After researching her, did you ever 4 another piece of art I am hying to think. I 5 attempt to make any contact with her? 5 remember her telling me that they had some 6 A. No. 6 relationship because he got friskier and 7 Q. Did other witnesses call into you or your 7 friskier. 8 department with information related to Jeffrey MR. PIKE: Move to strike that as 9 Epstein during your investigation? 9 nonresponsive. 10 MR. PIKE: Form. 10 BY MR. EDWARDS: 11 THE WITNESS: I don't follow the question 11 Q. When you say that is a separate case, 12 on it. 12 061078, what do you mean by a separate case? 13 BY MR. EDWARDS: 13 A. The initial incident report is 05368. That 14 Q. Okay. Bad question. During your 14 one was generated after the arrest when other people 15 investigation, did you receive any calls from local 15 were calling in. 16 citizens saying we have information that could be 16 Q. Was it because of a different 17 helpful to this investigation? 17 investigation related to Jeffrey Epstein or an 18 MR. PIKE: Form. 18 additional investiption? 19 THE WITNESS: Not during the 19 MR. PIKE: Form. 20 investigation, no. 20 THE WITNESS: Yes, it would have been 21 BY MR. EDWARDS: 21 people outside of 05368. 22 Q. Okay. Who is — sorry. Do remember 22 BY MR. EDWARDS: 23 speaking with somebody named from 23 Q. Olcay. Outside of the telephone call that 24 New York City? 24 is memorialized in the =Vs did you have 25 A. Yes. 25 occasion to speak with Ms. on any other Page 292 Page 294 1 Q. And how did you, what was the occasion to 1 occasions? 2 speak with ha? 2 MR. PHO3: Form. 3 A. That was after the arrest of Mr. Epstein. Sbe 3 THE WETNESS: I don't believe so. 4 phoned in to tell me that she had had dealings with him 4 BY MR. EDWARDS: in the past. She said that she had a relationship with 5 Q. You also remember getting a call from -- 6 him. 6 A. A girl from California 7 Q. Do you remember what she did for a living? 7 ' Q. "e a 8 MR. PIKE: Wait one second. Move to 8 A. (phonetic). 9 strike, nonresponsive. And your question is 9 Q. right Do you remember what she 10 finished or no? 10 told you? 11 BY MR. EDWARDS: 11 MR. PIKE: Form. 12 Q. Do you remember what Ms. .did for a 12 THE WITNESS: I believe that she also had 13 living? 13 a relationship with Mr. Epstein but I am trying 14 MR. PIKE: Form. 14 to remember. 15 THE WITNESS: She was an artist. 15 BY MR. EDWARDS: 16 BY MR. EDWARDS: 16 Q. Okay. It's obviously been since 2006 when 17 Q. And when she described the relationship as 17 you wrote the report. Have you looked over this 18 you just phrased it with Jeffrey Epstein, did she 18 report at all? 19 indicate that it included massages? 19 A. No, I didn't look over that report at all. 20 MR. PIKE: Form. 20 Q. Do you remember her indicating that 21 BY MR. EDWARDS: 21 Jeffrey Epstein was hying to go further and further 22 Q. If you remember. 22 with a massage and her asking what, what are you 23 MR. PIKE: Same objection. 23 doing, to which he replied don't you want to get 24 THE WITNESS: mat's on a separate case. 24 into Victoria Secret? 25 That's on 061078, correct. 25 MR. PIKE: Form. evAldAtraq 42 (Pages 291 to 294) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ridb-fa81-4116-b3b7-dcda61494142 EFTA00298335 Page 295 Page 297 1 THE WITNESS: I do recall that. 1 something that has been forward to the FBI and you 2 MR. PIKE: Hold on one second. Form and 2 don't have a copy of it? 3 leading. Move to strike. 3 A. Correct 4 BY MR. EDWARDS: 4 Q. Back in 2003 investigating the robbery, I 5 Q. Does that refresh your recollection? 5 guess it was ultimately determined that Juan Alessi 6 A Yes, I do recall that I believe she was an 6 was the person that committed the robbery? 7 aspiring — and she wanted to become a model. 7 A. The burglary, yeah. 8 Q. Okay. And we have spoken earlier about . And also in the house was 9 Leslie Wexner being the CEO of Victoria Secret, 9 and Did you speak 10 correct? 10 with those people? 11 A Correct. 11 A. No. 12 Q: Did you ever attempt to talk to Leslie 12 Q. That's just, you take down their name, 13 Wexner? 13 date of birth, just responding to the call? 14 A No. 14 A. I don't believe I did a supplement on that 15 Q. Even after this particular comment was 15 case. That might have been some other detective. I 16 made and the association or affiliation that was 16 believe Melnichok was the investigating detective on 17 previously determined between Epstein and Wexner, 17 that. 18 was there any follow-up related to that connection? 18 Q. Okay. 19 A No. 19 A. Like I said, my part was very small and I just 20 MR. PIKE Form. 20 put the camera up. 21 THE WITNESS: No. 21 Q. So, most of the detailed questions about 22 BY MR. EDWARDS: 22 that particular burglary, if it's at all relevant to 23 Q. Did you ever try to speak with Gerald° 23 this case, would have to go through whoever was the 24 Rivera? 24 detective on that case? 25 ' No. 25 A. (Witness nods head.) Page 296 Page 298 . Have ou ever spoken with 1 THE COURT REPORTER: Is that a yes? former house managers or 2 THE WITNESS: Yes. 3 housekeepers of Jeffrey Epstein? 3 BY MR. EDWARDS: MR. PIKE: Form. 4 Q. Did you testify before the grand jury -- 5 THE WITNESS: No, no. I spoke with the 5 MR. PIKE: Form. 6 Alessi's and Rodriguez. 6 THE WITNESS: Yes, I did. 7 BY MR. EDWARDS: 7 BY MR. EDWARDS: 8 Q. 'And also I saw the names mentioned Patrick 8 Q. related to Jeffrey Epstein at the State 9 and Evelyn as being formerly employed as house 9 Attorney's Office level? 10 managers. Are those people that you have tried to 10 A. Yes. 11 back down? 11 MR. PIKE: Form. 12 . MR. PIKE: Form. 12 BY MR. EDWARDS: 13 THE WITNESS: I believe I attempted but I 13 Q. Was there a grand jury proceeding at the 14 couldn't locate where they vivre. 14 federal level that you're aware of? 15 • BY MR. EDWARDS: 15 MR. PIKE: Form. 16 Q. Were you ever able to get a last name of 16 THE WITNESS: I have no idea. 17 Patrick and Evelyn? 17 BY MR. EDWARDS: 18 A. I don't recall. I can't recall. 18 Q. Do you know what was presented to the 19 Q. Okay. Is that something that you would 19 grand jury relative to the Jeffrey Epstein 20 have in your possession to refresh your recollection 20 investigation? 21 or is that something that -- 21 MR. PIKE Form. 22 A. No. I think it might have been during the 22 THE WITNESS: The state grand jury? 23 . interviews of the previous housemen but -- 23 MR. EDWARDS: Correct. 24 Q. Okay. Any those interviews of the 24 THE WITNESS: I don't know aside from my 25 previous housekeepers or house managers that's all 25 portion of my statement that [provided. 43 (Pages 295 to 298) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkIns (601 aa2a6ddb.fa81-41164ab7-dcda51494142 EFTA00298336 Page 299 Page 301 1 stuck around just to assist the victims. 1 between the Palm Beach Police Department and the 2: BY MR. EDWARDS: 2 State Attorney's Office? 3 Q. And when you talk about the statement that 3 A. Yes, there was. 4 you provided, did you present testimony related to 4 Q. And -- 5 all of the minor females that you discovered to have 5 A. This case was originally brought to their 1 6 come in contact with Jeffrey Epstein or only the 6 attention very early on in the investigation to which 7 four or five names that ultimately were at the end 7 they were, you know, very gung-ho, very let's go, let's 8 of your probable cause affidavit? 8 do this, up until, up until, up until the meeting with 9 ' MR. PIKE: Form and compound. 9 Alan Dershowitz and the State Attorney. And then it, ii 10 THE WITNESS: As far as my testimony at 10 all took a turn. 11. the grand jury, I only answered the questions 11 Q. Were you at that meeting? 12 that were asked of me by the state. At that 12 A. I attended one meeting where I believe it 13 • poi lit was Latina Belohiavek. 13 Dershowitz, Krischer, and Belohlavek. 14 El sorry about the last name. I don't 14 MR. PIKE: Object to form. 15 know how to spell her last name. 15 BY MR. EDWARDS: • 16 BY MR. EDWARDS: 16 Q.: What was said during that meeting? 17 Q. And in talking with the State Attorney's 17 MR. PiKE: All right. With regard to this 18 Office during the investigation, did you indicate to 18 line of questioning, I just want to be clear 19 them the number of underage females that you were 19 that I have form objections to this line of 20 aware had come in contact sexually with Mr. Epstein? '20 questioningg. And the fact that under various 21 MR. PiKE: Form and assumes facts not in 21 Federal Rules, I believe it's 408, 410 as well 22 evidence. 22 as various rules under Florida Evidence Code, 23 THE WITNESS: Yes, they were aware of the 23 some of these discussions are protected as 24 . probable cause affidavit which indicated all 24 potential plea negotiations. So, having said 25 the facts. 25 that... Page 300 Page 302 1 BY MR. EDWARDS: 1. BY MR. EDWARDS: 2 Q. And can you recall what their position was .2 • Q. What was said during these, this meeting 3 on the various acts that are related in the probable 3 that you attended? 4 . cause affidavit? And ultimately I am asking why is 4. A. Several of the girls' MySpaces were discussed. 5 it that they were not interested in hearing from all 5 MySpace being the social network. They all had 6 of the girls and only a select few? 6 MySpaces. And the girls, the girls were actually who 7 . MR. PIKE: Form and compound. 7 had the MySpaces had inputted, you know, various 8 THE WITNESS: That's a question that 8 different things regarding alcohol use or marijuana use .9 you're going to have to ask Lonna Belohlavek '9 or that kind of thing. 10 . because she was aware of all the people that I 10. Q. And what was broUght up at that meeting as 11 submitted to her, and yet she choose three 11 to the relevance of whether or not these females 12 people to appear before the grand jury, one 12 . that had been to Jeffrey Epstein's house while 13 ;mowing that she was not going to be able to 13 underage used alcohol or drugs? What was the point 14 appear. 14 of that? 15. . MR.PIKE: Move to strike. 15 MR. PIKE: Font 16'. BY MR. EDWARDS: 16 THE WITNESS: To show that the character 17. Q. And who was the person that was not going 17 of the girls were not, was not to be believed. 18 to be able to appear? 18 .• BY MR. EDWARDS: 19. A. That would have been Jane Doe No. 103. . 19 ' Q. Okay. It was specifically to attack their 20 Q. Do you know why she was unable to appear? 20 credibility? 21 A. • Because it was finals week in her university 21, MR. PIKE: Form, move to strike. 22 and the limited time that they had scheduled the grand 22' . s THE WITNESS: Correct. 23 jury and the time that it would have been for her to 23 BY MR. EDWARDS: 24 make arrangements to come down was very short. 24: • . . Q. So, at that poiM in time who was =Icing 25 Q. Was there a disagreement about this case 25. • • those arguments on behalfofJeffi ebe 44 (Pages 299 to 302) (561) ..832-7500 PROSE COURT REPORTING AGENCY, INC.. Electronically signed by synth's hooking (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (801 aa2a6ddb.fai-iff6-b3b7-dcda61494142 EFTA00298337 Page 303 Page 305 1 MR. PIKE: Form. 1 BY MR. EDWARDS: 2 THE WITNESS: It was Alan Dershowim. 2 Q. Happens all the time, right? 3 BY MR. EDWARDS: 3 . A. Yes. 4 Q. And was the argument that you can't 4 . MR. PIKE: Same objection. 5 believe these girls about what they're saying 5 • BY MR. EDWARDS: 6 transpired at Jeffrey Epstein's house because of 6 . . . Q. But for whatever reason the State 7 what we're viewing, material they chose to put on 7: Attorney's office was entertaining this argument? 8 their MySpace pages? 8 ' A. Absolutely. At that point they started to 9 ' MR. PIKE: Form and leading and compound. 9 back off. And then they are, like, well, you can't — 10 And is there a question? 10 . this girl is not a victim; this girl is this, you know, 11 BY MR. EDWARDS: 11. that kind thing. 12 Q. You understood, you understood that ended . 12 • Q. Was there ever a time when the State 13 with a question mark, right? 13 ' Attorney's Office bought into an argument that you 14 A. Yes. 14 can't even believe these girls when they testify 15 MR. PIKE: I just want to make sure of 15 about what transpired at Jeffrey Epstein's house? 16 that. Can you reread the question for me, 16 MR. PIKE: Form. 17 please. 17 THE WITNESS: I had that impression, that 18 (The requested portion of the record was 18 kind of thing where these girls were not 19 read by the reporter.) 19' victims. 20 M. PIKE: Saute objection. 20 ..BY MR. EDWARDS: 21 THE WITNESS: That's correct 21 •• • Q. You talked to many girls that didn't even 22 BY MR. EDWARDS: 22 know one another, correct? 23 Q. And I ask because I want, I want to make 23 ' A. Some didn't go to the same schools, correct. 24 sure that — well, I want to understand it was that, 24 . . MR. PIKE: Form. 25 hey, these girls have done a lot of bad things; 25 Page 304 Page 306 therefore, they am not sympathetic enough to 1 BY MR. EDWARDS: 2 prosecute the person that committed crimes against 2 Q. And in speaking with them, they each 3 them; or these girls have said a lot of things on 3 described an almost ritualistic process that 4 their MySpace page, therefore, they can't even be 4 happened inside Jeffrey Epstein's bedroom with each 5 believed about what transpired at his house. 5 • one of them, correct? 6 Do you understand the difference? 6 MR. PIKE: Form. 7 MR. PIKE: Fonn. 7 THE WITNESS: Correct. 8 THE WITNESS: Well — 8 BY MR. EDWARDS: MR. PIKE: Wait a second, Detective. 9. .Q. And that was something that was made clear 10 Form, compound, and speculative and hearsay. 10. to the State Attorney's office? 11 THE WITNESS: It was more to the effect 11• A. Correct. 12 of, you know, these girls are not saints; look 12 . MR.PIKE: Form. 13 at the stuff that they are posting out there 13 BY MR. EDWARDS: 14 for everyone to see, et cetera, et cetera. 14 Q. And at some point in time Chief Reiter 15 That kind of thing. 15 wrote a letter to Mr. Krischer in May of 2006 16 BY MR. EDWARDS: 16 indicating that he believes Mr. Krischer should 17 Q. Okay. But I mean, you have been a 17 disqualify himself from prosecuting the cases. Are 18 detective for how many years? 18 you aware of that? 19 A. Fifteen. 19 • A. Yes,' am. 20 Q. And you investigate an attempted murder, 20 • Q. And you have seen that letter before? 21 still prosecute the attempted murder even if he is 21 A. Yes, I've seen it before. 22 tying to shoot a gang member, right? 22 Q: And he also indicates in it it is • 23 MR. PIKE: Form, relevance. 23. regrettable that I am forced to communicate in this 24 THE WITNESS: AbSolutely. 24 manner, but my most recent telephone calls to you 25 25 and those of the lead detective to our assi s ed 45 (Pages 303 to 306 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cyntlga honking (601 Electronically signed by c-ynthia hopkins (601 Electronically signed by cynthia hopkins (601 ae2a6ddb.fa81.4ff6•b3b7.dcda61494142 EFTA00298338 Page 307 Page 309 1 attorneys have been unanswered and messages remain 1 A. Correct. 2 =owned. Is that a statement that you agree 2 MR. PIKE: Form. 3 4 5 with? A. Absolutely. Q. How many messages do you think that you 3 4 5 a. BY MR. EDWARDS: So, are you talking about" and Jane Doe No. 103? 6 left the State Attorneys Office that were 6 MR. PIKE: Form. 7 unearned? 7 ME WITNESS: Frowns family I had 8 A. Quite a few. I actually showed up at Lanna's gotten multiple phone callsduring that day. 9 office because I had left her several messages and BY MR. EDWARDS: 10 didn't, didn't return get a return phone call. And it 10 Q. During any of the meetings — how many 11 was during the time where: We're going to the grand 11 meetings are you aware of that Mr. Dershowitz 12 jury, no, we're not going to grand jury, yes, we're 12 participated in with the State Attorney's Office? 13 going no, we're not. 13 A. There were a couple. Like I said,1 attended 14 And it was, I believe, the following day 14 one. 15 when we were supposed to go to the grand jury and I 15 MR.-PIKE: Form. 16 still had not heard from her as to what time nor had 16 THE WITNESS: I didn't attend the second 17 I received a subpoena. So, I had contacted her 17 one. I want to say two to three. 18 numerous times during that day. I would say three 18 BY MR. EDWARDS: 19 to four times during that day. In the afternoon I 19 Q. And he is a person who also is found in 20 actually showed up at her office where she was 20 the message pad as somebody who has called Jeffrey 21 sitting in her office. 21 Epstein's home, correct? 22 Q. Did you speak with her? 22 A. As far as I can recall, yes. 23 A. Yes, I did. 23 Q. And did he ever indicate to them that he 24 Q. And what happened within that 24 was actually at the home on various occasions when 25 conversation? 25 some of these underage girls would come over to -3 Page 308 Page 310 1 MR. PIKE: Form. 1 Mr. Epstein's house? 2 THE WITNESS: There was actually a time 2 MR. PIKE: Form. 3 where there was a plea negotiation being 3 . THE WITNESS: Not that I recall. 4 discussed where it was to one count of felony, 4 BY MR. EDWARDS: 5 five years probation, and I believe no one had 5 Q. In fact, was he trying to convey to the 6 been contacted regarding to that negotiations. 6 State Attorney's office that you should not believe 7 BY MR. EDWARDS: 7 these girls that they were at his house at all 8 Q. When you say no one, are you speaking 8 because they have credibility problem's? 9 about the police or victims? 9. MR. PIKE: Form, asked and answered. 10 MR. PIKE: One second. Form. I'm going 10 THE WITNESS: That's, that was the 11 to move to strike and I am going to continue to 11 impression I received, yes. 12 assert the same privileges under the Federal 12 MR. EDWARDS: The.next portion is going to 13 Rules 408, 410, and 401.9. I'm sorry. Go 13 take a long time. I mean it's getting into the 14 ahead. 14 juice of it. So, are we at a point that you 15 BY MR. EDWARDS: 15 want to stop rather than getting into something 16 Q. When you say no one had been contacted, 16 that's going to take a long time? 17 are you speaking about no police officers that were 17 MS. O'CONNOR: How long? 18 on the case or no victims? 18 MR. EDWARDS: Couple of hours. 19 A. Both the police officers and the victims 19 MS. O'CONNOR: I need to stop. 20 because I was getting phone calls from the victims' 20 MR. KUVIN: Okay. 21 parents as to what time are we needed. 21 MR. PIKE: Ail right. So we are going to 22 Q. And when you say we were getting phone 22• break. We have an agreement on the record that 23 calls front the victims' parents, are those the 23 Detective Recarey, and correct me if I am 24 victims that ultimately were listed as victims in 24 wrong Ms. O'Connor will get back to us through 25 Cher in the plea that transpired? 25 you sometime weekvithi a few available 46 (Pages 307 to 310) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aitaaddbfell1-41164307-deda51464142 EFTA00298339 Page 311 Page 313 I dates sometime in April. And then counsel who 1 need a mini or any of that. 2 are here at this table will endeavor to pick 2 MS. ARBOUR: I don't need a fdl copy. 3 some dates that are most convenient so we can 3 Just a mini. I don't need any of that other 4 expeditiously complete Detective Recarey's 4 stuff. 5 deposition. 5 MS. O'CONNOR: We're going to read. 6 MR. EDWARDS: Agreed. 6 (Witness excused.) 7 MS. O'CONNOR: Complete in one day. 7 (Deposition was concluded.) 8 MR. KUVIN: Yep. 9 MR. PIKE: I hope to do that. ‘:) 10 MR. EDWARDS: I can get through mine in 10 11 three hours. 11 12 MS. O'CONNOR: We're supposed to only be 12 13 having one day in your order. 13 14 MR. PIKE: Well, kind of, sort of; kind 14 15 of, sort of. 15 16 MR. KUVIN: We're doing state and federal, 16 17 so ifs a mixture. There is no state order. 17 18 (A discussion was held off the record.) 18 19 MR. PIKE: I can tell you this, at past 19 20 depositions that deal with witnesses such as 20 21 Detective Recarey or any other alleged 21 22 witnesses, despite whether or not a lawyer 22 23 represents one, two, or seven alleged 23 24 Plaintiffs, it is not appropriate to rehash 24 25 background information pursuant to the court's 25 Page 312 Page .) I •: 1 orders that have already been entered and waste 1 CERTIFICATE OF OATH 2 a witness's time. 2 THE STATE OF FLORIDA 3 So hopefully we can all abide by that and 3 COUNTY OF PALM BEACH concentrate on our individual and particular 4 5 S clients at those depositions. 6 I, the undersigned authority, certify that 0 MR. EDWARDS: Certainly no one will 7 DETE,CTIVE JOSEPH RECAREY personally appeared intentionally do that but I just wanted to say 8 before me and was duly sworn on the 19th day of 3 that since I am questioning right now, I think 9 March, 2010. 9 that I am the only one with an eminent 10 10 discovery deadline. So, I will get through my 11 Dated this 1st day of April, 2010. 11 portion and whatever happens after that — 12 12 MR. PIKE: You and me. 13 14 13 MR. EDWARDS: Right. 15 14 (A discussion was held off the record.) 15 THE COURT REPORTER: Do you want to order 16 16 this? Chia Hopki 17 MR. KUVIN: No, I don't. 17 ti/cc 18 MR. PIKE: You know, I do need that, but I CommissionExpires: 5,2011 19 need it regular. And I need it for reasons 18 My Commission No.: DD 64 20 that I don't want to state. 19 21 20 Job N1509 THE COURT REPORTER: Does anyone want a 21 22 copy/ 22 23 MS. ARBOUR: Yes. 23 24 MS. EZELL: I want a copy too. 24 25 MR. EDWARDS: I just want a copy. I don't 47 (Pages 311 to 314) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (801 ea2a5ddb-fa81-41f6,b3b7-dcda51494142 EFTA00298340 Page 315 Page 317 CERTIFICATE 1 CERTIFICATE 2 THE STATE OF FLORIDA 3 COUNTY OP PALM BEACH 2 4 3 THE STATE OF FLORIDA 5 I, Cynthia Hookas. Regiatered Profusion.' Reporter, Florida Professional Reporter, and Notary 4 COUNTY OF PALM BEACH 6 Pattie in and for the Sate ofFlorida at large, do 5 I hereby certify that I have read the foregoing hereby cat? ? that lams authorized to and did report Si deposition in stemlym and dal the 6 deposition by me given, and that the statements foregoing ppm emotive Si Carat transcription 7 contained herein are true and correct to the best of 8 ofmy atethand notes of said deposition 9 I father eenify tint said deposition was 8 my knowledge and belief, with the exception of any atm at the toe and place haeinabove set forth 9 corrections or notations made on the errata sheet, to and that the taking ofmid depositket was commenced and carpeted as haeinabcne moue 10 if one was executed. 11 11 I pother catilY that I am not money a 12 cowed ofany of the penis. nor am I a relative 12 Dated this day of or employee of any attorney or camel of pony 13 2010. 13 connected with the aCteart, nor amp finamially berated in the edict 14 14 15 The foregoing cenigration of this trareaipt 15 does not apply to any rtprodatioo of the sane by 16 any men unless under the dna control ancitor 17 16 diadem of tit certifying repent/. 17 Dated this Iii day of Aga 2010. 18 18 19 DETECTIVE JOSEPH RECAREY 19 20 20 Job #1509 21 22 eckilti*rs 4 21 22 Job/ 1W9 23 23 24 24 25 25 Page 316 Page 318 1 DATE: April 1,2010 1 ERRATA SHEET 2 TO DETECTIVE JOSEPH RECAREY Job81509 2 IN RE: Jane Doe No.2, Jane Doe JOANNE M. O'CONNOR. ESQUIRE No. 103 and 88. 3 JONES. FOSTER JOHNSON at STUBBS,PA. 3 CR: Cynthia' Hopkins, RPR, FPR 503 South Flashy Drive. Suite 1100 4 Wm Pala Beath, Florida 31101 DEPOSMON OF: DETECTIVE JOSEPH RECAREY 5 JERE Jay Doe No. 2, Jane Doe No. 103, and B B. 4 TAKEN: Match 19, 2010 6 Please take notice Nate Friday, the Ina of JOB NO: 1509 Asa 2010, yen gave your deposition in the 7 aboyearefarei antler. At that that you did not 6 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE want signalise. his row natessay that you alga 7 PAGES LINEN CHANGE REASON 8 your depcsition As a pofessicad «aim. we are sondsag yes 9 8 evil at 10 . Althea, o e Intnage you at San 9 drab duet. As feu mad year deposition. any 11 Mangos or acre:dons that yon with termite should 10 lie noted* the ernes aka, ening page aid line 11 12 ember of saki change. DO NOT wile ate 12 rimcuipt itself One you brit read the 13 13 trawript and rated any dazes. be two to sip Si date the emit* thee* and return these pages to 14 14 rte. Yoe andid return the entire tranaript. If 15 arm do ace read and aip the topsail within a 16 15 learnable tims, the caging& *bleb has already 17 been foroarded to the adaieg 'Raney, may be 18 Please Reward the original signed Cat sheet to 16 tikd nig& due Clerk ofthe act IfMu Mat to this office so that copies may be distributed to naive yogi alpenum, sign year rim in the NM* at 19 17 the bottom of this letter and mnuq it to us. all punks. 18 20 Under pawky of perjury, I declare thatlhave read 19 793 1!' AS my deposition and that it is tit and correct 20 licaltins,RPR,FPR 21 subject to any changes in form or substance entered 21 I do hatby nano my signatan. hit 22 22 23 DETECTIVE 3OSPAH RECAREY 23 DATE: 24 I do hereby wane my Aspatore: 24 Cc Via trarceript. Bradley J. Eduard., Esquire 25 Katherine W' Ezell Estjuire, MichaelPik Entire., 25 SIGNATURE OF DEPONENT: 48 (Pages 315 to 318) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthla hopkins (601 Electronically signed by synth's honking (601 saddcWall1-4116-b31041cds51494142 EFTA00298341