EFTA00298342

Page 500 I', -1r 502 1 2 IN 741E CIRCUIT COURT OF THE FIFTEENTH JUDICIAL MOAT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.50200SCA037315000004B AB 1 2 1 APPEARANCES On tehalf Janc Den I thectralt 8: JESSICA BOOK ESQUIRE I MERME1812:214 & HOROW112, l'A. 3 W205 lagoon nukearr1 Son 2218 4 S M phon ironit e Plaintiff. 5 6 7 On batonMtn Plaintiff, lane Doe Nall: 6 -vs- VOLUME IV OF IV ISOM MANUEL Minn mom 7 GARCIA. ELKINS & BOEFIFUNGER 9 224 Dina Mew Saito 900 War tide 33401 Defendants Phan 9 I 11 sad 12 TARA k FINNIGAN,!MUM 10 TARA& FINNIGAN.PA 11 13 VA Miura Street 12 DEPOSITION OF State WO DETECTIVE JOSEPHRECAREY 14 West Pailliarida 33401 13 Mono 14 Friday,March 19, 2010 15 16 an Wulff of the Datong,hffny Emleos 15 10:03 - 5:23 p m 17 MICHAEL PIKE, ESQUIRE 16 505 South [take Drive BURMAN, CRIITOR LETT/ER& COLEMAN, LIP Suite 1100 la 303 014066 Boolean 17 West Palm Beach, Florida 33401 Stile 4'.0 18 19 West /MC 33401 19 Phone' 20 20 and 21. 21 22 a Reported By. MIUION O. WhlMIRO. ESQUIRE Jana Ricciuti. Mit FPR. CLR 22 LAW00110E OF MILTON G. WEINBERG 23 Notary Public. Stew ofFlorida 20 Pin Pima 23 Suite WOO, Prose Gault Reporting Bent 02116 24 24 Moue: 25 25 Page 5C. Page 503 1 1 Appearances continued... 2 uNDED STATES DISTRICT COURT 2 On behalf of the Witness: ' SOUTHERN DISTRICT OP FLORIDA 3 3 JOANNE M. O'CONNOR, ESQUIRE CASE NO.10-80309 JONES, FOSTER, JOHNSON & STUBBS, P.A. 4 505 South Flagler Drive, Suite 1100 5 JANE DOE NO. 103. West Florida 33401 Plaintiff, 5 Phone: 7 VOLUME IV OFIV 6 JRPFREY CPSIEIN, 9 Defendant. 7 Also Present Jeffrey Epstein 8 10 9 11 10 12 DEPOSITION OF 11 DEIECTIVE JOSEPH RECAREY 12 13 14 Tuesday, April 27, 2010 13 15 10:03 - 5:23 pm. 14 16 505 Saab Flagler Drive 15 Stitt 1100 16 17 Weft Palm Beach, Florida 33401 17 18 18 19 20 19 21 20 22 Reported By: 21 Jam Fticciuti, RPR, FPR, CLR 22 23 Notary Public, State ofFlorida 23 Prose Cain Reporting 24 24 25 25 .... - 2 (Pages 500 to 503) PROSE. COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601 ) Electronically signed by Jeana RIccluti (601 ) bdcd1876•c7242.432(1-8c40-0190e656129/ EFTA00298342 Page 504 Page 506 1 1 counsel? INDEX 2 MS. ARBOUR: Form. 2 3 THE WITNESS: I believe so, yes. 3 I wrrNESS: COMM CROSS CROSS REDIRECT RECROSS 4 BY MR. WEINBERG: 5 DETECTIVE JOE RECAREY 5 Q. And that was an offer that was extended by the 6 BY MR. WEINBERG 505 6 State Attorney following discussions with the Palm Beach BY MS. ARDOUR 636 7 Police Department, correct? 7 BY MR. GARCIA 636 8 A. That was when we had just heard about it. We 9 9 were unaware that the offer was made. 10 --- 10 Q. And how did you become aware that the offer EXHIBITS 11 was made? 11 12 A. I had made numerous telephone calls to the 12 NUMBER DESCRIPTION PAGE 13 13 State Attorney's office to inquire where we were, and DEPOSITION EX. 29 MESSAGE BOOKS 592 DEPOSITIONEX. 30 HANDWRITTEN NOTE ON 617 14 did not receive any return phone calls. I went over to 14 JEFFREY E. EPSTEINMEMO 15 the State Attorney's office personally on an tmrelated PAD 16 incident to drop off some filittpackets, and that's 15 DEPOSITION EX. 31 HANDWRITTEN MESSAGE 622 17 when I went by and I saw =was in her office. 16 17 18 Q. was an experienced State attorney, 18 19 correct? 19 20 MS. ARBOUR: Form. 20 21 THE WITNESS: I know she had been there for 21 22 some time. 22 23 23 BY MR. WEINBERG: 24 24 Q. And you knew she had been a prosecutor for sex 25 25 offense cases for some time, correct? Page 505 Page 507 1 PROCEEDINGS 1 A. She did a lot of crimes against children. 2 2 Q. And she, on other occasions, advocated 3 BY MR. WEINBERG: 3 prosecution of people on felony charges, correct? 4 Q. Good afternoon, sir. 4 A. I hadn't had many dealings with her so I don't 5 A. Good afternoon. 5 know. You know, l knew Mier. She was actually at the 6 Q. To finish up the subject that we were talking 6 office, State Attorney's office, when I was employed 7 about right before the recess, do you ever recall 7 there many years ago. 8 dicr-ncsions with the State Attorney's office about an 8 Q. And that was how many years ago? offer that was extended to Mr. Epstein to plead guilty 9 A. I've been with Palm Beach almost 19 years. 10 and receive a five-year period of probation for an 10 Q. So we're talking about at least 20 years ago? 11 aggravated assault charge? 11 A. Yeah. 12 A. Yes. 12 Q. And she had been there, to your knowledge, 13 Q. And that was a subject ofdiscussion between 13 continuously from the time that you knew she was there 14 you and members of the State Attornes fice? 14 20 years ago? 15 A. With Assistant State Attorney 15 A. Yeah. 16 I don't know if that's her last name, how 16 Q. And you knew her specialty to be charging 17 it's pronounced, but close enough. 17 people that were — for offenses that dealt with 18 Q. If we call her =, I think we both know who 18 violations of underagtal people, mama 19 we're discussing. 19 MS. ARBOUR: Fonn. 20 A. Yeah. 20 THE WITNESS: I believe so. I believe so. 21 Q. And those discussions occurred within or 21 Like I said, I didn't have many dealings with her. 22 around the winter of 2005,'6? 22 BY MR. WEINBERG: 23 A. I believe so. 23 Q. So you saw her in the office that day? 24 Q. And was that a sentence and a charge option 24 A. And that was the time that I just had learned 25 that was extended to Mr. Epstein through his then 25 of the offer that was made to previous counsel. 3 (Pages 504 to 507) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana ificciuti (801M Electronically signed by Jeana Moduli (601 bdecH 876 c72o.432d-8c10-bt 9ac656129t EFTA00298343 Page 508 Page 510 1 Q. And did you take a position on that offet? 1 correct? 2 A. Personally, I told her I didn't agree with it, 2 MS. ARBOUR: Form. 3 but I couldn't speak for the department. It actually 3 THE WITNESS: f know that when there's 4 had to come from people with a higher pay grade than 4 misdemeanor arrests in the Town of Palm Beach, a 5 mine, so I just relayed the information back to 5 lot of officers pretty much try to gain any 6 Chief Reiter. 6 intelligence they can from any of the people that 7 Q. And what, if anything, did Chief Reiter do? 7 they encounter. Some of the information actually 8 MS. ARBOUR: Form. 8 leads to other cases, clearance ofminor rocas 9 THE WITNESS: I believe he tried to make 9 thefts, bike thefts. 10 contact with State Attorney Barry Krischer. 10 BY MR. WEINBERG: 11 BY MR. WEINBERG: 11 Q. And in this case, it led to you going to sec 12 Q. Did he make contact with State Attorney 12 Jane Doe 103, first calling her on October 10th and then 13 KriSehe', to your knowledge? 13 visiting ha in Jacksonville on October 11th, correct? 14 A. I'm not 100 percent certain if he did or 14 A. Yes. 15 didn't. I bow there was some time where none of our I5 Q. And you also, in your investigation, learned 16 calls were being returned from the State Attorney's 16 that Jane Doe 103 had lost her job at Victoria Secret 17 office. 17 for stealing, did you not? 18 Q. Jane Doe 103 was one of the witnesses who was 18 A. No. 19 at the center of the State investigation, correct? 19 Q. You never received any information regarding 20 A. One of them, yes. 20 Jane Doe 103's employment history with Victoria Secret? 21 Q. And you knew that Jane Doe 103 had a MySpace 21 A. She was actually employed there when I went up 22 page that was one of the MySpace profiles that was 22 to seeker. Thrift where I met with her. 23 provided to the State Attorney by Mr. Epstein's then 23 Q. Did you ever team at any time that she had a 24 counsel, Professor Dersbowitz, correct? 24 problem that led to her losing her employment? 25 A. Yes, I knew that there were pages sent of the 25 A. No. Page 509 Page 511 1 MySpaces, but I wasn't sure of whom at that particular 1 Q. So you knew she had been arrested for 2 time. They provided us copies thereafter, but right 2 marijuana? 3 there, immediately, I wasn't aware of whom had pages. 3 A. Uhelmh. 4 Q. You eventually received than and reviewed 4 Q. You knew she had a MySpace page where there 5 than, correct? 5 was information that was -- that showed her to use 6 A. tJb-huh. 6 thugs, correct? 7 Q. And you understood that from even before then, 7 A. Uh-huh. 8 that Jane Doe 103 had a background that involved at 8 MR. PIKE: Yes or no? 9 least one arrest, correct? 9 THE WITNESS: Yes. 10 A. Yes. 10 BY MR. WEINBERG: 11 Q. And you understood that when she was arrested 11 Q. You knew that the role of the State Attorney, 12 in early October, she in fact informed the arresting 12 the prosecutor that would have to present this case to 13 officers that she had information regarding Mr. Epstein, 13 the jury, was to weigh evidence, correct? Not only the 14 correct? 14 evidence you provided but also any evidence that was 15 A. I believe so. 15 provided by those representing the target of criminal 16 Q. And if you go to your probable cause affidavit 16 investigation? 17 ai page 11, at the bottom of 10, it starts, 'On 17 A. Yes. 18 September 11, 2005, Jane Doe 103 was arrested by the 18 Q. And knew that as a result of that weighing 19 Palm Beach Police Department for misdemeanor possession 19 process, =, an experienced State Attorney, told you 20 ofmarijuana. During the arrest, Jane Doe 103 told the 20 that she believed at least that Jane Doe 103 was a 21 arresting officer that she had information about sexual 21 consenting participant and not a victim of criminal 22 activity taking place at the residence ofMr. Epstein." 22 offenses by Mr. Epstein, correct? 23 A. Yes. 23 MR. GARCIA: Object to the form. 24 Q. Jane Doe 103 essentially was asking the 24 THE WITNESS: I don't — consenting victim, 25 arresting officer to assist in her cooperating; is that 25 you mean? 4 (Pages 508 to 511) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciutl (601 Electronically signed by Jeana Ricciutl (601 bdcd1876-c720.432d-acre-blbae6561291 EFTA00298344 Page 512 P&p:: .., 14 1 BY MR. WEINBERG: 1 case, "Is it okay to take a taxi". 2 Q. She told you that there were no victims here 2 MS. ARBOUR: Form. 3 when — 3 BY MR. WEINBERG: 4 A. Originally, that was her statement, yes. 4 Q. Is that right? 5 Q. Right. And if there were no victims here, 5 MS. ARBOUR: Same objection. 6 then she's really saying to you that, after reviewing 6 THE WITNESS: Yes. 7 all of the evidence that she received, not only from you 7 BY MR. WEINBERG: 8 but from the defense, she didn't consider Jane Doe 103 8 Q. So whoever was at die Epstein home receiving 9 to be a victim? 9 the call would essentially write this denim on a message 10 MS. ARBOUR: Form. 10 pad that had at least two different layers? 11 111E WITNESS: 1believe that's what she 11 MS. ARBOUR: Fem. 12 stated. 12 THE WITNESS: Yes. 13 BY MR. WEINBERG: 13 BY MR. WEINBERG: 14 Q. And given her knowledge of what occurred on El 14 Q. And that when you seized the message pad from 15 Brillo Way, she didn't see any victims in this case. 15 the trash pulls, there was only one layer, which was the 16 MS. ARBOUR: Form. 16 original that had been thrown out or crumpled out, 17 THE WITNESS: 1believe that's what she 17 correct? 18 stated. 18 A. Yes. 19 BY MR. WEINBERG: 19 Q: AM when you went on October 20th and 20 Q. Whether or not she physically did possess the 20 conducted a search and seizure, you would seize the pads 21 message pads or whether she had access to information, 21 that included all of the copies of the original 22 the message pads that you reviewed were in the hundreds, 22 messages, correct? 23 if not thousands, correct? 23 A. Yes. 24 A. Uh-huh. 24 Q. And they were in various handwriting, were 25 Q. And that these pads reflected incoming calls 25 they not? Page 513 Page 515 1 to Mr. Epstein's phone that was in Mr. Epstein's 1 A. Yes. 2 residence on El Brillo, correct? 2 Q. And they provided you with leads to witnesses, 3 A. Correct. 3 did they not? 4 Q. And they reflected messages that came from 4 A. Yes. 5 people that left their phone numbers? 5 Q. And provided you with names and numbers? 6 A. Yes. 6 A. Yes. 7 Q. And it reflected messages that included, for 7 Q. And gave you information that there was lots 8 instance, from.. on July 9, 2004, is available 8 ofpeople who, at least according to these telephone, 9 on Tuesday. Was that a message that was concluded in 9 incoming telephone calls, were inviting themselves to 10 these message pads? 10 Mr. Epstein's home — 11 MS. ARBOUR: Form. 11 MS. ARBOUR: Form. 12 111E WITNESS: Yes, that was some like that, 12 BY MR. WEINBERG: 13 yes. 13 Q. — either directly or through their friends, 14 BY MR. WEINBERG: 14 correct? 15 Q. And that is clutmeteristic of lots of the 15 MS. ARBOUR: Form. 16 messages that were being received by whoever was taking 16 MR. GARCIA: Object to form. 17 down a message at the Epstein residence, correct? 17 THE WITNESS: There were several messages that 18 . MS. ARBOUR: Form. 18 I recall was written to Mr. Epstein indicating 19 THE WITNESS: Iih-huh, yes, correct. 19 girls' names and times that they were available. 20 BY MR. WEINBERG: 20 BY MR. WEINBERG: 21 Q. And the way it worked, if I'm right, is that 21 Q. Like, for instance here, she wants to confirm 22 somebody would answer the phone and, for instance, the 22 a 11:00 tomorrow, message for JAE from a woman's name. 23 message would say on July 19, '04, Mr. Epstein: Phone 23 That would be typical messages on these pads that you 24 call fromM., leaving a reply mobile phone number or 24 reviewed? 25 cellular number, and leaven very short message, in this 25 MS. ARBOUR: Form. 5 (Pages 512 to 515 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeans Ricciuti (601 bdcd1876-c720-432(1-8c10-b19iie6.56129f EFTA00298345 Page 516 THE WITNESS: That would be some, yes. 1 of 18; is that right? 1 2 BY MR. WEINBERG: 2 A. What groupings? 3 Q. And many of them appeared to be incoming calls 3 Q. Well, let's say, did you ever interview a 4 from different girls which said, Em in town, can I come 4 woman namedII.? 5 over, can I schedule a meeting? 5 A. Yes. 6 MS. ARBOUR: Form. 6 O. And youlcnew that her date of birth was in 7 THE WITNESS: Some were like that. 7 and that she was over 18 when you 8 BY MR. WEINBERG: 8 interviewed her — Q. And some appeared to be responses to a phone 9 A. Yes. 10 call made by someone at the El Bulb home asking, are 10 Q. — and represented herself to be over 18 when 11 12 you available, and there would be a phone call back saying, Pm available tomorrow afternoon or Wednesday 11 12 she saw Mr. Epstein? MS. ARBOUR: Font I 13 morning or Thursday afternoon. 13 THE WITNESS: Yes. I 14 A. Correct. 14 BY MR. WEINBERG: 15 Q. And by and large, these messages did not 15 Q. And, likewise, was another person who 16 include any negotiation over dollars? In other words, 16 said yes, she had been to Mr. Epstein's house at a time 17 there was not on a message pad that any of these 17 when she was over 18? 18 incoming girls were saying, I will come over ifIeffrey 18 A. Correct 19 gives me $500 or $300; there was no evidence of that 19 Q. And then M. was in her 20s when you 20 kind ofincoming phone call, correct? 20 interviewed her? 21 MS. ARBOUR: Form. 21. A. Yes. 22 THE WITNESS: Not that I can recall, no. 22 Q. And there was an., who after the publicity 23 BY MR. WEINBERG: 23 came out, called in and said she was 25 at the time she 24 Q. And likewise, there was no indication on these 24 met with Mr. Epstein? 25 message pads that any of the people calling 25 A. Yes. Page 517 Page 519 1 Mr. Epstein's home were, in essence, particularizing 1 Q. And., who you interviewed, who told you 2 what they were going to do or what they intended to do 2 that yes, she went to Mr. Epstein's home on many 3 or what they might do once they got there, correct? 3 occasions, and she was over 187 4 MS. ARBOUR: Form. 4 A. Yes. 5 THE WITNESS: Can you repeat that question? 5 Q. And a 6 BY MR. WEINBERG: 6 A. She was a licensed masseuse. 7 Q. Sure. Theres nothing on these message pads 7 Q. Licensed masseuse who was over 18. 8 that indicates, I'll come over and give a topless 8 A. Yes. 9 massage to Mr. Epstein? 9 Q. And some of the people interviewed had tumcd 10 A. No. 10 18 during the period that they were seeing Mr. Epstein 11 Q. These are essentially contact and scheduling 11 and so told you, correct? In other words, that they had 12 calls? 12 started seeing Mr. Epstein when they were 17, and then 13 MS. ARBOUR: Form. 13 they became 18 and continued to see him when they were 14 THE WITNESS: Yes. 14 18 and, in fact, you interviewed them when they were 18? 15 BY MR, WEINBERG: 15 MS. ARBOUR: Form. 16 Q. And often reflect the fact that the callers 16 THE WITNESS: Some, yes. 17 are not connecting on the first call, so they're going 17 BY MR. WEINBERG: 18 back and forth and trying to arrange times for a 18 Q. And they, too, are included in Mese book of 19 particular woman to come over to Mr. Epstein's home, 19 message pads? In other words, this was not limited, the 20 correct? 20 incoming calls were not limited to girls that were 17 or 21 MS. ARBOUR: Form. 21 16, and included girls that were 18, 19,20, 25 and even 22 THE WITNESS: Yeah. 22 older, correct? 23 BY MR. WEINBERG: 23 MS. ARBOUR: Form. 24 Q. And some of these calls come from a whole 24 THE WITNESS: Correct. 25 grouping of persons that you learned were over the age 25 BY MR. WEINBERG: 6 (Pages 516 to 519) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Rlcciuti (401Ia Electronically signed by Jenne Ricclutl (601 bded18714:726432d4d0-019.44561291 EFTA00298346 Page 520 Page 522 Q. Now, when you drafted the search warrant 1 now almost five years ago, that she had said to you that 7 affidavit and you agreed with me that you understood 2 Jeffrey Epstein preferred girls between 18 and 20. 3 when you drafted it, as an experienced detective of 3 A. I would have documented that in the incident 4 almost two decades, that the judge would be relying on 4 report, but... 3 the content of what you preiented to him, correct? 5 Q. Would it be an important modification of the 6 A. Yes. 6 statement attributed to her that Jeffrey Epstein wants 7 MS. ARBOUR: Form, asked and answered. 7 young girls, correct? 9 BY MR. WEINBERG: 8 MS. ARBOUR: Form. 9 Q. That the judge did not have some external 9 THE WITNESS: Had she said it, but again, I 10 bases to test the representations, either for 10 don't — 11 completeness or for accuracy? I1 BY MR. WEINBERG: 12 MS. ARBOUR: Form. 12 Q. I understand. Had she said it, it certainly 13 THE WITNESS: Correct. 13 would have been considered important enough to include 14 BY MR. WEINBERG: 14 in the various affidavits that you drafted that relied 15 Q. And you made representations in the search 15 in part on what told you. 16 warrant affidavit that were repeated in the probable 16 MS. ARBOUR: Form, the tape speaks for itself. 17 cause affidavit, did you not, that were attributed to 17 BY MR. WEINBERG: 18 18 Q. Correct? 19 A. Yes. 19 A. Correct. 20 Q. And directing myself to the probable cause 20 Q. The message pads include messages like, was 21 affidavit, because that's the one that is unsealed and 21 wondering if she would get work tonight, she couldn't 22 an exhibit in this case, you essentially said to, on the 22 work yesterday because of some family event. That's the 23 probable cause affidavit, thatM. said that Jeffrey 23 messages, those contents, you would have view of the 24 Epstein wanted young girls — 24 message pads, correct? 25 A. Yes. 25 MS. ARBOUR: Form. It speaks for themselves. Page 521 Page 523 1 Q. correct? 1 THE WITNESS: Oh-huh. 2 Do you recall that during your tape recorded 2 BY MR. WEINBERG: 3 interview with M., she told you that Jeffrey Epstein 3 Q. Did you ever interview n woman namedM.? 4 preferred to receive massages from girls between 18 and 4 A. I attempted it, and I don't think she ever 20 years old? 5 returned my calls. A. I recall her slating, "The younger, the 6 Q. Did you cvcr go to her house? 7 better," but I don't recall that he prefers girls A. Let me think. I may have. I mean, I can't 8 between 18 and 20. 8 recall if I went to her house or not, but I know I 9 Q. Will augrce with me that if the tape 9 telephoned her and I never got any call back from her. 10 recording of interview with you reports that as a 10 Q. Did you, dining this investigation, ever, 11 statement made by her, that the tape recording would be 11 yourself, go to MySpace pages to conduct any background 12 the most accurate source of what she told you back in 12 investigation on the various women that you were 13 early October 2005? 13 proffering to the State Attorney as reliable witnesses? 14 MS. ARBOUR: Form. 14 MR. GARCIA: Objection, asked and answered. 15 MR. GARCIA: Do you have the tape recording to 15 MS. ARBOUR: Joined. 16 play, because my understanding is that's under FRI 16 THE WITNESS: Again, I looked at them when 17. control. 17 they were turned over, but no, l didn't. 18 MR. WEINBERG: asking questions about 18 BY MR. WEINBERG: 19 whether or not it included — 19 Q. I'd ask you to look at page 65 of the incident 20 MR. GARCIA: Without playing the tape 20 report, paragraph 4, and see if that refreshes your 21 recording, I think it's an unfair question. 21 recollection. 22 MR. WEINBERG: You can object. I'll ask it. 22 A. Yes, I did. 23 THE WITNESS: If the recording indicated? 23 Q. And do you recall just how you accessed 24 BY MR. WEINBERG: 24 MySpace? Did you run through a list of all your 25 Q. That III. told you in early October of 2005, 25 witnesses and saw whether or not certain of them had 7 (Pages 520 to 523) 'PROSE COURT REPORTING. AGENCY, INC.. Electronically signed by Jeana Ricciuti (601M Electronically signed by Joana Rlcciu0 (601 bdcd1876c72e-432d-13cf0-b19no6561291 EFTA00298347 Page 524 Page 526 1 MySpace pages? 1 Beach, Mr. Epstein? 2 A. Correct. 2 A. Yes. 3 Q. And you concluded that -- ifs all redacted 3 Q. And the question is: You went on MySpace, you 4 hero, but it looks like 10 or 12 of your witnesses had 4 looked at certain pages that reflected at least some of 5 MYSPoce Pages. 5 your witnesses who were not only using drugs but 6 A. Correct. 6 bragging about using drugs publically and publishing 7 Q. And did you download the infonnaticm from 7 pictures or references to themselves as drug users, 8 these MySpace pages into sonic evidentiary format? 8 correct? 9 A. I believe either I printed them or I might 9 A. On the MySpace page, right. 10 have viewed them and made reference of it, that 10 Q. Right. Did you do anything else, as an 11 they had a MySpace page. 11 experienced investigator, to try to determine by 12 Q Did you ever study the contents of the MySpace 12 through the investigation into the background of any of 13 page? 13 the witnesses? 14 A. The ones that were viewable, 1 looked at. Thu 14 A. I believe I checked than under the local 15 ones that weren't, eventually they all became private. 15 systems to see if they had been arrested. I did like a 16 Q. And the ones that were viewable, did you 16 criminal background check on them and the sworn taped 17 identify certain of your witnesses as including in their 17 statement that we took as well. 18 MySpace page evidence that they were involved in the use 18 Q. October 20th you went to Mr. Epstein's home 19 of drugs? 19 with a group of others; is that correct? 20 A. I recall pictures of like a marijuana leaf, 20 A. Uh-huh. 21 comments made of being high when the photo was taken and 21. MR. PIKE: Yes? 22 some alcohol use. I remember that as well. 22 THE WITNESS: Yes. 23 Q. And did you include those obsavations in your 23 BY MR. WEINBERG: 24 incident report that ultimately would have gone to the 24 Q. And you went there with a search warrant — 25 State Attorney to assist the State Attorney in assessing 25 A. Correct Page 525 Page 527 1 the credibility of the people that you were proffering 1 Q. — correct? And in the search warrant, you 2 to them as witnesses? 2 requested the authority to seize all computers, all 3 A. Did I include those in with the State 3 equipment, any discs, any DVDs, any media, correct? I Attorney? I believe they had them by then. That was 4 A. Uh-huh. the winter of '05, '06. 5 MS. ARBOUR: Form, asked and answered. 6 Q. But this was an independent review of MySpace 6 THE WITNESS: Correct. 7 that was not related to what Professor Dershowitz gave 7 BY MR. WEINBERG: the State Attorney; this was something you were 8 Q. And you seized whatever you found there, reporting that you did on your own, correct? 9 correct? 10 A. I tray have done it on my own to view it myself 10 A. Yes. 11 after learning from the State Attorney's office. I'm 11 Q. And you, yourself, looked through what you 12 not —I can't recall if I did it totally on my own or could look through and asked your forensic people to 13 when I first heard of the MySpace pages, J researched it :3 look through what you couldn't look through; is that 14 myself to view it myself. 14 correct? 15 Q. Did you do anything other Than look at MySpace 15 A. That is correct. 16 pages to try to assess the credibility of any of your 16 Q. And as a result of the search and seizure, 17 witnesses based on what you could learn about them from 17 there was no picture of Jane Doe 103 that was seized, 18 other people? In other words, you were essentially 18 correct? 19 proffering to the State Attorney certain statements that 19 A. That's correct. 20 had been made to you regarding what occurred on El 20 Q. And there was no camera that was found in the 21 Milo Way, correct? 21 massage room, no coven camera found in the second floor 22 A. Uh-huh. 22 massage room of the Epstein home, correct? 23 Q. And you were relying on those statements and 23 MS. ARBOUR: Form. 24 their detail as a basis for asking the State Attorney to 24 THE WITNESS: No, we did not find a camera 25 bring a criminal prosecution against a residence of Palm 25 that day, no. ccers 1/4.-7,- a -2-- , 44.4aredeSev*......-4t-YeetSiers, Mr-nteaf J 8 (Pages 524 to 527 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana IlIcciutl (601 Electronically signed by Jeans Riccluti (601 bded1876-c726-432da-f0419666661291 EFTA00298348 Page 529 Page 530 1 BY MR. WEINBERG: 1 THE WITNESS: Yes. 2 Q. The only camera you found was the camera that 2 BY MR. WEINBERG: 3 you knew about from your 2003 investigation, the one 3 Q. At any time prior to that, did Jane Doe 103 4 that was in the clock aimed at Mr. Epstein's desk and 4 ever call you and say that she was concerned about an 5 the second camera that was in the garage, correct? 5 investigator? 6 A. We found, yes, the second camera in the 6 A. Yes. 7 garage- • 7 Q. And did she call — do you recall when she 8 Q. Did you ever, on any other day, find any 8 called you? Before or after the service of the 9 10 camera other than the cameras you, yourself, installed in 2003 and the camera that Mr. Epstein pointed out to 9 10 subpoena, if you remember? A. It was before. I 11 you in 2003 from the lint floor area? 11 Q. And did she call you at night or in the day I 12 A. No, we didn't see — we didn't find any other 12 time? 13 cameras. 13 A. I believe she called me in the evening time 14 Q. And you had only been to his house, twice; is 14 and left me a voice mail, and I returned her call in the 15 that correct? Once — 15 morning. 16 A. The day of the search warrant and the day that 16 Q. And when she left you a voice mail, where 17 I assisted by putting the cameras. 17 would she have called, into the office, or... 18 Q. You never went back in and altered his home 18 A. Into the Police Department. 19 after October 20, 2005, did you? 19 Q. Did she have your cell phone number? 20 A. No. 20 A. I had provided the victims with a cell phone 21 Q. Do you know of any audio or wire electronic 21 number, yes. 22 interceptions that were directed against Mr. Epstein or 22 Q. Was that a cell phone number that you carried? 23 his residence at any time by anyone? 23 A. Uh-huh. 24 A. No. 24 Q. Was it one of several cell phones you carried? 25 Q. There were certainly none that was connected 25 A. Yes. Page 529 Page 531 1 to your State investigation? 1 Q. Was it a cell phone that was paid for by the 2 A. No. 2 Palm Beach Police Department? 3 Q. So nobody under your command was outside his 3 A. I believe 1 was paying for that one. 4 house at any time trying to intercept telephone 4 Q. Was there a second cell phone — 5 communications of any kind? A. Here's the thing: The Town was offering us a 6 MS. ARDOUR: Form, asked and answered. 6 stipend onto a cell phone. I had, prior to that, a few 7 BY MR. WEINBERG: 7 months left on another cell phone to the end of 8 Q. Is that right? 8 contract. So fora time period there I carried two 9 A. Not to my knowledge, no. 9 phones until the contract expired, and at which time I 10 Q. And not to your knowledge, did anybody try to 10 shut off that service and then just used the — 11 intercept electronic communications, e-mails, any other 11 Q. The phone left was the one that the Town was 12 form of communication emanating from either his 12 offering you a stipend? 13 residence or any Internet service provider? 13 A. Yes. 14 MS. ARBOUR: Form, asked and answered. 14 Q. And by the Town," do you mean the Palm Beach 15 THE WITNESS: No. 15 Polka Department? 16 BY MR. WEINBERG: 16 A. Palm Beach Police Department. 17 Q. Do you recall that during the course of your 17 Q. And this was the nut that you began to give 18 investigation, before you ended up drafting your May 1st 18 out to different witnesses — 19 affidavit, there was a decision made to conduct a grand 19 A. That is correct. 20 jury? 20 Q. — not only in this case but in other cases? 21 A. Yes, a couple of times. 21 A. Correct. 22 Q. Whether it was March or April, a subpoena was 22 Q. Is that a — do you get copies of the cell 23 served on Jane Doe 103 by yourself in Tallahassee, 23 records that are connected to that phone or do they go 24 correct? 24 directly to the Palm Beach Police Department? 25 MS. ARBOUR: Form, asked and answered. 25 A. No, 1 receive the bill, but it's not an 9 (Pages 528 to 531) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (801 Electronically signed by Jeana Rlcciull (601 bdcd1875-8728-4328-8810-819866661291 EFTA00298349 Page 532 Page 534 1 itemized bill. It's just a regular bill. I pay it and 1 Q. To any State Attorney? 2 I shred it. 2 A. Nope. 3 Q. You pay it, you shred it and then you get 3 Q. To anyone associated with the investigation of 4 reimbursed by the Town -- 4 Jeffrey Epstein? 5 A. The Town offers -- 5 A. Norte. 6 Q. -- a flat sum before — 6 Q. Same question for your cell phones: I assume A. -- a flat sum, a monthly sum. 7 you have a cell phone other than the cell phone that you 8 Q. And with which service provider is that? 8 receive through the Palm Beach PD stipend. 9 A. AT&T. 9 A. No. This is the only phone I use. 10 Q. And can you give us the number of the cell 10 Q. And that's the phone that's subject to the 11 phone that Jane Doe 103 -- that you would have given to 11 separate inquiry. 12 Jane Doe 103 or other witnesses during this time period? 12 How about reimbursing expenses? When you have 13 A. Hold on one second. 13 expenses in connection with, for instance, the Epstein 14 MS. O'CONNER: Were going to object. If you 14 investigation, would there be a record of those 15 don't want to raise this issue in terms of the cell 15 expenses? 16 phone records on the motion to compel that's 16 MS. ARBOUR: Form. 17 pending, we can address it with the court. 17 THE WITNESS: We are given investigative funds 18 MR. PIKE: les noted. 18 to utilize an investigation, and sometimes -- 19 MS. CYCONNER: We raised a number of statutory 19 BY MR. WEINBERG: 20 objection to producing information regarding his 20 Q. Who would give you the funds? 21 cell phone. 21 A. — sometimes the funds is issued by the 22 BY MR. WEINBERG: 22 Detective Bureau sergeant. 23 . How about e-mails? You mentioned 23 Q. Would they give you a flat amount and leave to 24 [sic]. 24 your discretion the utilization of that amount? 25 A. That's correct 25 A. No. The maximum I think they give you is Page 533 Page 535 1 Q. Is that an account that you paid for or that 1 $200, and that's to be utilized if you're going out of 2 the Palm Beach Police pays for it? 2 County to pay for gas or if you run into a situation 3 A. The Palm Beach Police pays for it. 3 with a flat tire, to get a tire replaced or repaired, 4 Q. Are the copies ofyour e-mail on the server of 4 that kind of thing, providing you get a receipt — 5 the Palm Beach Police Department? 5 Q. What about, you do things on video 6 A. Yes. 6 surveillance and you have to continue to buy new 7 MR. PIKE: Can we go off the record for a 7 equipment to film the 24 hours a day of comings and 8 second? 8 goings ofa residence; would there be records of those 9 MS. OtONNER: Yes. 9 purchases? 10 (Discussion held off the record.) 10 A. For equipment? 11 BY MR. WEINBERG: 11 Q. Yes. 12 Q. So the e-mail is [sic]. 12 A. I'm sum there would be. I don't recall any 13 Do you have a separate e-mail account, a personal e-mail 13 purchases. 14 account as contrasted to a public e-mail account? 14 Q. How about travel, did you do any travel in 15 A. I do, but that's — lust that for my family 15 connection with the Epstein investigation? 16 and nothing work-related. 16 A. Up to Jacksonville, Tallahassee, all within 17 Q. So it's your representation that none of the 17 State. You know, we didn't leave. • 18 witnesses in this case ever e-mailed to you to your 18 Q. You didn't have to travel to New York or to 19 personal e-mail? 19 any other location? 20 A. Never. 20 A. No. 21 Q. And no communications front your personal 21 Q. Did you ever contact any law enforcement 22 e-mail to Chief Reiter? 22 officers in any other jurisdiction with the exception of 23 A. No. 23 this meeting with Special Agent Ortiz and other agents 24 Q. To the FBI? 24 of the FBI? 25 A. Nopc. 25 MS. ARBOUR: Form. 10 (Pages 532 to 535) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Moduli (601 Electronically signed by Jeana RIcduti Mit bdcd1878-c720-432d-8cf0-b19ae656129t EFTA00298350 Page 536 Page 538 1 THE WITNESS: I think, during the 1 correct? . 2 investigation, I telephoned New Mexico to see if 2 A. I believe so. 1documented it in the incident 3 there was any incidences involving the ranch that 3 report 4 Mr. Epstein owns. 4 Q. But, in fact, nobody got taken care of; nobody 5 BY MR. WEINBERG: 5 over got banned in this case, did they? 6 • Q. And what did you learn? 6 MS. ARBOUR: Form. 7 A. It was a huge ranch, but they didn't have 7 THE WITNESS: Not that I'm aware of, no. 8 anything documented. 8 BY MR. WEINBERG: 9 I believe I also called the NYPD to see if 9 Q. And there's no evidence that you're aware of 10 they bad any incidences involving Mr. Epstein up in New 10 that any persons were paid large sums of money not to 11 York. 11 cooperate with you, correct? 12 Q. What did you leant? 12 MS. ARBOUR: Forrn. 13 A. They had nothing on file after numerous phone 13 THE WITNESS: Not that I'm aware of. 14 calls up there, once someone returned your call. 14 BY MR. WEINBERG: 15 believe that was it. 15 Q. So this is simply Jane Doe 103 telling you 16 Q. When you went to Tallahassee to serve the 16 what said, and that was said to you on this 17 grand jury subpoena to Jane Doe 103, that was a subpoena 17 occasion where she received a grand jury subpoena, 18 that required her attendance, was it not? 18 right? 19 A. Yes. 19 A. Yes. 20 Q. It was fora given date to come to West Palm 20 Q. Did you ever interview 21 Beach and to appear in front of a grand jury being 21 A. I know that Jane Doe 103 didn't want to pursue 22 conducted by the State Attorney? 22 the natter any further. I know I forwarded that 23 A. Yes. 23 information to a, and I also subpoenaed 24 Q. Did you and her have any conversations 24 ='s cell phone records, which indicated phone calls 25 regarding that subpoena and her compliance obligations? 25 to Jane Doe 103 when she indicated she did get the Page 537 Page 539 1 A. I'm trying to recall what we discussed. 1 1 threatening calls. 2 served her with a subpoena and instructed her to call 2 Q. But did you ever — did_. ever get asked 3 the phone number that was on there to make arrangemans. 3 whether or not that was a statement that she had made to 4 Q. How long were you with her in Tallahassee on 4 Jane Doe 103? 5 this occasion? 5 A. No, I didn't, again, bes tise Jane Doe 103 did 6 A. I'd say about 40 minutes, 50 minutes. 6 not want to pursue the matter. 7 Q. And did you decide that you were to be the 7 Q. So at no time WES - did testify 8 person to save the subpoena as contrasted to any of the 8 or provide you with anarroboration from Jane Doe 9 different people working under or with you? 9 I03's allegations that had conveyed some sort of 10 A. Yes, I am the one who served the other search 10 threat to her, correct? 11 warrant — subpoenas. 11 A. Again, l didn't speak to 12 Q. So you served ull of the subpoenas? 12 Q. Nor did anyone else in the Palm Beach Police 13 A. Uh-huh. 13 Department, to your knowledge? 14 Q. And was that the only reason to go to 14 A. No, except for that one time I tried to 15 Tallahassee that day? 15 interview her at her boyfriend's job. 16 A. I spoke to her also regarding some phone calls 16 Q. Nor did any State Attorney, to the best of 17 that she had received which she felt was threatening in 17 your knowledge? 18 nature. 18 A. No, not that I'm aware of. 19 Q. And what were the results of those 19 Q. Now, this was the last time you saw Jane Doc 20 conversations? 20 103? 21 A. She had received a phone call from =, 21 A. I believe there was — there were two grand 22 indicating to her that those that are with Mr. Epstein 22 jury subpoenas. Yes, this would have been the last time 23 will be compensated and those that go against him 23 I met with her. 24 basically would be dealt with. 24 Q. Did you reserve her for the second, the summer 25 Q. We're talking about March or April of 2006, 25 grand jury? 11 (Pages 536 to 539) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Riccluti (601a Electronically signed by Jeana Rlcciull (801 bdcd1876c720-4328-8c10-b19ae6561291 EFTA00298351 Page 540 Page 542 1 A. The second time, I provided the State where 1 A. Yes. I was there. 2 they could serve the subpoenas. 2 Q. In response to a subpoena, correct? 3 Q. And to your knowledge, was she served a second 3 A. Yes. I was there. 4 time? 4 Q. And did you know whether or not she had bad 5 A. I have no knowledge. 5 any conversations with anyone other than you about her 6 Q. Do you recall any conversations with her 6 belief that her finals needed to be attended to rather 7 regarding that the second grand jury conflicted with her 7 than a grand jury subpoena? 8 school schedule? 8 A. That she — 9 A. That is correct, yes. 9 Q. In other words, did you ever speak to the 10 Q. But that was in response to her receiving a 10 State Attorney that she had gotten a pass on appearing 11 subpoena? 11 in front of the grand jury because of her school 12 A. Yes. I went to Tallahassee, correct 12 schedule? 13 Q. So you went to 'fallahassee a second time? 13 A. Oh, I have no idea. 14 A. Yes. 14 Q. All you do know is that the State Attorney was 15 Q. To serve her with a second subpoena? 15 waiting for her and she didn't come? 16 A. I think the trip — Pm confining the trips. 16 A. I don't know if she was waiting for her, 17 There was a trip that I went up to Jacksonville to 17 18 interview her. The second time I went up to see her, ii 18 Q. Didn't they expect her to appear and testify 19 was in Tallahassee. That one time that I went up there 19 in response to the subpoena and she failed to appear 20 to save her, we discussed the issue, but I 20 that day? 21 didn't go back the third time. 21 A. Again, I don't know the conversations that she 22 Q. Somebody else served her, to your knowledge? 22 had with the State Attorney's office. I do know that 23 A. It would have been the State Attorney's 23 she relayed that information to me. I told her to relay 24 office. 24 that information to the State Attorney's office. I 25 Q. And as a result of her being served a second 25 was — Page 541 Page 543 1 time, did she have a conversation with you regarding the 1 Q. Did you empathize with her conflict? 2 second subpoena's conflicting with her finals schedule? 2 A. Absolutely. 3 A. Correct 3 Q. And did you in any way tell her that, I 4 Q. And she made a phone call to you to complain 4 understand that your finals are important and you should 5 about the service? 5 tell the State Attorney that you can't come? 6 A. Correct. 6 A. I explained to her that she needed to contact 7 Q. And what was the conversation between Jane Doe 7 the State Attorney's office and make arrangements 8 103 and you on that occasion? 8 through the State Attorney's office. 9 A. It was finals week and she could not leave and 9 Q. You encouraged her to get excused front the 10 not take her final to come down for the grand jury. I 10 grand jury subpoena? 11 recommended that she contact the State Attorney's office 11. MS. ARBOUR: Form 12 and make recommendations through the State Attorney's 12 11IE WITNESS: I reconunended that she contact 13 office. 13 the State Attorney's office and let her know what 14 Q. And did you have any followup with her to see 14 was going on as far as her finals. 15 if she had been formally excused from the grand jury by 15 BY MR. WItINI3ERG: 16 the State Attorney? 16 Q. And whether she did or didn't, you have no 17 A. No, 'did not 17 knowledge? 18 Q. Did you leant that she didn't show up at the A. No, but I was present during the entire grand 19 grand jury? 19 jury, so l blew she wasn't — 20 A. Yes. 20 Q. That she didn't come? 21 Q. Did you learn that she had not been excused by 21 A. (Non-verbal response). 22 the State Attorney? 22 And you don't recall any conversation where 23 A. I don't think she officially came out and told 23 or any State Attorney informed you that she had 24 me that she was not excused. 24 authorized Jane Doe 103 not to comply with the grand 25 Q. But you do know that she failed to appear? 25 jury subpoena? 12 (Pages 540 to 543) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans Ricciuti (601 Electronically signed by Jean. Ricciutt (601 bdcd1876.c72o 432cI.8cf0-b19ao656129f EFTA00298352 Page 544 Page 546 1 A. No, 1 don't recall any of those conversations. 1 now, Sergeant Dawson, but back then it was Detective 2 Q. Toll records, you examined some toll records 2 Dawson. 3 in this case, did you not, telephone toll records? 3 Q. Were you a participant in that second 4 A. Do you mean itemized records? 4 investigation — 5 Q. Yes. 5 A. Yes. 6 A. Yes. 6 Q. -- that has a separate case number, an 7 Q. And, for instance, you told us there was a 7 '06 number instead of an '05 number? 8 record between Jane Doe 103 and 8 A. Correct 9 A. Uh-huh. 9 Q. And that investigation lasted until when? 10 a And there were records between.. and 10 A. Not very long. It lasted up to when the Feds 11 correct? 11. came in and basically took over. 12 A. Correct. 12 • Q. Again, I think you said the last time when the 13 Q. And it's fair to say that those toll records 13 FBI comes in, it becomes a one-way street? 14 15 establish connections between two phones, correct? A. That is correct 14 15 A. That is correct. Q. And that's been your 20-year experience as a I 16 Q. They don't tell you who was on either end, do 16 State law enforcement officer? 17 they? 17 A. Correct 18 A. No. 18 Q. And yet, this case, ironically, the Feds were 19 Q. They don't tell you the content of the call, 19 invited in by you and Chief Reiter, correct? 20 correct? 20 MS. ARBOUR: Form. 21 A. No. 21 THE WITNESS: Correct. 22 Q. They tell you how long the call was and phone 22 BY MR. WEINBERG: 23 numbers connected, but not the content of the call, 23 Q. And this Is the first time you've invited the 24 correct? 24 Feds into a State investigation? 25 A. No, not the content. Date and time. 25 A. I've been a participant in other Page 545 Page 547 3. Q. Anywhere in your investigation, were you ever 1 investigations where the Feds have come in and worked . 2 a participant in or hear any phone calls between any of 2 with us, and Pve assisted than in — 3 the witnesses in this case? 3 Q. Sure. But this is the first case where you've 4 A. In other words — 4 conducted an over-one-year State investigation of an 5 Q. Let me ask it another way. Did you ever, in 5 offense that occurred at a residence in Palm Beach and 6 any way, receive a to recording of any telephone call 6 that the chief of police of your department brought this 7 engaged in by 7 case to the Federal government; is that correct? 8 A. No. 8 MS. ARBOUR: Form. 9 Q. And certainly never received or heard a tape THE WITNESS: Like I said, we've worked with 10 recording of Jeffrey Epstein, correct? 10 the FBL Is that what you're trying to get at, in 11 A. No. 11 the past? 12 Q. Or anyone else who was associated with the la 12 BY MR. WEINBERG: 13 Brftlo residence, correct? 13 Q. Bringing the case to the FBI, this is what's 14 A. No. 14 unusual in this case is the chief of police not 15 Q. The only evidence you have of what transpired 15 accepting the charged decisions made by the State 16 during any call is the message pad and what somebody 16 Attorney, brought this investigation over to the United 17 told you happened during a call, correct? 17 States Attorneys office. That's a first for you, isn't 18 MS. ARBOUR: Form. 18 it? 19 THE WITNESS: And the toll records. 19 MS. ARBOUR: Form. 20 BY MR. WEINBERG: • 20 THE WITNESS: There were many firsts in this 21 Q. And the toll records. Okay. 21 case. 22 Now, after the grand jury returned a charge 22 BY MR. WEINBERG: 23 against Mr. Epstein, you conducted a followup 23 • Q. This was one of them? 24 investigation, did you not? 24 MS. ARBOUR: Form, asked and answered. 25 A. The followup investigation was initiated by, 25 THE WITNESS: There was — 13 (Pages 544 to 547) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricclull (601 bdcd1876-67243-43241-8cf0-b19666661291 EFTA00298353 Page 548 Page 550 1 MS. O'CONNER: Is there a question pending? 1 allegation, there was no attempts to charge Mr. Epstein 2 MR. WEINBERG: Yes. 2 or arrest Mr. Epstein in March, April, May, June, July, 3 BY MR. WEINBERG: 3 August and into September of 2005, correct? 4 Q One of the firsts in this case was that this 4 A. Correct. 5 was the first time that your chief of police brought the 5 Q. And then you picked up this case in late 6 case to the Federal government after a year of State 6 September of 2005, correct? 7 investigation, correct? 7 A. Correct. . MS. ARBOUR: Form, asked and answered. 8 MS. ARBOUR: Form, asked and answered. 9 THE WITNESS: I believe so. 9 BY MR. WEINBERG: 10 BY MR. WEINBERG: 10 Q. And you interviewedM. in the first week of 11 Q. Now, Mr. Epstein stays at El Brillo, and hes 11 October 2005, correct? 12 there on a periodic basis, at least until this case 12 MS. ARBOUR: Form, asked and answered. 13 ended up in the Criminal Justice System, correct? He 13 THE WITNESS: Correct. 14 would come there at times and be absent at times, 14 BY MR. WEINBERG: 15 correct? 15 Q. And.. gave you certain corroborating_ 16 A. Yes. 16 information that confirmed the information that.. had 17 MS. ARBOUR: Form. 17 given you about their joint visit In early '05 to 18 BY MR. WEINBERG: 18 Mr. Epstein's home? 19 Q. And the investigation began in March; is that 19 A. Correct. 20 right? 20 Q. Correct? 21 A. Yes. 21 That led to a request for a search warrant 22 Q. And there was an allegation made bye, and 22 rather than a request for an arrest warrant, correct? 23 resulted horn a phone call by her parents, correct? 23 A. Correct. 24 MS. ARBOUR: Form, asked and answered. 24 Q. And surveillance continued on Mr. Epstein's 25 THE WITNESS: Yes. 25 home on occasion when you knew he was in town? Page 549 Page 551 1 BY MR. WEINBERG: 1 A. Yes. 2 Q. And then there were trash pulls that, in some 2 Q. And trash pulls continued, correct? 3 respects, were believed to included objects that you 3 A. Correct. 4 thought were reflective of anal sex, correct? 4 Q. And your investigation disclosed that the 5 MS. ARBOUR: Form, asked and answered. 5 youvrwomen going to his home were more than just 6 THE WITNESS: Yes. 6 and M., correct? 7 BY MR. WEINBERG: 7 A. Correct. 8 Q. Yet, there was no attempts to arrest 8 Q. And yet there was no arrest warrant in October 9 Mr. Epstein in April of 2005, were they? 9 or November or December brought against Mr. Epstein, 10 A. Again, that was when Detective Pagan had that 10 correct? 11 case. 11 A. Correct 12 Q. I'm not being critical of you. 12 Q. And no attempt to initiate a criminal charge 13 A. No, I'm just saying I don't know. I don't 13 against him through the end of the year 2005? 14 know back then what she did. 14 A. Correct. 15 Q. Well, you have access to her case file, do you 15. Q. In the beginning of 2006, you continued to 16 not? 16 conduct interviews of women, including.., correct? 17 A. Right. 17 MS. ARBOUR: Form, asked and answered. 18 Q. And you, in fact, on September 22nd, asked 18 THE WITNESS: Yes. 19 that the case file be provided to you so that you, as an 19 BY MR. WEINBERG: 20 experienced investigator, could kern from the history 20 Q. You continued to do garbage pulls, correct? 21 of this case, correct? 21 A. In 306,1 don't know if we continued to do 22 MS. ARBOUR: Form, and asked and answered. 22 trash pulls. 23 THE WITNESS: Correct. 23 Q. You continued to do surveillances, on 24 BY MR. WEDIBERG: 24 occasion, of Mr. Epstein's home? 25 Q. And you knew for six months following the E. 25 A. On occasion, I believe. 14 (Pages 548 to 551) PROSE COURT REPORTING AGENCY, .INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricciuti (801 bdecH878.c72s-432d-ttcf0-b19ao5581291 EFTA00298354 Page 552 t'". - 1 Q. Studied the results of the seizures of 1 reporters and media broadcasters? 2 October 20th to try to augment your investigation? 2 MS. ARBOUR: Fenn. 3 MS. ARBOUR: Form. 3 THE WITNESS: I wasn't privy on who he —1 4 THE WITNESS: We went through the evidence 4 mean, obviously, he's — 5 collected, if that's what you're trying to get at, 5 BY MR. WEINBERG: 6 Yee- 6 Q. He's the chief. 7 BY MR. WEINBERG: 7 A. — hers the chief, you know. 8 Q. And yet the first time you executed a probable 6 Q. You're the detective. 9 cause affidavit was May 1,2006, correct? 9 A. Exactly. 10 MS. ARBOUR: Form, asked and answered. 10 Q. Let me run through a couple of additional 11 THE WITNESS: Correct. 11 investigators and see whether you actually have ever had 12 BY MR. WEINBERG: 12 conversations with them, and if you have, then follow it 13 Q. And the first time Mr. Epstein was charged was 13 up with whether those conversations addressed any part 14 late in the summer or during the summer of 2006 by the 14 of this communication. 15 turn ofan indictment for solicitation by the grand 15 Richard Fandrey? 16 jury, correct? 16 A. No. 17 A. Correct. 17 Q. Kenneth Jenne? 18 Q. Now, have you ever spoken to any reporters 18 A. Na 19 from outside the Palm Beach area — 19 Q. Patrick Roberts? 20 MS. ARBOUR: Form, asked and answered. 20 A. Na 21 BY MR. WEINBERG: 21 Q. Christina Kitterman? 22 Q. — regarding Mr. Epstein? 22 A. Uh-uh. 23 MS. ARBOUR: Same objection. 23 Q. Michael listen? 24 THE WITNESS: No. I know we received a lot of 24 A. No. 25 phone calls. We received a lot ofphone calls from 25 Q. And again, do you have any knowledge that Page 553 Page 555 1 different reporters. 1 several of these investigators went toMr. Epstein's 2 BY MR. WEINBERG: 2 property and entered it at or around 10:00 to 10:30 on 3 Q. Do you know whether or not Mr. Reiter was in 3 March 17,2010, dressed in black and leaving in a 4 touch — former Chief Reiter was in touch with various 4 vehicle registered to an investigator named Richard 5 reporters? 5 Fandrey? 6 A. I don't believe so. 6 MS. ARBOUR: Form. 7 Q. Did he talk to you about having been 7 THE WITNESS: No, sir. 8 interviewed by Mr. Connolly from Vanity Fair? 8 BY MR. WEINBERG: 9 A. Not that I'm aware of 9 Q. Do you have any knowledge that there was 10 Q. Did he talk to you about being interviewed by 10 surveillance of an entry onto Mr. Epstein's property by 11 anyone from the New York Daily News? 11 private investigators connected to this case on any 12 A. No. 12 occasion? 13 Q. New York Post? 13 A. No, sir. I was under the assumption that 14 A. No. 14 Wackenhut was still protecting the property. 15 Q. New York Tunes? 15 Q. After Mr. Epstein entered his plea and began 16 A. (Non-verbal response). 16 his service of his sentence, did you receive any 17 Q. Any other magazine? 17 followup requests for you to conduct investigations of 18 A. No, sir. 18 him? 19 Q. Any local reporters from the media here? 19 A. Again, I received a phone call from 20 A. Not that I'm aware of. 20 Mr. Edwards pertaining to a victim that was not in the 21 Q. TV broadcasters looking for news about 21 original report I referred him over to the FBI. 22 Mr. Epstein? 22 Q. Did anyone in the FBI ask you to conduct any 23 A. Not that I'm aware of. 23 followup investigation of Mr. Epstein? 24 Q. Would it surprise you if there was e-mail 24 A. No. 25 traffic between Chief Reiter and some of the local 25 Q. And that includes the time he was in jail? 15 (Pages 552 to 555 PROSE COURT REPORTING AGENCY, INC.' (561) 832-7506 Electronically signed by Jeana Moduli (601 Electronically signed by Jeana Moduli (601 bdcd1876-c720-432d-8cIO-bleae6561291 EFTA00298355 Page 556 Page 558 1 A (Non-verbal response). 1 Probation Department? 2 Q. The time he was on work release, no request? 2 A. As far as I'm concerned, yeah. As far as I 3 A. None. 3 know. 4 Q. The time he was on probation, community 4 Q. On that occasion, he was how far from his home 5 control? 5 when you saw him? 6 A. No. 6 A. From El Brillo to Clark and the ocean, fd say 7 Q. So you've never received an FBI request to, in 7 about a mile, mile and a half. 8 any way, investigate Mr. Epstein? 8 Q. And Clark is north of El Brillo? 9 A. No. 9 A. Yes, north of Royal Palm Way. 10 Q. Surveille Mr. Epstein? Io Q. And in other words, coming this way from 11 A. No. 11 Mr. Epstein's house, from south to north? 12 Q. Report to them any of your knowledge of 12 A. Yes. 13 Mr. Epstein's ongoing conduct? 13 Q. Right? 14 A. No. 14 A. Yes. 15 Q. Same question for the US Attorney's office: 15 Q. And Mr. Epstein's office is north of his 16 Have they ever initiated a call to you at any time after 16 house, correct? 17 Mr. Epstein went to jail asking you to do anything in 17 A. Northwest. 16 connection to their ongoing investigation of 18 Q. Northwest, so north and then west. You'd have 19 Mr. Epstein? 19 to go over a bridge, right? 20 A. Absolutely not. 20 A. Right. 21 Q. And what about Probation? Has Probation ever 21 Q. And the bridge that's closest to his office is 22 asked you to initiate any surveillance or investigation 22 north of his house? 23 of Mr. Epstein? 23 A. Actually, this one right here, Okeechobee. 24 A. No. Aside from that ono day that I saw him 24 Okeechobee Boulevard right here. 25 walking on the — along South Ocean Boulevard, that was 25 Q. So he would go over Okeechobee Boulevard and Page 557 Page 559 1 it. That was the only — and I didn't even contact 1 end up at his office, and Clark is between El Brillo and 2 Probation. I believe Captain Frick (phonetic) is the 2 Okeechobee Boulevard, correct? 3 one who contacted Probation and something Sloan 3 A. Actually, Clark is north of Okeechoboo 4 (phonetic). 4 Boulevard. Q. Are you aware of any — putting yourself aside 5 Q. So is there a second bridge just to the north and putting this ono incident aside, arc you aware of 6 of Okeechobee? the Palm Beach Police Department having any ongoing role 7 A. Yes, there is a north bridge. in the investigation of Jeffrey Epstein? 8 Q. What's the name of that bridge? 9 A. As far as today? 9 A. The North Bridge. 10 Q. Yes, as of today. 10 Q. And that's a bridge that comes west from Rahn 11 A. No. 11 Beach? 12 Q. How about at any time over the past year, 12 A. Yes. 13 starting with the time he was out on work release and 13 Q. And ends up in this community of offices that 14 thereafter on commtmity control — 14 includes Mr. Epstein's office? 15 A. There did no — 15 A. If his office was in Mr. Goldberger's Office, 16 Q. — house arrest? 16 the quickest route would have been on Okeechobee. 17 A. — investigation, not that I'm aware of. 17 Q. But one of the route — you have to get off 18 Q. Is the one occasion the only time that you or 18 the beach, right? 19 anyone working with you spoke to Probation about 19 A. Correct. 20 Mr. Epstein's ongoing activities? 20 Q. And there's two bridges that are connecting 21 A. That was the only time I think — 21 the beach to the Palm Beach financial district, one 22 Q. That you were involved? 22 being Okeechobee and one being the bridge to the north 23 A. Yes. 23 of it? 24 Q. And is it the only time that you are aware 24 MS. ARBOUR: Form, asked and answered. 25 that anyone else has had communications to and from the 25 THE WITNIZS: Right. There is one south, too, 16 (Pages 556 to 559) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Riceluti (601 Electronically signed by Joana Ricciutl (601 bdcd1B76-c726A32d•Be10-b19aa666129f EFTA00298356 Page 560 Page 562 1 fin sorry. I didn't want to just make you think 1 residence — Mr. Epstein's residence? 2 there was only two bridges. 2 A. I'm trying to think. I can't recall. it's 3 BY MR. WEINBERG: 3 been a while since I've seen those. 4 Q. That's way south. 4 Q. Was Ms... somebody that was interviewed by 5 A. That's southern. 5 you in '05 or '06? 6 MS. ARBOUR: Objection, form. 6 A. It might have been'06 when I interviewed her. 7 BY MR. WEINBERG: 7 Q. And she was one of the ova 18 people that — 8 Q. You had a thumb drive that you gave to the 8 A. Correct 9 FBI? 9 Q. -- that you ended up interviewing in phase two 10 A. Yes. 10 of your investigation ofMr. Epstein? 11 Q. And the thumb drive consisted of what? 11 MS. ARBOUR: Fenn, asked and answered. 12 A. The thumb drive consisted of photographs of 12 THE WITNESS: Yes. 13 the victims, some ofmy supplements that were saved onto 13 BY MR. WEINBERG: 14 the thumb drive. That was turned over to the FBI. 14 Q. And you interviewed about how many people that 15 Q. Are those records that are on the thumb drive 15 told you they engaged in consensual adult activities 16 also in the public records of the Palm Beach Police 16 with Mr. Epstein? 17 Department, or were there additional — 17 MS. ARBOUR: Form. 18 A. Those were actually my personal thumb drives. 18 THE WITNESS: It's tough to say. I don't 19 Q. Those were your personal thumb drives? 19 know, less than ten. I don't know. 20 A. Yeah. 20 BY MR. WEINBERG: 21 Q. Was everything on it also in the case file? 21 Q. And of the other people, taking Jane Doe 103 22 A. Yes. 22 out and taking out the one other person who you 23 Q. So the photographs are in the case file? 23 mentioned who had the digital penetration that stopped 24 A. Yes. 24 when she withdrew, the other people told you that they 25 Q. And these photographs came from driver's 25 consented to go to Mr. Epstein's home, correct? Page 561 Page 563 1 license photos of the different witnesses? 1 MS. ARBOUR: Form. 2 A. Driver's license photos and some of the 2 THE WITNESS: Well, what do you mean 3 yearbooks that wore collected. 3 "consented"? 4 Q. Were there surveillance of Mr. Epstein's 4 BY MR. WEINBERG: 5 residences? Have you seen than since September of 2005? 5 Q. They did so voluntarily. 6 A. What do you mean *surveillances'? 6 MS. ARBOUR: Same objection. 7 Q. When you, assuming there were videos taken of 7 THE WITNESS: Right. Nobody was bound and 8 Mr. Epstein's residence -- 8 gagged. 9 A. Correct, yes. 9 BY MR. WEINBERG: 10 Q. — it showed the comings and goings ofhim? 10 Q. Not only bound and gagged, but they made a 11 A. Correct. 11 decision that they were — 12 Q. And did you watch them? 12 MS. ARDOUR: Form, asked and answered. 13 A. I saw some of than, yes. 13 THE WITNESS: Right, they were going to go to 14 Q. And did it show any particular people going 14 the house. 15 into Mr. Epstein's home that you identified? 15 BY MR. WEINBERG: 16 A. Yes, and she was subsequently interviewed as 16 Q. And they, one way or the other, drove to 17 well. 17 Mr. Epstein's residence from wherever they lived or 18 Q. And what was her name, if you remember? 18 worked? 19 A. She was overage. 19 MS. ARBOUR: Form, and asked and answered. 20 Q. So she was one of the group of people that was 20 BY MR. WEINBERG: 21 over 18? 21 Q. Is that correct? 22 A. Correct, and an aspiring model. She brought 22 MS. ARBOUR: Same objection. 23 her portfolio ova and did some minor modeling at the 23 THE WITNESS: Some of them took taxis. 24 house. 24 BY MR. WEINBERG: 25 Q. Anybody else seen on these videos entering a 25 Q. Some of them got driven by friends and some oi 3 17 (Pages 560 to 563) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricclutl (601 Electronically signed by Joann RIcelutl (601 bdcd1876•c72es•432d 8cf0.b19806561291 EFTA00298357 Page sc..: 1 - them drove themselves, correct? BY MR.. WEINBERG: 2 MS. ARBOUR: Form, asked and answered 2 Q. And that they would be paid for it? 3 THE WITNESS: Correct. 3 A. Yes. 4 BY MR.. WEINBERG: 4 MS. ARBOUR: Form, and asked and answered. 5 Q. And they all made a decision to drive their 5 BY MR. WEINBERG: 6 cars or get into a taxi to be driven or to get into 6 Q. M. also told you that she told them to 7 their friends' cars to go to El Brine Way? 7 represent themselves as 18 years old, correct? 8 MS. ARBOUR: Form, and asked and answered 8 MS. ARBOUR: Form. 9 THE WITNESS: Correct. 9 THE WITNESS: I don't know if she said that 10 BY MR. WEINBERG: 10 they have to be 18, unless — if it's documented in 11 Q. They then told you, as a matter ofroutine and 11 the report, then it is. 12 practice, that they either were dropped off, parked 12 BY MR. WEINBERG: 13. their cars and entered the first floor ofMr. Epstein's 13 Q. At least some of the girls told you that, in 14 home, correct? 14 fact, they told Mr. Epstein — they were directed to 15 MS. ARBOUR: Form. 15 tell Mr. Epstein they were 18 and, in fact, they did? 16 THE WITNESS: Correct 16 MS. ARBOUR: Form. 17 BY MR. WEINBERG: 17 THE WITNESS: I know that on several 18 Q. They went inside and were greeted by someone 18 occasions, some of the girls said, you know, that 19 and often brought upstairs to the second floor, correct? 19 they knew that Mr. Epstein knew that they were in 20 MS. ARBOUR: Form, and asked and answered. 20 high school, that they were asked what high school 21 THE WITNESS: Correct. 21 they attended, what grade they were in, that kind 22 BY MR. WEINBERG: 22 ofthing. 23 Q. MI., for instance, when you interviewed her, 23 BY MR. WEINBERG: 24 said that on her first occasion, she was taken there by 24 Q. And other girls, I ikoM., told you that they 25 a Mend, went in the first floor door and was taken 25 were told that they needed to say they were 18, they Page 565 Page 567 1 upstairs to the second floor, correct? 1 needed to represent themselves as 18 if asked, and that 2 A. Correct. 2 she did represent herself to be an I8-year-old when she Q. She told you she gave Mr. Epstein a massage, 3 made her single visit to Mr. Epstein's home in the early 4 correct? 4 part of2005, correct? 3 A. Yes. 5 MS. ARBOUR: Form, and asked and answered. Q. She told you Mr. Epstein perceived that she 6 THE WITNESS: That's the interview that 7 was uncomfortable giving him a massage? 7 Detective Pagan conducted. 8 A. Yes. 8 Can I just have two minutes? Q. And that Mr. Epstein told her she didn't have 9 (A brief recess was taken.) 10 to or shouldn't — not didn't have to — strike that — 10 BY MR. WEINBERG: 11 but she wouldn't be asked to do what she was 11 Q. FBI agents, you had several meetings with them 12 uncomfortable with a second time? 12 after this meeting with Special Agent Ortiz? 13 MS. ARBOUR: Form. 13 A. T believe I had one more meeting with 14 THE WITNESS: Correct. 14 Kirkendahl and someone else. 15 BY MR. WEINBERG: 15 Q. Do you recall where that meeting occurred? 16 Q. thereafter, said that she brought six 16 A. I believe it was at the US Attorneys office. 17 people to Mr. Epstein's home? 17 Q. In Palm Beach? 18 A. Correct. 18 A. West Pah». 19 Q. AndMold you that on each and every one 19 Q. West Palm? 20 of them, she told them precisely what they were going to 20 And was that a meeting at which you reviewed 21 be asked to do, which was to give a massage to 21 the evidence that you then collected pursuant to your 22 Mr. Epstein in various states of undress, correct? 22 role as the case agent in charge of the '05 Epstein 23 MS. ARBOUR: Form, and asked and answered. 23 case? 24 THE WITNESS: Yes. 24 A. I believe I gave Agent Kirkendahl a summary of 25 25 the case. There was another agent in there, 1 can't 18 (Pages 564 to 567) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricciuti (601 bdcd11376-c729-432d4c10.b19844661291 EFTA00298358 Page 568 Page 570 1 recall his name. 1 A. I signed it out on the 3rd and returned it on 2 Q. Does Jason Richards ring a bell? 2 the 4th. 3 A. Jason came in after the fact, but there was 3 Q. And what did you sign out on the 3rd? 4 someone else in there. Jason wasn't present in that 4 A. Items No. 1 through 5, 8 through 12,5 through 5 meeting. 5 I7, 20 to 22. 6 Q. And this was the second meeting, the first one 6 Q. And these were items that reflect evidence 7 being with the Chief and Ortiz - 7 that was seized on October 20th from Mr. Epstein's home? 8 A. Correct. 8 A. Right. It would probably be the page right 9 Q. — and the other one being with Kidcendahl and 9 before this one. 10 the second agent; is that correct? 10 Q. And you checked it out on the 3rd and returned 11 A. Correct. 11 it on the 4th because you wanted to view it with the 12 Q. And this meeting got more detailed in terms of 12 FBI; is that correct? 13 your giving the FBI agents, in essence, an overview of 13 A. Correct_ 14 the results of your State investigation? 14 Q. And that's October 3, 2006, correct? 15 A. Correct 15 A. Correct. 16 Q. And did you give them evidence at this time? 16 Q. And if we then go back to what has been 17 A. I don't believe so. 17 separately admitted into evidence here — I don't recall 18 Q. Did you review evidence with them? 18 the exhibit number, but showing you what appears to 19 A. I might have had with me a small case file 19 be a property receipt dated October 20th that has 20 which had flight logs -- which had some of the flight 20 numbers 1 through 58, and ask you whether or not those 21 logs, that I may have shown them. 21 four handwritten pages, numbered 1 through 58, arc the 22 Q. And those would have been flight logs that 22 log of evidence that was taken from Mr. Epstein's home 23 would have derived from where? 23 on October 20th, pursuant to your execution of the State 24 A. Mr. Dashowitz. 24 search warrant. 25 Q. Was Mr. Dershowitz brought the flight logs to 25 A. Correct. Page 569 Page 571 1 the State Attorney? 1 Q. And the numbers that appear on that inventory 2 A. Correct. 2 log as having been checked out by you on the 3rd of 3 Q. And that was in connection with his efforts to 3 August correspond to the numbers that are on the 4 persuade the State Attorney that the State Attorney 4 inventory from the search of October 20th, correct? should reject the initiatives of the Palm Beach Police 5 A. Correct 6 Department for nue serious charges? 6 Q. And so it's clear from reading those two 7 A. 1believe so. 7 documents together, that on October 3rd — strike 3 Q. And do you recall reviewing the message pads 8 that — on August 3, 2006, you were reviewing with the 9 at any time with the FBI agents? 9 FBI the results of your search and seizure dating back 10 A. I may have had some copies. Like I said, l 10 to October 20, 2005, correct? 11 had a small case file; that I didn't bring the entire 11 A. Correct. 12 case. I may have had some. 12 Q. And you were showing them things like message 13 Q. And there would have been some report on the 13 pads, correct? 14 chain of custody log regarding your having checked out 14 A. Correct. 15 various exhibits to review and then retwn; is that 15 Q. And you were informing them that the message 16 possible? 16 pads, in some respects, corroborated what you informed 17 A. What I had was copies. 17 them were the results of your witness interviews? 18 Q. SoI'm showing you a supplement for a chain of 18 A. Correct 19 custody, a Palm Beach property receipt. And if you 19 Q. And you, in essence, were using the evidence 20 would just refresh your recollection from the lower two 20 that came from Mr. Epstein's home to demonstrate that 21 lines and see if that provides us with some reflection 21 there was support for these narratives that were given 22 regarding the review of evidence. 22 to you by your various witness interviews that you began 23 A. Correct. 23 to conduct in October of 2005, correct? 24 Q. And what does that tell you now that your 24 A. COrrect. 25 memory is refreshed? 25 Q. And I through 5 are largely the phone message 19 (Pages 568 to 571) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RIcciuti (601 Electronically signed by Jeana RIcclutl (601 bdcd1876-6726-4326430(0-619666561291 EFTA00298359 Page 572 Page 574 1 book from the kitchen, the phone message book from the 1 they were returned. 2 cacti off the kitchen, the file folder of messages, 2 Q. Do you recall whether they were returned with 3 shredded paper from the office, an orange folder marked 3 the rest of the houseman's possessions? 4 "Messages: correct? 4 A. I don't believe so. 5 A. Correct. 5 Q. What was returned to the houseman were copies 6 Q. And then in addition, there were pictures -- 6 kept by the Palm Beach Police Department? In other 7 A. I think the orange folder was massages. 7 words, were they copied and the originals were returned 8 Q. Marked 'Message," it says here, M-E-S-S-Afir-E. 8 to the houseman? 9 A. Okay. 9 A. No. Items that belonged to the houseman were 10 Q. M-E-S-S-A-G-E, right? 10 returned right to the houseman. 11 Is this your handwriting? 11 Q. And no copies were kept by the Palm Beach 12 A. No. 12 Police Department? 13 • Q. Okay. And then there were photos that are 13 A. No. 14 numbered 8 through 12. If I can — since 1 don't have a 14 Q. And therefore, none were turned over to the 15 second copy of this., do you mind if I just read with 15 FBI when they executed their later subpoena, correct? 16 You — 16 A. They all were turned over. 17 A. Absolutely. 17 Q. To the houseman? 18 Q. -- so we can shortcut this already lengthy 18 A. To the FBI. 19 afternoon? 19 Q. So the FBI got copies of everything that 20 8 through 12 are the photos of difference 20 appears on items 1 through 58 of the search warrant 21 pictures taken from Mr. Epstein's home. 21 inventory? 22 A. Correct 22 A. Items that belonged to Mr. Janusz were given 23 Q. And then 15 through 17 were more photos and 23 back to him. His personal computer, his external media, 24 more message books taken from the rust floor, correct? 24 his photo discs for his camera, those were returned. 25 A. Uh-huh. 25 Q. Was his computer reviewed before it was Page 573 Page 575 Q. And then you checked out 20 through 22, which 1 returned? 2 was photos from his desk and from a table in the first 2 A. Yes. 3 floor office? 3 Q. And it was, in other words, your forensic team 4 A. Correct 4 or your Sheriffs forensic team 5 Q. And then you went to 26 to 30, which were more 5 A. The Sheriffs office. 6 pictures, transcript? That's Jane Doe 103,1 assume? 6 Q. reviewed the computer? 7 A. Correct 7 A. Correct 8 Q. So videotapes of what turned out to be adult 8 Q. And by reviewing the computer, they image de 9 pornography, correct? 9 computer, do they not? 10 A. Yes. 10 A. Uh-huh. 11 Q. More pictures? 11 Q. And they look through the image in order not 12 A. Yes. 12 to upset the authenticity of the different files and 13 Q. And then 49 and 50 were two message books, 13 folders that were in the original seized computer, 14 correct? 14 correct? 15 A. Correct. 15 A. Correct 16 Q. And they came from the separate standalone 16 Q. Because you didn't know what was in the 17 residence that is called the guest house, correct? 17 computer, did you? 18 A. Correct. 18 A. Correct. 19 Q. And those ultimately were message books that 19 Q. So in the event there was something there that 20 were in the possession of one of Mr. Epstein's 20 would be evidence, you didn't want to copy it and change 21 employees, correct? 21 the modification dates by looking at the original; is 22 A. The houseman, yes. 22 that right? 23 Q. But they were returned to the houseman; is 23 A. Correct. 24 that correct? 24 Q. So what happens is that the forensic team's 25 A. The message books? It would indicate there if 25 law enforcement, what they did in this case, they imaged 20 (Pages 572 to 575) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Rkciuti (601 Electronically signed by Jeans Rlcciutl (601 bdedl 876.e72e-4326400-b19m4561291 EFTA00298360 Page 576 Page 578 1 the Dell computer that was taken from the guest house? 1 Q. So die image was retained as evidence? 2 A. Correct. 2 A. It was a packet of like CDs that contained the 3 Q. The image of the Dell computer was reviewed, 3 images of that. 4 correct? 4 Q. Ofhis compute?? 5 A. Correct 5 A. His computer and the other CPU computer. 6 Q. As were different CPU units that were seized, 6 Q. And those were retained and not returned? 7 one on the first floor and one on the second floor of 7 A. Correct. 8 Mr. Epstein's residence, correct? 8 Q. And then they were ultimately part of the 9 A. 'believe there was only one on the first 9 subject of the grand jury subpoena that the Palm 10 floor. I don't believe there was one on the second 10 Beach — 11 floor. 11 A. Correct 12 Q. So there was an additional CPU unit. What is 12 Q. — PD produced — 13 a CPU? 13 A. Correct. 14 A. Like, a computer processing tmit. 14 Q. - later in August; is that correct? 15 Q. And that was imaged as well, correct? 15 A. Yes, sir. 16 A. Correct 16 Q. So that, if I'm clear, the computer forensic 17 Q. And the image was looked through there as 17 procedures used on Janusz's computer, the Dell compute:, 18 well? 18 were identical to those that would be used on any seized 19 A. Correct 19 computer, which is a complete and thorough computer 20 Q. And the only piece of evidence that you 20 review of the image of the hard drive of the seized 21 thought might be of value was a vahazy, dim lighted 21 computer? 22 picture ofsomeone that might ben? 22 A. Correct. 23 A. Correct There was video images of that. 23 Q. And it's essentially they just an A tot 24 Q. But you couldn't tell for sure and, therefore, 24 search to see whether or not the computer contains any 25 you'd be candid with us and say, I'm not 100 percent 25 file or folder or e-mail or data or picture that would Page 577 Page 579 1 sure that it was..? 1 be consistent and further your investigation? 2 A. It might be somebody else. 2 A. I don't believe there were e-mails. I think 3 Q. And that was the CPU that connected to the 3 it was file pictures or any data, but I don't think eve 4 first floor camera, correct? 4 went into e-mails. 5 A. Correct. 5 Q. So you know these computers contain, 6 Q. And that was the same CPU that was seen in 6 essentially, a mountain of information when they are 7 2003 to reflect the identify of the thief that was 7 regularly used? 8 stealing the money from Mr. Epstein's desk? 8 A. Correct. 9 A. Possibly. 9 Q. And what was done by your forensic team is to 10 essentially skim or scan through or review this mountain 10 11 Q. It was the same connection? There was a camera on the first floor directed at Mr. Epstein's 11 of data to see if any one file or folder or piece of I 12 desk? 12 data was consistent with and furthered your I 13 A. Correct. 13 investigation? 14 Q. And the photos went into a separate unit? 14 A. Correct 15 A. Correct. 'at, I do remember. 15 Q. And in terms of this Dell computer, the answer 16 Q. And there was nothing of value that was seen 1.6 was none? 17 in Mr. Epstein's fust floor desk or office that was 17 A. Right. 18 recorded by this camera that was in the clock, correct? 18 Q. And in terms of the CPU that was taken from an 19 A. Correct. 19 area on the first floor of Mr. Epstein's house, there 20 Q. No sex, no massage, just a man at his desk? 20 was none with the exception of a single image that was 21 A. Correct. 21 22 bard to see and might bea? A. There were segments of videos, but again, the 22 Q. Now, when the Dell computer was returned to 23 Janusz from a complete search by the forensic team, was 23 lighting was poor, so... 24 the image of the computer returned to him as well? 24 Q. And again, when you went in there on 25 A. I don't believe so. 25 October 20th with a warrant, you had no allegation from 4 21 (Pages 576 to 579) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciull (601= Electronically signed by Jeana Medial (601 bdcd1876-c728-432d4cf04219a06613129( EFTA00298361 Page 580 Page 582 1 any particular witness that thae would be anything on 1 A. Pretty much. 2 any of those computers that would be a porn photo, for 2 Q. And did you physically bring them the case 3 instance? 3 materials? 4 MS. ARBOUR: FO(111. 4 A. No. They came to the police department and 5 BY MR. WEINBERG: 5 took possession of them. 6 Q. No one told you that? 6 Q. Was this a fourth meeting with them? 7 A. No. 7 A. No. That was the mating. 8 Q. Now, this was the first shoe that you had a 0 Q. In other words, they called you in advance and 9 discussion with Agent Kirkendall regarding the Epstein 9 said they were coming with a subpoena, please — 10 investigation, August 3rd or 4th of 2006? 10 A. We're coming with a truck and subpoena, get 11 A. I believe the first time was with Junior, the 11 everything ready. 12 second time was with ICiiitendahl and another agent 12 Q. And they got the results of the search and 13 Q. Do you have any memos or notes of that meeting 13 seizure from October 20th; is that right? 14 or were you essentially seeing them as a witness to 14 A. Well, everything — 15 their investigation? I mean — strike that 15 Q. Everything on your inventory list. 16 Did you take any notes of that meeting? 16 A. Everything but what belonged to Janusz. That 17 A. No, I did not take any notes. 17 went back to him. 18 Q. And what did you see your role as at that 18 Q. Except what you imaged that belonged to 19 meeting? 19 Janusz, which was maintained and turned over pursuant to 20 A. Providing them, basically, a synopsis of the 20 the subpoena? 21 22 case and answering any questions that they may have. Q. Do you recall any particular questions? 21 22 A. Correct Q. Second is that you gave them all of the I 23 24 A. I knew that one of the questions were, did any of the victims fly out of the country with Mr. Epstein. 23 24 physical results of the trash pulls, correct? A. Correct. 1 25 At that point, I had that packet of some of the flight 25 Q. Both those that occurred in March and April Page 581 Page 583 1 logs, so... 1 under the aegis ofOfficer Pagan or the Burglary Task 2 Q. Which came to you from Mr. Epstein's lawyer -- 2 Force, and those that were conducted under your 3 A. Right. 3 investigatory supervision, correct? 4 Q. — through the State Attorney? 4 A. Correct 5 A. But there was several that were missing, so... 5 Q. And did you watch the trash pulls or was that 6 Q. The ones you had reflected no trips on 6 something you said you assigned to others to watch? 7 Mr. Epstein's plane by any of the persons that you 7 A. That was assigned to others to watch. identified as being people who went to his house — 8. Q. And they'd report to you that they watched it? 9 A. That's — 9 A. And they actually conducted their supplements. 10 Q. — in your case, correct? 10 Q. And physically, they took the bag of garbage 11 A. Thaes pretty much correct 11 from the garbage man, right? 12 Q. Was there a third meeting with the FBI? 12 A. Correct. 13 A. The third meeting I think it was when they 13 Q. By pre-arrangement, correct? 14 showed up with the grand jury subpoena requesting all 14 A. Uh-huh. 15 info on the case. 15 Q. At a place close to Mr. Epstein's home but 16 Q. And did you have a substantive discussion with 16 inaccessible to his vision, correct? 17 them on that occasion, or was it just an occasion where 17 A. Correct. 18 they served the subpoena on you as the person to whom — 18 Q. And they then took that bag back to the Palm 19 A. They served a subpoena on nit as the person who 19 Beach Police Department and searched within it for 20 had the information. 20 evidence, correct? 21 Q. And it was a broad subpoena that essentially 21 A. Correct. 22 asked you for everything? 22 Q. And that bag, to your knowledge, was taken 23 A. Everything. 23 from within Mr. Epstein's property gates? 24 Q. And you produced everything because that's 24 A. Correct. 25 what you do when you get a federal subpoena? 25 Q. inside the gates. And it happened on occasion . 22 (Pages 580 to 583) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Joana RiccitlE (601M Electronically signed by Joana Ricciull (601 bdcd1876-0726-4326411410431964656129f EFTA00298362 Page S84 Page 586 3 two and three times a week? 1 and that's when Jason stepped in. I 2 A. I believe so. 2 Q. Did you have any communications with Jason? 3 Q. And it happened at times that there wouldn't 3 A. I can't recall if l did or didn't. 4 be limey garbage runs at Mr. Epstein's house? on 4 Q. And how about with any of the United States 5 A. Once a week there is a recycle pickup day. 5 Attorneys, did you have any substantive communications 6 Q. And did you participate in the search through 6 with anyone in the upper hierarchy of the US Attorney's 1 7 the garbage? 7 office? 8 A. No. A. No. 9 Q. But others did and you directed them as to 9 Q. So there was no conversations between you and 1 10 what to look for, correct? 10 the US Attorney? 11 A. Correct. 11 A. No. 12 Q. Evidence ofMr. Epstein's meetings with or 12 Q. The acting US Attorney? 13 phone call — strike that. Evidence ofMr. Epstein's 13 A. No. 14 meetings or relationships to different witnesses in your 14 Q. The head ofcriminal? 15 case? 15 A. No. 16 A. Correct. 16 Q. And how about the US Attorney in charge of the 17 Q. Leads to new witnesses, correct? 17 investigation ofMr. Epstein? 18 A. Correct. 18 A. No. 19 Q. And you got leads to new witnesses from the 19 Q. No meetings involved with Ms. 20 garbage pulls, correct? 20 A. Na 21 A. Correct. 21 Q. All of your carununications were with FBI 22 Q. And then you got more leads to new witnesses 22 agents, and you've provided us with the details 23 from message pads that were seized from Mr. Epstein's 23 regarding those meetings. And there were really 24 home on October 20th? 24 primarily two meetings; one attended by ChiefReiter 25 A. Correct. 25 between.you and Special Agent Ortiz, and then the Page 585 Page 5R7 Q. Now, the FBI came and the file was essentially 1 followup meeting which this evidence log reflects checked out on October 28, 2006 at 1:30 p.m.? 2 occurred on August 3rd or 4th wherein you reviewed A. Where it says TOT FBI? Yeah. 3 largely the results of the search and seizure of Q. Did you have any occasion to meet with the FBI 4 Mr. Epstein's home on October 20, 2005? after October 28 -- or after August 28, 2006? 5 A. Correct A. I think I was telephoned once by Agent 6 Q. Mr. Reiter, Chief Reiter or former 7 Kirkendahl requesting clarification on something, and 7 ChiefReiter, how often do you speak to him since he 8 then I would call her, hey, how's everything going, can 8 left office? 9 you share anything, and no, 1never got any response 9 A. I've seen him maybe two or three times and 10 back as far as what was going on or... 10 spoken to him maybe a handful of times. 11 Q. Do you recall what the subject was that the 11 Q. Do you know whether or not he is employed or 12 FBI agent asked you about, Agent Kirkendahl? 12 planning to be employed as a private investigator? 13 A. No. 13 A. I have no idea. 14 Q. And so that was the last substantive 14 Q. Do you know whether he was ever employed by 15 communication with Agent Kirkendahl? 15 the Rothstein firm? 16 A. Like I said, I would call her. 16 A. I have no idea. 17 Q. Right, but those were essentially, what can 17 Q. Do you know whether or not he's engaged in any 18 you tell - 18 private investigation in connection with any of the 19 A. Nothing. 19 Plaintiffs' cases against Mr. Epstein? 20 Q. There was no content to those? 20 A. I have no idea. When we speak, we don't speak 21 A. No, no. 21 about business. 22 Q. And what about the male agent that you 22 Q. Understandably, given that you're being 23 remembered meeting with Agent Kirkendahl that was on 23 deposed. 24 August 4, 2006? Did you ever have a followup with him? 24 Before (Thief Reiter left and, in fact, before 25 A. Shortly thereafter, I think he loft the FBI, 25 the Plaintiffs' lawyers instituted these civil lawsuits, gIV•SS - ' .--IrraWCWO“•••••••••• •• 23 (Pages 584 to 587) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricautt (601 Electronically signed by deans RIcetun 0101 bdcd1876, c72o 432c1.8cf0-b19ao656129f EFTA00298363 Page 588 Page 590 1 though, you and the Chief would see each other 1 last week. 2 regularly, correct? 2 Q. So you don't know about all these c-mails that 3 A. Yes. 3 have been disclosed to us through public record searches 4 Q. In fact, you and the Chief would e-mail each 4 reflecting e-mails between Chief Reiter and the other regularly regarding matters of common interests; 5 different members of the media wherein he's keeping them 6 is that correct? 6 in touch with the events connected to the Epstein case9 7 A. Yes. 7 A. No. 8 Q. And you and the Chief would c-mail each other 8 Q. Or his e-mail to the US Attorney's office, 9 about interests including the ongoing efforts of the 9 saying, "Contrary to your information, you may note that 10 media to find out what's going on in the Epstein case? 10 nothing in the story relative to the plea was attributed 11 A. Yes, through Goo& alerts and things he would 11 to me, as I have not discussed this case with the news 12 come across and things I would come across, I would send 12 media." 13 to him. 13 Are these not e-mails that you remember or 14 Q. In other words, Reiter to Ramey, 14 that you were copied on? 15 September 6, 2007, 'Channel 5 ran a major story on 15 A. No. I'm the low man on the totem pole. 16 Epstein at 6:00. Showed footage ofEpstein at PBIA and 16 Q. I understand. That's why there's a chief and 17 audio of Connolly from Vanity Fair saying Epstein would 17 the rest of us. 18 take a plea as early at tomorrow, signed Reiter." 18 A. And many wigwams. 19 Do you remember that one? 19 MR. WEINBERG: May I have one minute with my 20 A. Yes. 20 co-courtsel? This depo may be concluded. 21 Q. Or Reiter to Recarey, December 10,2008, 21 (A brief recess was talon.) 22 'Shiny Shade advised me they're naming her article 22 MIL WEINBERG: In the interest of speed, 23 tomorrow that Epstein's on work release. Read it 23 say thank you for a long day, Detective Recarey. 24 online. Please notify Nesbitt. Thanks, Reiter." 24 I'm finished. 25 Do you recall following that direction and 25 THE WITNESS: Thank you very much. Page 589 Page 591 1 notifying — 1 CROSS (DETECTIVE JOE RECAREY) 2 A. I may have called her and left her a voice 2 BY MS. ARBOUR: mail, Nesbitt Kirkendahl. Like I said, everything with 3 Q. Detective, the search warrant that you the FBI is one way. They don't share the information. 4 executed on 358 El Brillo Way, prior to the execution in A lot of times I would call her desk line and it goes 5 October of2005, did you do any research on who the right to voice mail, so I would just leave her thc 6 property owner was? information and... 7 A. Yes. 8 Q. Can you recall as an aftermath of that 8 Q. And were you able to determine who owned that information regarding work mleuse that there was some 9 FroPa1Y? 10 discussions as to whether or not Mr. Epstein's contract 10 A. Yes. I believe it was Mr. Epstein, but I 11 required him to do day-to-day in prison, meaning to 11 think it was under a corporation. 12 serve 18 months, or whether instead he had to be 12 Q. Did you do any research on potential residents 13 sentenced to 18 months which would make him eligible for 13 at that address? 14 work release and that the conclusion was that he was 14 A. Yes. 15 eligible for work release like all others? 15 Q. And do you recall who you identified as a 16 A. Correct 16 potential resident, if anyone? 17 Q. And do you recall Mr. Reiter, ChiefReiter, 17 A. Mr. ein,l believe and 18 having ongoing communications with a Joyce Reingold at 18 MMTM 19 the PB Daily News in the fall of 2008? 19 Q. Did you determine that it was an address used 20 A. I have no idea. 20 by Jeffrey Epstein? 21 Q. But you knew Unlike waste chief and he was 21 A. Yes. 22 the contact person for a lot of the media•to-police 22 Q. The message pads that you seized during the 23 communications? 23 search warrant in October of2005, do you recall how 24 A. Actually, Janet Consuelo is the — well, was 24 many there were? 25 the PIO for the Police Department. She just retired 25 A. Five, five or six, I think. 24 (Pages 588 to 591 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Rlcciutl (601 Electronically signed by Jeana McGinn (601 bdcd1876-c72e-432d-Ilet0-b19a4561291 EFTA00298364 Page 592 Page 594 1 Q. Does that include the ones that were 1 Q. At any time. 2 ultimately returned to Mr. Janusz? 2 A. I recall a lot of names. Would you know, more 3 A. None were returned to Mr. Janusz. 3 or less, what page? 4 (Deposition Exhibit No. 29 was marked for 4 Q. The truth is, I'm not even sure if she's in 5 identification.) 5 there. • just asking if her name's in there. 6 BY MS. ARBOUR; 6 A. Oh, I can't recall. 7 Q. I'll show you what I've marked as 29, and It 7 Q. Do you recall seeing the name Jane Doe 4 on 8 represent to you that I got those from a public records 8 any of those messages? 9 request from the State Attorney. I'll ask you to flip 9 A. Yes. 10 through them and ask you if that seems to be all the 10 Q. Do you recall seeing the name Jane Doe 3 on 11 ones that you seized. 11. any of those messages? 12 A. This was three message books. This would be 12 A. I can't recall. 13 No. 2 on the property receipt. 13 Q. How about Jane Doe 6? 14 Q. So would there be an additional two or three 14 A. No, I'm sorry. 15 message books malted as No. 1 or something on the 15 Q. How about Jane Doe 7? 16 property receipt? 16 A. Yes. 17 A. There would be No. 1, No. 2. On the search 17 Q. And how about Jane Doe 8? 18 warrant return, you would see the different ones that 18 A. Yes, I remember Jane Doe 8. 19 bad the different message books. 19 Q. you recall seeing a or a 20 Q. Do you recall, of all of the message books 20 21. that you reviewed, not just the one in May ljust marked 21 A. Yes. 22 as 29, what time period they covered? 22 Q. Do you recall seeing the name M.? 23 A. Off the top of my head, no, I couldn't tell 23 A. Yes. 24 you. 24 Q. ChM. Okay. 25 Q. Do you know if they extended into 2004? 25 Did you ever speak with at Page 593 Page 595 1 A. I knew we got current books and older books, 1 any point during your investigation? 2 but I couldn't tell you the time frame. 2 A. It doesn't ring a bell. 3 Q. Do you recall what rooms the message pads were 3 Q. Do you recall speaking to anyone who informed 4 taken from inside the main residence at El Brillo? 4 you that they brought a girl named Jane Doe 8 to 5 A. There was some taken from the small office in 5 Mr. Epstein's house? 6 the kitchen area, there was some taken from the kitchen 6 A. No. 7 area, there was some taken from — there was some taken 7 Q. Do you recall ever speaking to a girl who 8 from the guest house, I believe the pool house and then 8 informed you that she brought Jane Doe 6 to 9 there is like a little pantry area. There was, I think, 9 Mr. Epstein's home? 10 a book taken from there too. 10 A. No. 11 Q. And when you say the pool house, is that the 11 Q. During your execution of the search warrant in 12 room that Mr. Epstein or someone used as an office out 12 October 2005, did you recover any vibrating massagers? 13 by the pool? 13 A. I remember a twin torpedo, but no. 14 A. Yes. There was like a pad, you know, like a 14 Q. What is a twin torpedo? 15 writing -- like an old grease marker pad. 15 A. Double sided — 16 Q. Obviously, since I got those as part of a 16 Q. Okay, some type of sex toy? 17 public records, a lot of them are redacted. Must 17 A. Yeah. 18 going to ask you if you recall seeing any of the 18 Q. Which room did you recover that from? 19 following names on the pads. Anything you need to refer 19 A. That was from a back bedroom. 20 back, that's fine. 20 Q. Do you recall — I'm sorry, did you recover 21 Do you recall seeing the name Jane Doe 2 on 21 any lotions from within a bathroom? 22 any of those messages? 22 MR. PIKE: Form. 23 A. Can I refer? 23 THE WITNESS: From a small credenza, there was 24 Q. Absolutely. 24 a lotion there was a lotion in a small credenza 25 A. Do you know, more or less, when? 25 in the master bedroom, a little Joy Jelly bottle. 25 (Pages 592 to 595) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricetull (601 bdcd1876-c720-432d-Bc10-b19ae8561291 EFTA00298365 Page 596 Page 598 BY MS. ARBOUR: I been made? 2 Q. And the master bedroom, was that the same 2 A. I believe so. 3 master bedroom you understood to be the massage room? 3 Q. Were you able to cross reference any of the A. Yes. 4 witnesses withMr. Epstein's phone records? Q. Turning back to your testimony about reviewing 5 A. I only subpoenaed the house phone records the phone records for Ms. and Mr. Epstein I 6 because there was no indication of anything on his cell. 1 believe you said you reviewed as part of your 7 But there was, I believe, some phone calls made to the i investigation. 8 victims/witnesses from the house. 9 A. Yes. 9 Q. And did you do any research to find out who 10 Q. When you reviewed Ms. phone records, 10 was the registered user of that house phone? 11 what period of time did those phone records cover? 11 A. It was registered to Mr. Epstein. 12 A. I don't 'mow the specific time frame. 12 Q. Were you able to confirm that Ms 13 Q. Do you recall if it covered only 2005? 13 placed or received any phone calls from Jane We 14 A. Possibly. I don't recall but... 14 during your review ofha records? 15 Q. Would it be noted in the probable cause 15 A. Yes. 16 affidavit? 16 Q. Were you able to confirm that Ms. 17 A Probably in the incident report 17 received or made any phone calls to Jane Doe 7? 18 Q. You can flip through if that helps to refresh 18 A. Yes. 19 your recollection. 19 Q. Were you able to confirm that Ms. made 20 A. I wouldn't even know where to find it at this 20 or received any phone calls from Jane Doe 3? 21 point. 21 A. I can't recall if there were any calls to 22 Q. You believe it's in the incident report, 22 Jane Doe 3. 23 though? 23 Q. Were you able to confirm that any phone calls 24 A. I believe so. 24 had been made or received by the house phone by 25 Q. And would it be the same time period that 25 Jane Doe 4? Page 597 Page 599 I covered Mr. Epstein's phone records as Ms.M? 1 MR. PIKE: Form. 2 A. I believe Mr. Epstein's was not as in depth as 2 114E WITNESS: I believe so, yes. 3 Ms. 3 BY MS. ARBOUR: 4 Q. And with regard to the phones, did you pull 4 Q. Were you able to cross reference any phone S the phone records for the house phone itself or cellular 5 calls received front or made to Jane Doe 7 from the house b phones for each of the people? 6 phone? 7 A. I believe it was Ms. cell phone and 7 A. I can't recall brim the house phone, Pm house phone records. 8 sorry. Q. At any point, were you able to match up Q. What you interview — as part of your 10 victims with Ms. phone records where there had 10 investigation, you interviewed Janusz Banasiak: is that 11 been some communication between the two of them? 11 correct? 12 A. Yes. 12 A. Yes. Well, I take that back. I attempted it. 13 MR. PIKE: Form. 13 That never happened. 14 BY MS. ARBOUR.: 14 Q. At any point, did you come to Team that he 15 Q. Were any of those victims under the age of 18 15 rented a car for Jane Doe 4 to use? 16 at the time the phone calls were made? 16 A. Yes. 17 MR. PIKE: Form. 17 Q. And how did you learn that? 18 l'HE WITNESS: I believe so. 18 A. Through Jane Doe 4. 19 MS. ARBOUR: Is your objection to the use of 19 Q. And what did she tell you? 20 the word "victim"? 20 MR. PIKE: Form 21 MR. PIKE: Yes. 21 THE WITNESS: When I interviewed her, she told 22 BY MS. ARBOUR: 22 me that there was a rental car for her use that she 23 Q. Were any of the witnesses that you were able 23 was utilizI9L- actually, when I went down to talk 24 to cross reference with Ms. phone records under 24 to her at University, I actually found the car 25 the age of 18 at the time the phone calls appear to have 25 parked in the school lot. 26 (Pages 596 to 599) PROSE COURT REPORTING AGENCY, INC. '1561) 832-7506 Electronically signed by Jeana Ricciutl (601 Electronically signed by Jeana Ricciutl (601 bded1676-072•432d-W0-019ae656129t EFTA00298366 Page 600 Page 602 1 BY MS. ARBOUR: 1 partial truth, and she did not elaborate any further. 2 Q. What did she tell you about how she came to 2 Q. Did any of the other girls that you 3 acquire that car? 3 interviewed give you that same impression, that they 4 A. She needed a car to get around. 4 were holding back or not telling the truth? 5 MR. PIKE: Fonn. 5 MR. PIKE: Form. 6 THE WITNESS: She asked Mr. Epstein if he 6 THE WITNESS: I also had that feeling from 7 could raft her a car, at which time there was a 7 Jane Doe 7. 8 rental car available to her. 8 BY MS. ARBOUR: 9 BY MS. ARBOUR: 9 Q. What is it about Jane Doe 7 that gave you that 10 Q. And you went back and researched who, in fact, 10 feeling? 11 rented that car; is that right? 11 MR. PIKE: Form. 12 A. Correct. 12 THE WITNESS: The fact that she was extremely 13 Q. And that was Mr. Banasiak? 13 nervous, extremely scared when talking about the 14 A. Yes. 14 investigation. 15 Q. When you met with each of the witnesses, each 15 BY MS. ARBOUR: 16 of the girls who had later — who you suspected may have 16 Q. When you spoke with Jane Doe 7, do you recall 17 been at Mr. Epstein's house, did you tape record each 17 if any of her parents were home? 18 and every single one of the interviews? 18 A. Yes, her mother was present. 19 A. Yes. 19 Q. Was she in the same room as Jane Doe 7 or was 20 MR. PIKE: Form. 20 she in a different room, do you recall? 21 BY MS. ARBOUR: 21 A. She was in a different room. 22 Q. And when the incident report says that a 22 Q. How did you know to go and interview Jane Doe 23 statement is sworn, that you took a sworn statement from 23 7 as part of your investigation? 24 a witness, what does that mean? 24 A. That name was given to me 25 A. Where 1 swear them in. I made them raise 25 Q. Did she indicate that Jane Doe 7 was one of Page 601 Page 603 1 their right hand and, do you solemnly swear to tell the 1 the girls she brought to Mr. Epstein's home? 2 truth, the whole truth and nothing but the truth_ 2 A. Yes. Q. Are those the exact words that you used? 3 Q. What did you tell Jane Doe No. 7's parents 1 A. Yes. 4 about why you were there to interview Jane Doe 7, if you Q. Have you since learned that some of those 5 recall? .3 girls that you interviewed did not tell you the entire 6 A. Pretty much same as I told all, I believe that 7 truth about what happened at Mr. Epstein's house? 7 they were either a victimaitness to an investigation 8 MR. PIKE: Form. 8 that I was conducting about an individual that lived 9 TIM WITNESS: I had heard, I believe, Jane 9 within the Town of Palm Beach. 10 Doe 4 was not truthful, 100 percent truthful. 10 Q. When you met with Jane Doe 7 and spoke with 11 BY MS. ARBOUR: 11 her, did she cry? 12 Q. During the course of your entire 12 A. She was scared and she was nervous. We were 13 investigation, did you ever have an opinion or a feeling 13 sitting -- the first time I went out to her house, she 14 that maybe one or more of the girls was holding back on 14 was not home. We waited for a little while and 15 what happened at Mr. Epstein's house? 15 eventually we lett, not knowing what time she was going 16 MR. PIKE: Form. 16 to be back. When I received a phone call the following 17 THE WITNESS: Yes. 17 morning, 'went back out there and she was visibly 18 BY MS. ARBOUR: 18 scared. You could tell, she was shaking. 19 Q. Can you tell me more about that? 19 Q. During the course of your interview, did she 20 A. I actually went to interview Jane Doe 4 twice 20 tell you that Mr. Epstein touched her buttocks? 21 because I had that feeling from her when 1 spoke with 21 MR. PIKE: Form. 22 her. I actually went dam to twice to speak to 22 BY MS. ARBOUR: 23 her. On the second time that 1 went down to speak to 23 Q. You eventually interviewed her, correct? 24 her, I told her the reason why I came down was that 1 24 A. Yes. 25 felt she was being untruthful, or at least telling me a 25 Q. During the course of that interview, did she 27 (Pages 600 to 603) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Rlcciuti (601 Electronically signed by Jeana RIcclutl (601 bdcd1876-c720-432d-8cf0-b19ae6561291 EFTA00298367 Page 604 Page 606 1 tell you that Mr. Epstein touched her buttarles? 1 A. Yes. 2 MR. PIKE: Form. 2 Q. During the course of your interview with 3 MS. ARBOUR: I believe so. 3 Jane Doe 7, did she tell you that she was paid to give 4 BY MS. ARBOUR: 4 Mr. Epstein massages during which he touched her in a 5 Q. During the course of that interview, did she 5 sexual way? 6 tell you that he =shit-bated in front of her? 6 MR. PIKE: Form. 7 MR. PIKE: Form. 7 THE WITNESS: Yes. 8 THE WITNESS: I believe so. 8 BY MS. ARDOUR: 9 BY MS. ARBOUR: 9 Q. Did you interview a girl named Jane Doe 3 as a 10 Q. During the course of your interview did 10 part of your investigation? 11 Jana Doe 7 play you a voice mail from Ms. M? 11 A. Yes, I did. 12 A. Yes. 12 Q. How did you know to speak with Jane Doe 3? 13 Q. What do you remember about that voice mail? 13 A I think this was another name provided to me 14 MR. PIKE: Form. 14 bY 15 THE WITNESS: It was a voice mail left on her 15 Q.Do you recall if.lane Doe 3 told you that M. 16 cell phone from asking Jane Doe 7 to 16 was the one who arranged for her to go to Mr. Epstein's 17 call her and let her know what I was looking into. 17 house? 18 BY MS. ARBOUR: 18 MR. PIKE: Form. 19 Q. Did Jane Doe 7 tell you that had called 19 THE WITNESS: I believe so. 20 multiple times during the investigation? 20 BY MS. ARBOUR: 21 MR. PIKE: Form. 21 Q. At any point during your conversations with 22 THE WITNESS: Yes. 22 Jane Doe 3, did she tell you that she was paid to give 23 BY MS. ARBOUR: 23 Mr. Epstein a massage in which he touched her in a 24 1QpWhat is your understanding of how many times 24 sexual manna? 25 Ms. called Jane Doe 7? 25 MR. PIKE: Ram. Page 605 Page 607 1 A. I believe approximately three times that 1 THE WITNESS: That is correct. 2 evening. 2 BY MS. ARBOUR: 3 Q. Did you ever review Jane Doe 7 or Ms. 3 Q. Did she tell you that Mr. Epstein touched her 4 phone records to see how many phone contacts there were 4 buttocks? 5 that day or within that period? 5 MR. PIKE: Form. 6 A. Again, I can't recall how many or the time 6 THE WITNESS: Yes. 7 frame of the phone records. 7 BY MS. ARBOUR 8 Q. Did Jane Doe 7 tell you that Ms. was 8 Q. Did she tell you that Mr. Epstein touched her 9 the one she spoke with in order to arrange Mr. F-pstcin's 9 breasts? 10 massages? 10 MR. PIKE: Same objection. 11 MR. PIKE: Form. 11 THE WITNESS: Yes. 12 TUE WITNESS: Yes. I do recall 12 BY MS. ARBOUR 13 BY MS. ARBOUR: 13 Q. Did she tell you that he masturbated in front 14 Q. Was it your understanding that.4sr 14 of her? 15 would call her or she would call Ms. or did you 15 MR. PIKE: Same objection. 16 get into that at all with her? 16 THE WITNESS: Yes. 17 MR. PIKE: Form. 17 BY MS. ARBOUR: 18 THE WITNESS: How it was told to me was 18 Q. Did you ascertain from Jane Doe 3 If she knew 19 would call like a day or two prior to their arrival 19 you were investigating Mr. Epstein before you went to 20 to Palm Beach, to coordinate a time and a date when 20 speak with her? 21 they were going to be in the Town of Palm Beach, 21 MR. PIKE: Form. 22 and if she was interested in working. 22 THE WITNESS: I interviewed.., who is an 23 BY MS. ARBOUR: 23 associate of hers as well, and I had interviewed 24 25 Q. So Ws your understanding Ms. would make a phone call to Jane Doc 7 to schedule work? 24 25 her prior to Jane Doe 3. I i 28 (Pages 604 to 607) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciutl (601 Electronically signed by Jeana RIccluti (601 bdcd1876-c72c-432d-8c10-b19ae6561291 EFTA00298368 Page 608 Page 6101 I BY MS. ARBOUR: 1 occurred at Mr. Epstein's house; is that correct? 1 2 Q. Did Jane Doe 3 indicate to you that she was 2 A. Correct. 3 expectingyou to come by or that someone had told her 3 Q. Did she tell you that she — 4 that you were investigating? 4 MR. PIKE: Form. 5 MR. PIKE: Form. 5 BY MS. ARBOUR: 6 . THE WITNESS: Someone had told her. 6 Q. — went to Mr. Epstein's house more than one / BY MS. ARBOUR: 7 time? 8 Q. Was it your understanding that M. told her 8 MR. PUCE: And form to this question. 9 there was an investigation? 9 THE WITNESS: Yes. 10 MR. PIKE: Same. 10 BY MS. ARBOUR: 11 ME WITNESS: I believe so. 11 Q. How many times did she tell you that she went 12 BY MS. ARBOUR: . 12 to Mr. Epstein's house to give him a massage? 13 Q. Did Jane Doe 3 ever tell you that she was paid 13 MR. PIKE: Form. 14 to bring other underaged girls to Mr. Epstein's house 14 (Mr. Epstein left the proceedings.) 15 for massages? 15 MR. PIKE: You can continue. 16 MR. PIKE: Form. 16 THE WITNESS: I can't— I don't know. 17 THE WITNESS: I can't recall if she did or she 17 MIL PIKE: May I ask a quick question? Do you 18 didn't. 18 need to terminate at 5:00? 19 BY MS. ARBOUR: 19 MS. O'CONNER: No. Thank you, though. 20 Q. Would it help to refer back to the PC? Do you 20 BY MS. ARBOUR: 21 have it there? 21 Q. Would it help to look at the PCA, page 9? 22 A. Yeah. 22 A. Yes. Okay. 23 Q. I think page 8 is Jane Doe 3. 23 Q. Did she tell you how many times she went to 24 MR. PIKE: Same objection to the extent the 24 Mr. Epstein's house to give hint a massage? 25 question is pending. 25 MR. PIKE: Form. Page 609 Page 611 1 THE WITNESS: Yes. 1 THE WITNESS: A lot is what she claimed. 2 BY MS. ARBOUR: 2 BY MS. ARBOUR: 1 Q. Yes, she did tell you that? 3 Q. And over what period of time do you understand 4 MR. PIKE: Form 4 she was going to Mr. Epstein's home to give him these () THE WITNESS: That she had gone back to the 5 massages? house with.. on two other occasions. 6 A. Since she was 16. 7 BY MS. ARBOUR: 7 MR. PIKE: Form. 8 Q. Did she tell you who she generally spoke with 8 BY MS. ARBOUR: 9 in order to make arrangements to go to Mr. Epstein's 9 Q. What is your understanding of how she came to 10 house for these massages, whether she was providing them 10 Mr. Epstein's house for the first time? 11 or another girl was? 11 A. I believe she was taken to the house by.. 12 MR. PIKE: Form. 12 Q. And did she tell you on her subsequent visits 13 THE WITNESS: The het that she went with 13 how she would make arrangements to get to Mr. Epstein's 14 M., so I'm sure they would contact M. 14 house, if she would call Ms. or if she would call 15 BY MS. ARBOUR: 15 the house, or can you walk me through what she told you 16 Q. Did you ever pull 's phone records as a 16 about how she got there? 17 part of your investigation? 17 MR. PIKE: Form. 18 A. I believe they were pulled by Detective Pagan. 18 THE WITNESS: if refer to it? 19 Q. Do you know how many times, if any, there was 19 BY MS. ARBOUR: a 20 convene — or there were phone calls between .'s 20 Q. Absolutely, go ahead. 21 number and lane Doe 3's number on those records? 21 A. Okay. 22 A. No. 22 Q. she toll you that she would call 23 Q. Lees focus on your interview with Jane Doe 4, 23 Ms. to make arrangements to come ova and give r. 24 or your interviews with Jane Doe 4. At some point, she 24 Mr. Epstein massages? 25 did discuss or she did give you a version of events that 25 MR. PIKE: Form. 29 (Pages 608 to 611) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RICOinti (601 Electronically signed by Jeans Riecluti (601 bdcd1876.c720-432d-13c10-b19ae6561291 EFTA00298369 Page 612 Page 614 1 THE WITNESS: Correct. 1 BY MS. ARBOUR: 2 BY MS. ARBOUR: 2 Q. And did Jane Doe 4 tell you if Mr. Epstein 3 • Q. Didshe tell you that IVIs. would call 3 ever touched her buttocks? 4 her to make arrangement to come over and give 4 MR.PIKE Form. 5 Mr. Epstein a massage? 5 THE WITNESS: Yes. 6 MR. PIKE: Form. 6 BY MS. ARBOUR: 7 THE WITNESS: On occasion. 7 Q. Did Jane Doe 4 tell you that Mr. Epstein 8 BY MS. ARBOUR: 8 touched her breasts? 9 Q. Did she tell you that she would make 9 A. Yes. 10 arrangements through.. to go ova to Mr. Epstein's 10 MR. PIKE: Fonn. 11. house to give him a massage? 11 BY MS. ARBOUR: 12 A. Initially. 12 Q. Did Jane Doe 4 tell you that Mr. Epstein 13 Q. Didyou ever cross reference Jane Doe 4's 13 touched her genitals? 14 number on phone records, specifically, 14 MR. PIKE: Form. 15 that you recall? 15 THE WITNESS: That, I don't recall. 16 A. Jane Doe 4, I do remember on her cell phone. 16 BY MS. ARBOUR: 17 Q. And do you recall if Jane Doe 4's number 17 Q. Did Jane Doe 4 tell you that Mr. Epstein 18 appeared on Ms. phone records? 18 performed oral sex on her? 19 A. Jane Doe 4, I believe so, yes. 19 MR. PIKE: Form. 20 Q. Do you know if you looked specifically to see 20 THE WITNESS: No. 21 if any ofMs. phone records indicated 21 BY MS. ARBOUR: 22 communication between Jane Doe 4 and Ms. Min 22 Q. Did Jane Doe 4 tell you that Mr. Epstein used 23 strike that, let me start over. 23 a vibrator or a vibrating massager on her? 24 Do you recall looking at phone records prior 24 MR. PIKE: Form. 25 to June of 2005 to see if there veere any cross 25 THE WITNESS: She claimed that the vibrator Page 613 Page 615 1 references prior to Jane Doe 4 turning 187 1 was not used on her. She knew of the vibrator, but 2 A. I don't know. I can't recall the time frame 2 it was not used on her. 3 of the cell phone records. 3 BY MS. ARBOUR: 4 Q. Do you recall if, at the time did End 4 Q. Is it your understanding that when — when Jane Doe 4's number on Ms.ME records, Jane Doe 4 5 Jane Doe 4 — so going back to what she did tell you, 6 was under 187 6 which is that he touched her buttocks and her breasts at 7 A. Not - fin not sure because I don't know the 7 least, was it your understanding that those incidents 8 time frame I have the cell phone records from. 8 occurred when she was under the age of 18? 9 Q. Did Jane Doe 4 tell you that Mr. Epstein 9 MR. PIKE: Form, move to strike. 10 touched her in a sexual manner on more than one 10 THE WITNESS: Yes. 11 occasion? 11 BY MS. ARBOUR: 12 A. Yes. 12 Q. Did she tell you that the touching of the 13 Q. Did she tell you that Mr. Epstein masturbated 13 buttocks and the touching of the breasts occurred before 14 in front ofher? 14 she was 18? 15 MR. PIKE: Form to the last question, and fans 15 MR. PIKE: Font 16 to this question. 16 THE WITNESS: She had been going there since 17 THE WITNESS: Yes. 17 the age of 16. I can't recall if she said she was 18 MR. PIKE: You're just too fast. 18 under 18 when he was touching her buttocks and 19 MR. GARCIA: I join. 19 breasts. 20 BY MS. ARBOUR: 20 BY MS. ARBOUR: 21 Q. Did Jane Doe 4 tell you that she was nude in 21 Q. When you interviewed Jane Doe 4, where did the 22 front ofMr. Epstein during the massages she gave him? 22 interview take place? 23 MR. PIKE: Form. 23 A. University. 24 THE WITNESS: I believe down to her thong 24 Q. And was it in a particular place, in a 25 underwear. 25 particular room, or — 30 (L'ages 612 to 615) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Moduli (601 Electronically signed by Jeana Riccluti (601 bdcd1876-c72c432d-8cfrittga06561291 EFTA00298370 rage 616 Page 618 1 A. It was in a small office room within — next 1 Q. The number that's on there, 635-3454, do you 2 to the PE room. 2 see that? 3 Q. And was anyone else present? 3 A. Yes. 4 • A. Detective Dawson. 4 Q. Did you do any investigation into that number? ) Q. And did Jane Doe 4 — during the course of 5 A. Yes. 6 your interview, was Jane Doe 4 crying? 6 Q. And what did you find it to be? A. She was shaken, nervous and occasionally she 7 A. I believe that was Jane Doe 4's number. 8 would ay. Q. And how about the other number that's on 9 Q. Was that the first interview or the second 9 there, 324-7996, did you investigate that number? 10 interview that took place — 10 A. I believe I did request subscriber information 11 A. The first one. 11 on that. I can't recall who that came back to, though. 12 Q. — in that room? 12 MS. O'CONNER: Can we go off the record for .1 13 A. The first one. 13 minute? 14 Q. Where did the second interview take place? 14 MS. ARBOUR: Sure. 15 A. She had just finished playing soccer. I want 15 (Discussion held off the record.) 16 to say — the second one, I believe, was in the PE area. 16 BY MS. ARBOUR: 17 It was like a gym, like a gymnasium. 17 Q. Did you ask Jane Doe 4 about this note? 18 Q. And in that second interview, was she crying 18 A. No. 19 when she spoke with you? 19 Q. Why not? 20 A. I can't recall if she was or if she wasn't. I 20 A. I felt that she was holding back from Inc, so I 21 know the first one she was. 21 didn't want to let her know what I knew. I stressed to 22 Q. Did she ever ask you if she was in trouble for 22 her that I !mew a lot more than what I was letting on 23 what happened at Mr. Epstein's house? 23 to, but she continued with her limited story. 24 MR. PIKE: Form. 24 Q. At any point, did Jane Doe 4 tell you that she 25 THE WITNESS: I don't recall. 25 bad told Mr. Epstein about the police investigation? Page 617 Page 619 1 BY MS. ARBOUR: 1 MR. PIKE: Fonn. 2 Q. Do you recall if any of the witnesses that you 2 THE WITNESS: I can't recall if she said 3 interviewed asked if they were in trouble for what 3 anything. 4 happened at Mr. Epstein's house or for what they say 4 BY MS. ARBOUR: 5 happened at Mr. Epstein's house? 5 Q. Do you recall if any of the witnesses that you 6 MR. PIKE: Rom. 6 spoke with told you that they told Mr. Epstein about the 7 THE WITNESS: I recall s was concerned that 7 police investigation, your investigation? 3 she might have been — be getting into trouble. 8 MR. PIKE: Form. 9 BY MS. ARBOUR: 9 THE WITNESS: I believe ■., when I 10 Q. Let me show you this, marked 30. 10 interviewed her in Orlando. 11 (Deposition Exhibit No. 30 was marked for 11 BY MS. ARBOUR: 12 identification.) 12 Q. Did that interview take place before or after 13 BY MS. ARBOUR: 13 Jane Doe 4's first interview? 14 Q. Detective, have you seen that document before? 14 A. After. 15 A. Yes. 15 Q. And what did you and M. discuss about her 16 Q. And what are you recognizing this document to 16 reporting to Mr. Epstein about your investigation? 17 be? 17 MR. PIKE: Form. 18 A. It is from a memo pad, from Mr. Epstein's memo 18 THE WITNESS: That she had been contacted 19 pad. It's a sheet. 19 prior to me by a private investigator and wanted to 20 Q. Did you recover this document from a trash 20 know what she knew about the police investigation 21 pull that you did on Mr. Epstein's residence? 21 and wanted her to call the investigator after I 22 A. Yes. 22 would leave. 23 Q. There's a name that's redacted on there. Do 23 BY MS. ARBOUR: 24 you remember if that name was Jane Doe 4? 24 Q. Did she tell you who this supposed 25 A. Yes. 25 investigator worked for 31 (Pages 616 to 619) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricciuti (601 bdcd1876-c726-432dabilin666129f EFTA00298371 Page 620 Page 622 1 2 3 4 MR. PIKE: Form. BY MS. ARBOUR: Q. — that had called her? MR. PIKE: Same. 1 2 3 4 Q. What do you recognize this to be? A. This came from a trash pull what it says lane Doe 4 cannot come at 7:00 because of soccer. Q. And so the name that's redacted on there is I 5 THE WITNESS: I want to say Mr. Black's 5 Jane Doe 4? 6 office. 6 A. Yes. 7 BY MS. ARBOUR: 7 Q. Did you ever ask lane Doe 4 about this note? Q. Do you recall the name of the investigator she 8 A. No, I did not. 9 told you was trying to contact her? 9 Q. For the same reason you didn't ask her about 10 MR. PIKE: Form. 10 the other one? 11 THE WITNESS: I don't know. I can't recall. 11 A. Correct. 12 There were so many PIs. 12 Q. During the course of your investigation, did 13 BY MS. ARBOUR: 13 you uncover any other alleged victims who were named 14 Q. Dees the name Bill Reilly ring a boll? 14 Jane Doe 4? 15 A. Yes. 15 MR. PIKE: Form. 16 Q. Was he the investigator that M. said called 16 THE WITNESS: No, I did not. 17 him — or called her, sorry? 17 BY MS. ARBOUR: 18 A. I believe so, yes And they had met in an — 18 Q. Do you recall your interview with Jane Doe 2? 19 MR. PIKE: Form. 19 A. Yes. 20 THE WITNESS: — Applcbee's or like a 20 Q. And you testified about it in the previous 21 Chili's/Applebee's type restaurant. 21 deposition, so I want to ask you just a couple of 22 BY MS. ARBOUR: 22 followup questions about that. 23 Q. Did an,y of the other witnesses that you 23 How did you know to speak with Jane Doe 2? 24 interviewed indicate that Mr. Reilly had tried to 24 MR. PIKE: Form. 25 contact them? 25 THE WITNESS: Her name — 'think her name was Page 621 Page 623 1 MR.PIKE: Form. Form. It's hearsay, that's 1 given by her name was given by another *male, 2 alL 2 another of the witnesses. 3 MS. ARBOUR: You said form twice. 3 BY MS. ARBOUR: 4 MR. PIKE: Fm just making sure you're not 4 Q. Would it have been lane Doe 3 who told you her 5 beating me to the punch with another fast question. 5 name? 6 THE WITNESS: !Uteri had interviewed certain 6 MFL PIKE; Form. 7 people, I've gotten phone calls that the private 7 BY MS. ARBOUR: 8 investigator had shown up and asking them questions 8 Q. Do you recall? 9 similar to the questions I was asking. 9 A. I believe so. I'm not 100 percent certain, 10 BY MS. ARBOUR: 10 though. 11 Q. And of those phone calls that you've received, 11 Q. If it would be in the PCA, if you want to take 12 were those all after the grand jury indictment in the 12 a look, that's okay. I think she's page 18. 13 summer of 2006? 13 A. I believe so. 14 A. Prior. 14 Q. Is it your understanding that Jane Doe 2 was 15 Q. Prior to? Okay. 15 brought to Mr. Epstein's home prior to turning 18 in 16 And do you recall if Jane Doe 4 ever told you 16 order to provide him a massage? 17 that she had been contacted by Mr. Reilly? 17 A. Yes. 18 A. I can't recall if she did. 18 MR. PIKE: Form. 19 Q. Let me show you this one. Well mark this 31. 19 BY MS. ARBOUR: 20 (Deposition Exhibit No. 31 was marked for 20 Q. Did she tell you that during the course of a 21 identification.) 21 massage with Mr. Epstein, she was touched in a sexual 22 THE WITNESS: Yes, I remember that. 22 manner by Mr. Epstein? 23 BY MS. AREIOUR: 23 MR. PIKE Form. 24 Q. Have you seen this document before? 24 11W WITNESS: Yes. 25 A. Yes. 25 BY MS. ARBOUR: usaasiaLvar...iwniasa... • .•••••••••••••• 32 (Pages 620 to 623) PROSE COURT REPORTING AGENCY, INC. Electronically signed by ..leana Faceted (601 Electronically signed by Jeans Ricciuti (801 bdcd1876••c72o•432d 8cf0-blgae656129f EFTA00298372 Page 624 Page 626 1 Q. Did she tell you that Mr. Epstein asked her to 1 Q. You testified earlier that you turned over a 2 remove her pants and her shin during that massage and, 2 thumb drive to the FBI that had pictures of victims on 3 in fact, she did remove her pants and shirt? 3 it — 4 MR. PIKE: Form. 4 A. Correct 5 THE WITNESS: That she did, yes. 5 Q. — is that what you said? 6 BY MS. ARBOUR: 6 A. Correct. 7 Q. Did Jane Doe 2 tell you if Mr. Epstein removed 7 Q. Do you recall what girls were on that thumb 8 her bra and touched her breasts? 8 drive that you turned over? 9 MR. PIKE: Form. 9 A. The girls that were mentioned in the report. 10 THE WITNESS: I believe so. 10 I know I acquired yearbooks from the schools for what 11 BY MS. ARBOUR: 11 they looked like back then, compared to DL photos that 12 Q. Did she tell you that Mr. Epstein masturbated 12 we were able to save their image. Ofcourse I went onto 13 in front ofher? 13 my thumb drive... 14 MR. PIKE: Form. 14 Q. And now the FBI has that? 15 THE WITNESS: Yes. 15 A. Any and all information. 16 BY MS. ARBOUR: 16 Q. You said it was in the report, the girls would 17 Q. Did she toll you that Mr. Epstein touched her 17 be listed in the report. What report are you within!, 18 vaginal area? 18 to? 19 MR. PIKE: Form. 19 A. The incident report. 20 THE WITNESS: Yes. 20 Q. Do you recall if there wore any pictures of 21 BY MS. ARBOUR: 21 Jane Doe 2 on that thumb drive? 22 Q. Did she — is this the one you were referring 22 A. Yes, there was. 23 to earlier where she told you that ho put his fingers 23 Q. How about Jane Doe 4? 24 inside ofher vagina? 24 A. Yes, there was. 25 MR. PIKE: Form. 25 Q. How about Jane Doe 3? Page 623 Page 627 1 THE WITNESS: Yes. 1 A. Yes, there was. 2 BY MS. ARBOUR: 2 Q. How about Jane Doe?? 3 Q. Did she tell you that Mr. Epstein made any 3 A. Yes. 4 comments about her clitoris? 4 Q. How about a girl that we haven't discussed 5 MR. PIKE: Form. 5 named Jane Doe 5? 6 THE WITNESS: 1believe he mentioned how large 6 A. No. 7 it was. 7 Q. How about a girl named Jane Doe 6? 8 BY MS. ARBOUR: 8 A. No. 9 Q. Is it your understanding that from what Jane 9 Q. How about Jane Doe 8? 10 Doe 2 told you, that these events happened before 10 A. No. 11 Jane Doe 2 turned 18? 11 Q. At any time during your investigation, did you 12 MR. PIKE: Fenn. 12 speak to lane Doe 5? 13 14 THE WITNESS: Yes. BY MS. ARBOUR: 13 14 A. No. Q. Did you speak to a girl named Jane Doe 6? I 15 Q. Did Jane Doe 2 tell you she went there before 15 A. No. 16 she turned 18? 16 Q. Did you ever speak to a girl named Jane Doe 8? 17 MR. PIKE: Form. . 17 A. No. 18 THE WITNESS: Yes, she told me she was, I 18 Q. You were asked some questions earlier about a 19 believe, 16 years of age. 19 private investigator following you and pulling your 20 MR. PIKE: Can we take a quick break? 20 trash I believe you said. 21. MS. ARBOUR: I'm almost done. 21 A. Yes. 22 Just for the record, live got the most amount 22 Q. Can you tell me more about that? 23 ofplaintiffs and I've been the quickest. 23 MR. PIKES Form. 24 (A briefrecess was taken.) 24 THE WITNESS: Sometime during the 25 BY MS. ARBOUR: 25 investigation, it was discovered that we had 33 rages 624 to 627) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricciuti (601 bdcd1876 c72o 432d.8ctg.b19ac656129f EFTA00298373 Page 628 Page 630 1 private investigators following myself and former 1 September'05 to May 2006 time period? 2 • ChiefReiter. When I would leave work and I'd go 2 A. Yes. 3 visit my children, I would notice a car two lengths 3 Q. Did you ever speak with any of the other 4 behind 'no doing the exact same moves I did. If 4 witnesses who indicated to you that they believed they 5 sped up, he sped up; if I slowed down, he slowed 5 were being followed? 6 down. 6 A. Yes. 7 I purposely — purposely drove way under the 7 Q. What witnesses indicated they thought they 8 speed limit just to see if he would go around. No 8 were being followed? 9 cars around us and he stayed right behind me. 1 9 A. I received several phone calls from Jane Doe 10 11 made several U-Hints, he did the same exact thing. So it was clearly evident I was being followed. 10 11 103, indicating that she was — her neighbors were being talked to. People were going to her door representing 1 12 I did manage to obtain a driver's license 12 themselves to be a police officer at first and then 13 plate number and it carne back to a private 13 later identifying themselves as a private investigator. 14 investigator. 14 Q. And did that occur sometime in that same 15 I was actually called by one of the Pls, which 15 September'05 to May 2006 time period? 16 the phone number came back to the Law Office ofRoy 16 A. Correct. 17 Black in Miami. 17 Q. Did any other witnesses that you can recall 18 As far as my trash being pulled, it became 18 express similar concerns about being followed or being 19 clearly evident the day after Thanksgiving where 19 investigated? 20 there is no trash pickup in my neighborhood, at my 20 A. Yes. Jane Doe II. I had received several 21 house, the day after Thanksgiving, it's a holiday, 21 text messages and phone calls indicating similar, where 22 everybody's cans were full and mine is empty. 22 Pls were speaking to her friends, her family, previous 23 MIL PIKE: Form. Move to strike. 23 boyfriends and following her around. 24 BY MS. ARBOUR: 24 MR. PIKE: Fenn. 25 Q. Did you eves do any research to determine the 25 BY MS. ARBOUR: Page 629 Page 631 1 identity of the private investigators that you believed 1 Q. Did Jane Doe 7 ever express to you that she 2 were following you? 2 was worried she was being followed or investigated by a 3 A. Yes. I did obtain — based on their license 3 private investigator? 4 plate, l was able to obtain who they were and which PI 4 MR. PIKE: Form. 5 firm they represent. 5 THE WITNESS: Not that I can recall. 6 Q. Did you ever speak to any -- 6 BY MS. ARBOUR: 7 MR. PIKE: Same objection. 7 Q. How about Jane Doe 3? 8 BY MS. ARBOUR: 8 MR. PIKE: Form. . 9 Q. Did you ever speak to any representatives of 9 THE WITNESS: Not that I can recall. 10 thatPI firm? 10 BY MS. ARBOUR: 11 A. No. 11 Q. How about Jane Doe 4, did she ever indicate Iti 12 Q. Do you have any information about who, if 12 you that she was worried that she was being followed t 13 anyone, hired them to follow you? 13 investigated? 14 A. Aside from that one phone call that came back 14 MR. PIKE: Form. 15 to Roy Black's office. 15 THE WITNESS: Not that I can recall. 16 Q. And that was the investigators calling you or 16 MS. ARBOUR: I think that's all I have. 17 you were calling the investigators? 17 CROSS (DETECTIVE JOE RECAREY) 18 A. No. They actually called me by mistake. 18 BY MR. GARCIA: 19 Q. Okay. So you didn't actually speak to anyone? 19 Q. Just a couple ofquestions. Jane Doe II, you 20 A. No. They asked me who I was, and I said who 20 just mentioned her, how many phone calls or how many 21 are you, and they hung up. I had the number on my 21 conversations did you have with her? 22 caller ID. I cross referenced the phone number and it 22 A. Probably less than a handful. 23 came back to it. 23 Q. By phone or in person or — 24 Q. And to the best of your recollection, all of 24 A. By phone. 25 this occurred sometime in that September to May 2006 -- 25 Q. And how did you meet Jane Doe II? 34 (Pages 628 to 631) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Rlcciuti (801 bdcd1876•c72o•432c1.8c10-b19ae6561291 EFTA00298374 Page 632 Page 634 A. Actually, she came to the police station and 1 already -- the discussion was occurring already with the 2 spoke with Detective Dawson once there was information 2 FBI, and there was original talk in the very beginning 3 pertaining to Mr. Epstein's arrest 3 with the State Attorney's office that they were going to 4 Q. After the arrest was made? 4 amend the charges, depending on the new victims that 5 A. Correct. 5 came forward and what they had to say. And then the 6 Q. Why was that assigned to Detective Dawson as 6 Feds came in and then... 7 opposed to yourself? 7 Q. And then that was that? 8 MR. PIKE: Fonn. 8 A. That was it. 9 THE WITNESS: I had taken a week vacation. 9 Q. Do you know a man named Charles or Gerald 10 BY MR. GARCIA: 10 Goldsmith? He ran for mayor or something. 11 Q. Was there any followup after Detective Dawson 11. A. Yeah, I know ofhim, but.. 12 spoke to her? 12 Q. You've never met him? 13 A. Yes, I did make telephone contact with her, to 13 A. I mean,11cnow who he is if I see him, but he 14 let her know that I had the case, and that I was going 14 doesn't — we don't speak or... 15 to be looking into the case further. When the FBI took . 15 Q. Did ChiefReiter ever tell you or confide in 16 all the information, I notified her and let her know 16 you or report to you that Mr. Goldsmith was seeking 17 that the FBI was going to be looking into this as well. 17 information about the investigation ofMr. Epstein? 18 And then it was clearly evident to me that it was just 18 A. He had mentioned that to me. 19 going to be the FBI looking into this, so... 19 Q. And what did he tell you about that? 20 Q. And now, was the -- Pm trying to just piece 20 A. That he had received basically an inquiry from 21 together the sequence. You said she came to you after 21 Goldsmith and basically to back off the investigation. 22 Epstein was arrested, correct? 22 Q. Do you recall when ChiefReiter reported this 23 A. Correct. 23 to you? 24 Q. Had the FBI already taken your files at that 24 A. No. 25 point? 25 MR. PIKE: Form. Page 633 Page 635 A. Negative. 1 BY MR. GARCIA: 2 Q. So there was an arrest. And the plea deal, 2 Q. Was there any issue about any donations that 3 was that struck shortly after the arrest? 3 Mr. Epstein had made to the Police Department? 4 A. The plea deal didn't get struck until further 4 A. You know, I heard he had made a donation and 5 down the road. 5 it was returned to him, but I don't know any of that 6 Q. But it was after the FBI took all your 6 infonnation at all. 7 documents? 7 Q. Regarding the conversations that you had with 8 A. When she came in? 8 Jane Doe II, you said there were some text messages or 9 Q. No, in terms of the plea deal. 9 phone calls. Did you make any reports of those 10 A. Oh, yeah, it was after, way after. 10 conversations? 11 Q. And other — I have one statement that she 11 A. No, I did not The text messages was because 12 gave to detective — Pm sorry, Sergeant Dawson, 12 she was concerned that her family, her boyfriend were 13 apparently. It's dated — can you tell me what the date 13 being questioned by PIs, they were being told certain 14 of that report is? 14 things about the case, and she was concerned that it was 15 A. 7/28/06. 15 like a harassment type of thing. 16 Q. Do you know if there are any other reports 16 Q. Was she able to ascertain the names of the 17 that were taken of Jane Doe ll's involvement in this 17 investigators? 18 case from the Palm Beach Police Department? 18 A. I believe she did. I believe it was on the 19 A. Not that I'm aware of. 19 text message she sent me. 20 Q. That's the only one? Okay. 20 MR. GARCIA: Okay, that's alit have. 21 Did you ever present her information to the 21. MS. ARBOUR: Can I just ask one more? Is that 22 State Attorney's office for a criminal prosecution? 22 all right? 23 A. No. 23 RECROSS (DETECTIVE JOE RECAREY) 24 Q. Do you know why? 24 BY MS. ARBOUR: 25 A. Prior to me getting into the case, there was 25 Q. Detective, during the course of your 35 (Pages 632 to 635) PROSE COURT REPORTING AGENCY INC. Electronically signed by Jeana RIcclutl (601 Electronically signed by Jeana Rlcclutl (601 bdcd1876-c72o-432d-Bcf0-blilae656129f EFTA00298375 Page 636 Page 638 1 investigation, would you say that it was absolutely 1 Q. Did she know that it was a federal crime to 2 critical that you knew the amount of limes a girl went 2 solicit tmderaged women for prostitution? 3 to Mr. Epstein's house? 3 MR. PIKE: Form. 4 MR. PIKE: Form. 4 BY MR. GARCIA: 5 THE WITNESS: Would I say it was critical? 1 5 Q. Or did she appear to know that? 6 wanted to know if it was once or twice, more than 6 MR. PIKE: Same. 7 10, more than 15, more than 20. 7 THE WITNESS: I have no idea. 8 BY MS. ARBOUR: 8 MR. GARCIA: All right Thanks. 9 Q. Would it be fair to say it was more important MR. PIKE: Any followup? Okay. 10 to you, during the course of your investigation, to get 10 MS. O'CONNER: So we're concluded, right? 11 a general sense of what happened and approximately how 11 MR. PIKE: We are concluded. 12 many times it happened rather than an exact number of 12 MS. O'CONNER: We're going to read. 13 times? 13 14 A. Correct. 14 15 MS. ARBOUR: That's all I have. 15 (Witness excused.) 16 RECROSS (DETECTIVE JOE RECAREY) 16 (Deposition was concluded.) 17 BY MR. GARCIA: 17 18 Q. I'm sorry, I forgot to ask you something. The 18 19 Assistant State Attorney that you were working with on 19 20 this case -- 20 21 A. Yes. 21 22 Q. -- I keep forgetting her name. What's her 22 23 name a.? 23 24 A. 24 25 Q. Now, is she an attorney who tried a lot of 25 Page 637 Page 639 1 cases for the State Attorney's office or did she work 1 CERTIFICATE OF OA114 2 more in the intake section of the State Attorney's 2 THE STATI3OF FLORIDA 3 office, if you know? 3 cowry OF PALMBEAM 4 4 A. I don't know exactly how many times she's been 5 5 to tried, but --1couldn't tell you. 6 1, the undersigned authority, certify that 6 Q. And did she make the presentation to the grand 7 DE,7BCFIVE 1OE RECAREY personally appeared below int tn.! 7 :WY? 8 was duly swan on the 27th day of April, 2010. 8 A. Yes. 9 Q. By herself? 10 Dated this 27th day of April, 2010. 10 A. Yes. 11 11 Q. Did you ever participate in any cases where 12 12 she was the trial attorney for the State Attorney's 13 14 13 office? 1 C 14 A. No. No, I did not. 15 15 Q. And did she explain to you why she thought hams Ricciuti, RPR, 1TR, Cllr" 16 that these minor girls who were lured, in exchange for 16 Notary Public- Star ofFlorida 17 compensation to perform sex acts on Mr. Epstein, were My Commission Expires: 2/172013 18 not victims in her mind? 17 My CommissionNo.: DD 854778 19 MR. WEINBERG: Form. 18 20 THE WITNESS: Based on the MySpace pages that 19 21 20 she viewed, she had mate that determination. 21 22 BY MR. GARCIA: 22 23 Q. Just based on that? 23 24 A. That was my — that's what she basically told 24 25 me. 25 s 36 (Pages 636 to 639) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ftleclud (601 Electronically signed by Jeana Rleelutl (601 bded1876 c72o.432d•8ef0-b19ae6561291 EFTA00298376 Page Bd Page 642 1 CERTIFICATE 1 CERTIFICATE 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 2 4 3 THE STATE OF FLORIDA 5 Llama Ricciuti, Rq3istcrcd Professional Repeater and Notary Public in and for the State of 4 COUNTY OF PALM BEACH 6 Makin at lame, do hereby ecetiy that I was 5 I hereby certify that I have read the authoi mai to and did report staid deposition in 7 stenotype. and that the fon-vain pages ore a true and 6 foregoing deposition by me given, and that the correct trainer:Sion of my shorthand notes of said 7 statements contained herein are true and correct to the 8 deposition. 8 best of my knowledge and belief, with the exception of 9 I further comfy that said deposition wri taken at the time and place hereinabon act forth and 9 any corrections or notations made on the errata sheet, 10 thee the taking of said deposition was canoe cord and 10 if one was executed. completed as hereinabovc set out 11. 11 I Rather certify that I ant not an attorney or 12 Dated this day of 12 counsel arty of the partia, not ant I a relative or employee of any atUrney cr counsel of party connected 13 2010. 13 nith the action, nor am I fituincially irterated in the 14 Mien. 15 14 The romping certification of this tronsuipt 16 15 does not apply to any reproduction ofthe same by any 17 means unless under the direct control taid/or direction 16 of the certifying reporter. 18 17 Dated tins I 1th day of May, 2010. 19 DEFECTIVE JOE RECAREY 18 19 20 20 21. 21 C... 451:2 0t 41 22 gonna Rieciuti, EPP, CLR 22 23 23 24 24 25 25 Page 641 Page 643 1 DATE: May11.2010 1 ERRATA SHEET 2 TR DEfECTIVE10ERECAREY 2 INRE JANE00B2 v. EPSIE114 CR: NANA RICOUIT doJoann:1A Orator Esquire 3 DEPOSITION OP: DEFECIIVEJOERECAREY 3 JONES, Bus I tit, JOHNSTON At STUBBS 4 TAKEN: Apnl 27. 2010 505 Sooth Hagler Ent. Suite 1100 5 DO mar von cennansaurr -Dust CHANGES HERE 4 West Palm Beach. Florida 33401 6 PAGES W181 CHANGE REASON 5 IN RE: lane Doe 2 v. Pprtein 6 Ham take notice that on Tuesday, the 27th 7 of Apil, 2010, yea pot your depoition in the olison cla nal pastel. AT that now, you did out went 8 siimattec. It is now non:trythat you sip your 8 rlopinition 9 As deviously speed to the tneseript will 9 be finished to you through Emo ccwnd Plane read the following instnictices earthily: 10 10 At the and affix transcript you %nil Rod an coatis shed. As you read your demcwoon: eny (lunges II 11 or conections Ihrt you oish to coke shoil4 be noted on 1hµ al du Steel, citing Luba am1 line :Amax/ or um 12 12 change. DONUT write M ILK illinalF4 Olt: Once you bee mad the oniony end WWI nay changes, be 13 11 due to sign and date the dram Ad/ and mum these pones to nte. 14 14 If wet do ad mad end acei the &Porn, within a tenonatik time , days unless aliay.ise 15 15 directed) the cuirthal, %Ain has already beat forwarded to the ordering attorney, may be filed nth the Oak of 16 16 the Coon. If yru wish to waiw yow sitarist, aim 17 Please thorns(' tic miginfl sided 011111 aka to this your come in the Nankai the bittern of this hoer rid office so dot copes may be donihred to all panics. 17 retro it tons. 18 18 Very may yours, Utak: penalty of perjury, I declare that I hem read my 19 Scam Ricciati, RPR IPA CLR :9 deposition and Poi it es tor and coned subject to PRIM 001111 Reporting Amoy.In. any damps in form or substheve atered bac. 20 250 S. Auslralin Avenue, Ste 1500 20 Wert Palm Reath, Florida 33401 21 21 DATEt 22 I do botchy waive my *entre 22 23 23 SIONATUREOF DEPONEWP 24 DU tut WE ICERECAREY 24 25 25 37 (Pages 640 to 64 ) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Riccluti (601 Electronically signed by Jeana Ricciutl (601 bdcd1876-c720-437d-800-619nc6561791 EFTA00298377