EFTA00726182.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 10-80309 JANE DOE NO. 103 Plaintiff, vs. JEFFREY EPSTEIN, Defendant. RE-NOTICE OF TAKING DEPOSITION DUCES TECUM (As to Location ONLY) PLEASE TAKE NOTICE that at the below listed time and place the Plaintiff, JANE DOE NO. 103, by and through undersigned counsel, will take the depositions of: NAME OF DEPONENT Detective Joseph Recary do Joanne M. O'Conner, Esq. Jones, Foster, Stubbs, P.A. 505 South Flagler Drive, # 1100 West Palm Beach, FL 33401 DATE AND TIME Tuesday April 27, 2010 10:00 a.m. PLACE OF DEPOSITION Joanne M. O'Connor Esq. Jones, Foster, & Stubbs, P.A. 505 South Flagler Drive Suite 1100 West Palm Beach, FL 33401 upon oral examination before PROSE COURT REPORTING, a Notary Public, or any other notary public or officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. This deposition is being taken for the purpose of Podhurst Orsecls, P.A. 25 West Flagler Street. Suite 800, Miami, FL 33130, MIMI 305 358.2900 Fax 305.3582382 • Fort Lauderdale 954.4634346 1 www.podluustorn EFTA00726182 CASE NO.: 10-80309 discovery, for use at trial, or for such other purposes as are permitted under the rules of Court. The deponent is further directed to bring with him or her to the deposition documents described in Exhibit "A" attached. DATED this 19th day of April, 2010. Respectfully submitted, PODHURST ORSECK, P.A. Attorneys for Plaintiff Jane Doe No. 103 By: C.Jo66fsberg Fla. Bar No. 040856 Katherine W. Ezell Fla. Bar No. 114771 City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: Facsimile: ( - 2 - Podhurst Orsedc, P.A. 25 West Flagler Street. Suite 800, ?Aunt FL 33130, Muni X6358.2800 Fax 305.35&2382 • Fort Lauderdale 951.463A316 I www.podhurst.caus EFTA00726183 CASE NO.: 10-80309 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this 19th day of April, 2010, a copy of the foregoing was served this day on all counsel of record on the attached Service List via e-mail transmission. Respectfully submitted, PODHURST ORSECK, P.A. Attorneys for Plaintifflane Doe No. 103 By: C. J6§efsberg Fla. Bar No. 040856 Fla. Bar No. 114771 City National Bank Building 25 W. Flagler Street, Suite 800 Miami, FL 33130 Telephone: (305) 358-2800 Facsimile: (305) 358-2382 - 3 - Podhurst Orseck, 25 West Meer Street. Suite 800, Miami. FL 33130, Miami 386358.2800 Fax 305.3562382 • Fat Lauderdale 954463.4346 www.podIstust.com EFTA00726184 CASE NO.: 10-80309 SERVICE LIST JANE DOE NO. 103 v. JEFFREY EPSTEIN Case No.: 10-80309 United States District Court, Southern District of Florida Critton, Esq. Michael 3. Pike, Esq. Burman, Critton, Luttier & Coleman LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 Phone: (561) 842-2820/Fax: (561) 515-3148 ounse e ant, Jerey Epstein Jack Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300/Fax: (561) 835-8691 Co-Counsel for Defendant, Jeffrey Epstein Bruce E. Reinhart, Esq. Bruce E. Reinhart, P.A. 250 South Australian Avenue, Suite 1400 West Palm Beach, FL 33401 Phone: 561 202-6360/Fax: (561) 828-0983 ounse or o- e en ant, Adam Horowitz, Esq. Stuart Mermelstein, Esq. Mennelstein & Horowitz, P,A. 18205 Biscayne Blvd., Suite 2218 Miami, FL 33160 Phone: (305) 931-2200/Fax: (305) 931-0877 - 4 - Podhurst Orseck, P.A. 25 West Hagler Street Suite 800, Miami, Ft 33130, Miami 3053582800 Fax 3053582382 • Fort Lauderdale 95{463.4346 www.podhurst.com EFTA00726185 CASE NO.: 10-80309 Counsel for Plain:lb in Related Cases Nos. 08-80069, 08-80119,08-80232, 08-80380 08-80381, 08-80993,08-80994 Spencer Todd Kuvin, Esq. Theodore Jon Leopold, Esq. Leopold Kuvin, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 61) 515-1401 Counsel for Plaintiff in Related Case No. 0848804 Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820/Fax: (954) 524-2822 Counsel for Plaintiff in Related Case No. 08-80893 Isidro Manuel M, Esq. Elkins & Boehringer 224 Datura Avenue, Suite 900 West Palm Beach, FL 33401 Phone: (561) 832-8033/Fax: (561) 832-7137 Counsel for Plaintiff in Related Case No. 0840469 - 5 - Podhurst Orseck, P.A. 25 West Hagler Street, Suite 800, Miami, FL 33150, Miami 305.358.1300 Fax 305-3582382 • Fort Lauderdale 954463.4346 www.podlutrd.cOm EFTA00726186 WONT "A" 1. Any and all written reports, notes, memoranda or other papers authored by ygn or any other member of the Palm Beach Police Department, whether in hard-copy or electronic form, that relate to any law enforcement investigation of Jeffrey Epstein including but not limited to the investigation that resulted in the filing of State criminal charges against Mr. Epstein. This request includes any written communications between mend any members of the Palm Beach Police Department, any member of any Federal Law Enforcement Agency, any member of the Unites States Attorney's Office, any member of the Office of the State Attorney, any representatives of the media, any civil parties, any civilian witnesses and/or any lawyers or representatives of any parents of any civilian witnesses. 2. Any and all electronic communications (EMAIL) between inn any of the following relating to any law enforcement investigation of Jeffrey Epstein including but not limited to the investigation that resulted in the filing of State criminal charges against him: (A) any member of the Palm Beach Police Department, (B) any member of any Federal Law Enforcement Agency, (C) any member of the Untied States Attorney's Office, (D) any member of the Office of the State Attorney (B) any member of any print, television, or radio media outlet, (F) any attorney representing any civilian witness or civil party who has filed or may potentially file a civil complaint against Mr. Epstein. 3. Any and all notes, memoranda or reports reflecting any communications between you and counsel on behalf of Mr. Epstein, including but not limited fo any request for. exculpatory evidence. 4. Any and all notes, memoranda or reports reflecting any attempts by you to initiate or encourage a federal review of any facet/aspect of the Epstein investigation or State prosecution of Epstein. 5. Any and all notes, memoranda or reports reflecting any complaints made to the Palm Beach Police Department from any person, parent, or lawyer for any person or parent claiming to have been a victim of any conduct of Mr. Epstein or from any other private citizen of Palm Beach County retailing to any conduct of Epstein from January 1, 2000 — October 22, 2009., • 6. Any and all notes, memoranda, or reports reflecting any communication between You or and any other member of the Palm Beach Police Department with "AB:* in relation to her being subpoenaed to testify before or her requested attendance before a State Grand Jury, including but not limited to any discussions regarding what she would testify to and/or any preparation that any law enforcement officer provided her with prior to any testimony. 7. Any and all notes, memoranda, or reports reflecting any communication between you or any other member of the Palm Beach Police Department with "Ali." or referencing "AIL" in relation to her being subpoenaed to testify before or hex requested attendance before a State Grand Jury where y_ or any Palm Beach police officer or official sought to discourage her or influence her not to testify or to testify in a certain manner at any Grand Jury proceeding involving Mr. Epstein. EFTA00726187 8. Any and all agreements, memoranda, and/or notes of any kind, electronic or otherwise, between mond any member of the Palm B each Police Department, any member of the Office of the State Attorney, and/or any member of the United States Attorney's Office relating to any criminal charges, formal or otherwise, regarding "A.H." at any time. 9., y and all notes, memoranda, or reports of ineetbas or communications between nu and mg-I% her parents, or any lawyers who represent 'ire 10. Any and all records of expenditures made or incurred by xi.% and all requests for expenditures relating to the criminal investigation of Mr. Epstein. 11. Any and all logs, pictures, videos, digital information, reports, memoranda or notes, and any record of expenditure, which relate to the institution of and/or maintenance of any video surveillance of Mr. Epstein, his residence, or his visitors during the following time periods: a. January 1, 2004-December 31, 2004 b. January I, 2005-December 31, 2005 c. January 1, 2006-December 31, 2006 d. January 1, 2007-December 31, 2007 e. January 1, 2008-December 31, 2008 f. January 1, 2009-today's date. 12. Any and all reports, logs, pictures, videos, notes, records of expenditures or any other memoranda relating to any physical surveillance of Mr. Epstein, his residence, his visitors, or any individual who was believed to be a potential witnesses or co-conspirator other than the information relating to video surveillance that is requested in request number 11. 13. Any and all reports (including forensic reports), memoranda, notes, and reports of any examination of any computer seized from Mr. Epstein's residence in October 2005 or on any other occasion. 14. Any and all reports; memoranda, or notes reflecting a criminal theft or burglary investigation of Mr. Epstein or his residence on any occasion prior to October 2005. 15. All cell phone records, both official cell phone and personal cell phone, used by you between during the folloWing time periods: a January 1, 2004 December 31, 2004 b. January 1, 2005-December 31, 2005 c. Jemmy 1, 2006-December 31, 2006 d. January 1, 2007-Deoeenbesr 31, 2007 e. January 1, 2008-December 31, 2008 f. January 1, 2009-today's date. 16. All calendars or diaries, electronic or hard-copy, kept for the periods between October 1, 2004 up through and including today, reflecting your schedules, activities, meeting, etc, EFTA00726188 17. Any and all reports, memoranda, and notes of any communication between att and any member of the Office of the State Attorney relating to the criminal investigation and subsequent prosecution of Mr. Epstein from October 1, 2004 up through and including today. 18. AU policies and procedures of the Palm Beach Police Department setting forth the procedures for police officers, including the Chief, any detective and officers when commenting to any media outlets, including but not to the local news, the national media, print outlets, and any web-based media format. 19. All personal notes contained either on your personal computer, work computer, and those that are handy/nth:a containing any witnesses that ym or any other member of the Palm Beach Police Department interviewed or attempted to interview with regard to the Epstein investigation from January I, 2004, up thorough and including today. 20. Any and all audio tapes of any witnesses that ygg or any member of the Palm Beach Police Department obtained statements or interviews from, either man. or informal, with regard to the Epstein investigation. 21. Any and all audio tapes, notes (hand-written or typed), memoranda, reports, messages,. and/or any communications obtained or generated by vs or any member of the Palm Beach Police Department, either sworn or informal, that relate to Jane Doe #4**, who is the Plaintiff in a Federal Civil Case No. 08.80380 filed against Jeffrey Epstein. * The initials A.11. and S.R. refer to the individuals identified in the Palm Beach County Probable Cause Affidavit as it relates to the Jeffrey Epstein investigation. Should you require the complete name of the individuals, please contact Jessica Cadwell at ** Should you need the full identity of Jane Doe #4, please contact Jessica Cadwell MIN IMMES EFTA00726189