EFTA00298293.pdf

Page 130 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME II OF II Related cases: 08-80232, 08-08380, 08-80381, 08-80994 08-80993, 08-80811, 08-80893, 09-80469 09-80591, 09-80656, 09-80802, 09-81092 DEPOSITION OF DETECTIVE JOSEPH RECAREY Friday, March 19, 2010 9:37 - 5:12 p.m. -250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1509 PROSE COURT REPORTING AGENCY, INC. au& Electronically signed by eynthla hopkins (601 Electronically signed by cynthia bodkins (601 Electronically signed by cynthia hopkins (601 ea2stiddbfaB1-4f16-b3b7deda51494142 EFTA00298293 EFTA00298294 17 18 19 20 21 22 2 3 Page IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.502038CA0373I9/000CMB AB 131 B.B. 4 Plaintiff S 6 -vs- VOLUMBIIOFII 7 jA121.11 8 Defendants. 9 10 11 12 DEPOSITION OF DETECTIVE JOSEPH RECAREY 13 14 Friday, March 19, 2010 15 9:37 - 5:12 p.m. 16 250 Australian Avenue South Suite 1500 17 West Palm Beach, Florida33401 18 19 20 21 22 Reported By. Cynthia Hopkins, RPR, FPR 23 Notary Public, State of Florida Prose Court Reporting 24 Job No.: 1509 25 Page 132 2 UNITED STATES DISTRICT COURT SOUITIIRN DISTRICT OF FLORIDA 3 CASE NO. 10.80309 4 5 JANE DOE NO. 103, 6 Plabtiff, 7 -vs- VOLUME II OF II 8 JEFFREY EPSTEIN, 9 Defendant. 10 11 12 DEPOSITION OF DETECTIVE JOSEPH RECAREY 13 14 Friday, March 19, 2010 IS 9-37 - 5:12 pm. 16 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR 23 Notary Public, State of Florida Prose Court Reporting 24 Mb No.: 1509 25 t APPEARANCES 2 On bead( cflbe Plaintiffs, B3.CL 3 SPENCER T. KUM!. ESQUIRE LEOPOLD KUVIN 4 2925 PGA Bodevard Suite 200 5 Pam flaida 33410 Phone. 7 On behalf et the Pin:dirk Ltd E.W and Jane Doe: 6 15 16 17 18 19 20 KAI/691M W EZELL, ESQUIRE PODHURST ORSEOC 21 25 Wen Hagler Street SAC 800 22 Moe: 23 (Via one) 24 25 9 BRADLEY J. EDWARDS, ESQUIRE FARMER, JAFFE, WEISSING, EDWARDS 10 FISTOS & LEHRMAN, P.L. 425 Rath Anikens Avenue 11 Stile 2 1 2 Fat 33301 Maw 13 On behalf ace a I Drench 8. 14 JESSICA ARDOUR. ESQUIRE MERMELS1131N k HOROW112., P.A. 16205 Biscayne Boulevard Suite 2218 Miami, 3 60 nom &mad Onbelsalf, t e 3Ulli..S s , and 103. Page 133 1 Appearances oonimued 2 On behalf of the FlairditT, Ina Doe No.11: 3 IDDRO MANUEl. °ARM, ESQUIRE GARCIA ELKINS& BOEHRINCER 4 224 Diva Ann, Sale 900 Wen PUS& 33401 5 Phe 6 and 7 TARA A FDDILGAN, ESQUIRE TARA A MINICAR. P A 8 224 Dina Street Suite 900 9 West tide 3340! Mae: 10 1/. Cte tehalfof the Defendant inlay Epstein: 12 MICHAEL PIKE, ESQUIRE BURMAN, ORITTON, LUIT1ER & COLEMAN, U.1) 13 303 Barn Bouienad Suite 4t0 14 West tads. 33401 Phone- 15 16 and 17 AO; ALAN GOUAERGER, ESQUIRE ATTERBURY, GOLDBERGER & WELSS, PA 10 250 Attu Wine Avenue Sash Suite 1400 19 west P • 'dm 334014012 Phan' 20 21 and 22 lifiLTON G. wrgramo. ESQUIRE LAW OFFICE OF MILTON 0. WEIMER° 20 Pat Plaza Sine I COO, Boston. 02116 Phone 23 24 25 2 (Pages 131 to 134) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 na2a6ddb.fa81-41f6-b3b7-deda61494142 EFTA00298295 15 16 17 18 19 29 • 21 22 23 24 25 5 6 7 8. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Page 135 Appearances continued... 2 On behalf of the Witness: 3 JOANNE M. O'CONNOR. ESQUIRE JONES, }vs eft, JOHNSON & STUBBS, P.A. 4 505 South Elegies Drive, Suite 1100 West Nitride 33401 Phone: Also Present: Jeffrey Epstein INDEX EXAMINATION DIRECT CROSS REDIRECT CONTINUED EXAMINATION BY het ICUVIN 134 BY MR. EDWARDS 243 • EXHIBITS EXHIBIT DESCRIPTION PAGE PLARTI1FF'S EX. S SUPPLEMENT FOR CHAIN 151 OF CUSTODY LOG 24 PLAINTIFFS EX. 6 PAGE FROM MESSAGE PAD 196 PLAINTIFFS EX. 7 PHONE MESSAGE 204 25 3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 137 g CONTINUED DIRECT EXAMINATION BY MR. KUVIN: Q. All right. We were going over the property receipts for the search warrant when we left off. And specifically we were at Page 2. We were looking at some of the things that you took in. Each item that you took dining the search warrant was numbered; is that correct? A. Correct MR. PIKE: Foram. BY MR. KUVIN: Q. And the item number appears where? MR. PIKE: Form. THE WITNESS: Under item number. BY MR. KUVIN: Q. All right And this is a standard form wed by the police department? A. That's correct. MR. PIKE: Fonm BY MR. KUVIN: Q. All right If we look at Item Number 24, what MS that? MR. PIKE: Form. THE WITNESS: It was a twin torpedo in a brown box. 2 3 4 EXHIBITS CCeITINUED MONT DESCRIPTION PAGE PLANETS EX S PHONE MESSAGE 205 PLAINTIFFS Ex 9 PHONE MESSAGE 208 $ PLAINTIFFS EC 10 PHONE MESSAGE 209 PLAINTIFFS EC 11 PHONE MESSAGE 211 6 PLAINTIFFS EX 12 PHONE MESSAGE 212 PLAINTIFFS EX 13 PHONE MESSAGE 213 7 PLAINTIFF'S EX 14 PHONE MESSAGE 215 PLA/NIIFF'S EC 15 PHONE MESSAGE 215 8 FIAINTIFFS EC 16 PHONE MESSAGE 217' PLAINTIFFS EX 17 PHONE MESSAGE 219 9 PLAINTIFFS EX IS PHONE MESSAGE 220 PLAINTIFFS EC. I9 PHONE MESSAGE 221 10 PLAINTIFFS DC 20 PHONE MESSAGE 222 PLAINTIFFS DC 21 PHONE MESSAGE 223 11, PLAINTIFFS EC 22 PHONE MESSAGE 22$ PLAINTIFFS DC. 23 AND 24 PHOTOS 227 12 PLAINTIFFS EX. 2$ PHo GE 230 PLABTTIFFSFX. 26MS. 240 13 CELLINIONE LOG PLAINTIFF'S EC 27 LETTER DATED JULY 24, 241 14 2006 PLAINTIFFS DC 28 INTELLIGENCE REPORT 243 DATED maw 01.1•1•11W*1 CFA, Page 136 PROSE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 COURT REPORTING Page 138 1 BY MR. KUVIN: 2 Q. What is that? 3 MR. PIKE: Form. 4 THE WITNESS: It is a synthetic penis, 5 double, double sided. 6 BY MR. KUVIN: 7 Q. Okay. Double sided meaning it has, what, 8 two heads on it? 9 A. Yes. MR. PIKE: Fonm. BY MR. KUVIN: Q. How big is this? A. About 12 inches, 10, 12 inches. MR. PIKE: Objection to the form of that question. BY MR KUVIN: Q. Do you know where it was taken from? MR. PIKE: Form. THE WITNESS: It was in one of the bedrooms. BY MR. KUVIN: Q. Do you know if any DNA analysis was done on that? MR. PIKE: Form. THEE WITNESS: Not that I am aware of. r.), 1,1 .f7 3 (Pages 135 to 138 AGENCY, INC. Electronically signed by cynthla hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2Mddb-fal31-4116-b3b7-dcda51494142 EFTA00298296 Page 139 1 (Mr. Epstein returned the deposition 2 mom.) 3 BY MR. KUVIN: 4 Q. All right. Let's take a look at the next 5 page. Item 27, what was that? 6 A. It was a high school transcript — 7 MR. PIKE: Form. 8 THE WITNESS: that was located in the 9 master bedroom. 10 ' BY MR. KUVIN: 11 Q. Appears to be something blacked out. What 12 is blacked out? 13' . A. The name of Jane Doe No. 103. 14 MR. PIKE: Form. 15 BY MR. KUVIN: 16 Q. Okay. Did you actually see this? 17 A. Yes, I did. 18 Q. And can you describe for me what it was? 19 MR. PIKE: Form. 20 THE WITNE • was h hi school 21 transcript from High School. 22 BY MR. KUVIN: . . 23 Q. Now, it says "VALUE not" What does that • 24. mean? 25 MR. PIKE: Form. Page 141 1 THE WITNESS: I believe so. MR. PIKE: Move to strike. BY MR. !MIN: 4 . Q. Where in the house was this transcript 5 kelt 6 MR. PIKE: Form. 7 THE WITNESS: In the desk, the desk drawer 8 of the — there was a desk in the master 9 bedroom. 10 BY MR. KUVIN: 11 Q. Okay; So, in the master bedroom? 12 MR. PUCE: Form. 13 THE WITNESS: Yes, sir. 14 BY MR. KUVIN: 15 Q. Was there an office downstairs as well? 16 A. Yes. 17 Q. It was not found in the office? 18 MR. PIKE: Form. 19 THE WITNESS: No.. 20 BY MR. KUVIN: 21. . Q. The next thing, Item 28, what was that? 22. A. That was a bottle of Joy Jelly. 23 Q Did you determine what that is? 24 MR. PIKE: Form. 25 THE WITNESS: It's a lubricant 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18. 19. 20 21'. 22 23 24 25 Page 140 THE WITNESS: That was written by Greg Parkinson, our crime scene manager, who was filling the form as to, when we identified the object we wanted to take, you would put it on . the property receipt BY MR. KUVIN: Q. Okay. With respect to this particular transcript, was this taken by the FBI when they took' all the evidence? A. Yes. MR. PIKE: Form. BY MR. KUVIN: Q. Did you ever determine why her high school transcript was found in Mr. Epstein's home? MR. PIKE: Form. ME WITNESS: During my interview with' , : het, she claimed that Mr. Epstein had said that he was going to help her get into a good • college and when she graduated to give him a copy of the transcript to assist her in getting into a college. BY MR. KUVIN: Q. Did the high school transcript show her date of birth? MR. PIKE: Form. Page 142 1 MR. KUVIN: Sexual lubricant? 2 MR. PUCE: Form. •3 • THE WITNESS: That's correct 4 BY MR. KUVIN: 5 Q. Where was that found? 6 A. In the credenza in the master bedroom. 7 MR. PIKE Form. 8 BY MR. KUVIN: 9 Q. Item 29 appears to be a bunch of 10 videotapes? 11 A. Yes. 12 Q. There is one there called "I Love Lesbians 13 Four." Do you see that? 14 A. Yes. 15 Q. Where was that found? 16 MR. PUCE: Form. 17 THE WITNESS: The master bedroom. 18 BY MR. KUVIN: 19 Q. Did you find massage tables during the 20 search of the home? 21 MR. PIKE: Form. . 22 THE. WITNESS: Yes, we did. We found a 23 couple of massage tables. 24 BY MR. KUVIN: 25 Eyhere? (561) 832-7500 832-7500 PROSE COURT REPORTING 4 (Pages 139 to 142) AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by Cynthia hopkins (601 Electronically signed by cynthia hopkins (601 ea2a6ddb-fa81.4lf6•b3b7•dcda51494142 EFTA00298297 Page 143 MR. PIKE: Form. THE WITNESS: One was in the master 3 bedroom area. There was another one found in 4 another bedroom area. There were different colors. There was like a green one, a white one, a peach one but -- 7 BY MR. KUVIN: 8 Q. Okay. Did you, yourself, personally see 9 the massage tables in the home when you were-there 10. for the warrant? 11 MR. PIKE: Form. 12 THE WITNESS: That is correct. 13 BY MR. KUVIN: 14 Q. It appears that Item 34 was a number of 15 CD's? 16 A. Correct. 17 Q. Did you ever determine what was on them? 18 A. Everything was viewed, some of the CD's were 19 empty. But at the time we didn't know, we just had to 20 take it and view it. 21 Q. Items 34 through 40 on the list appears to 22 be a bunch of different medias such as ZIP CD's and 23 eight millimeter video, flash cards, ZIP CD's and 24 CD's. Did you view all those materials? 25 A. That is correct. Page 145 1 in any format that you felt was useful evidence for 2 Mr. Epstein's prosecution that was currently being 3 investigated? . 4 MR. PIKE: Form. ' 5 THE WITNESS: There was a CPU that was in 6. an office like the assistant's office. 7 MR. KUVIN: Okay. 8 THE WITNESS: That was not connected. It 9 was an Older CPU which was taken to the 10 Sheriffs Office for — to be analyzed. 11 MR. KUVIN: Okay. 12 THE WITNESS: They were able to retrieve 13 some images off that computer from that covert 14 camera in the living room, in that office 15 living room area. 16 BY MR. KUVIN: 17 Q. And what did those images show? 18 MR. PIKE: Form. 19. THE WITNESS: It showed Mr. Epstein 20 sitting at his desk. It was basically motion 21 activated. When there was motion, it would 22 start to record. So, there was, there were 23 images of Epstein at his desk. There was 24 images of his assistant with Mr. Epstein 25 sitting at the desk. There were images of what Page 144 1 MR. PIKE: Form. 2 BY MR. KUVIN: 3 Q. Was there anything on these materials that 4 are listed on here, 34 through 40, that showed any 5 girls that you determined to be underage? 6 MR. PIKE: Form. 7 THE WITNESS: Some of the items that we 8 took from the guesthouse area were determined 9 to be Janusz's, the houseman, live-in houseman, 10 items which was returned to him once we 11. determined that it was his. 12 BY MR. KUVIN: 13 Q. Okay. Anything else that you found on 14 there that you felt was of value for the prosecution 15 of Mr. Epstein? 16 MR. PIKE: Form. 17 BY MR. KUVIN: 18 Q. That you can recall. 19 MR PIKE: Same. 20 THE WITNESS: From the guesthouse? 21 BY MR. KUVIN: 22 Q. Well let me ask it this way, a little bit 23 broader: Based on the information that you 24 confiscated from the home during the warrant, search 25 warrant, did you find any cons uterized nf r 1. I believe to be 2 well. 3 Again, the lighting was poor so a, I 4 couldn't positively say 100 percent, okay, 5 that's so-and-so. I could say that was 6 Mr. Epstein because I have seen Mr. Epstein. I 7 know what he looks like. You know I can say the female did appear to be one 9 of the assistants appeared to be 10 You know, that kind of thing. 11 BY MR. KUVIN: 12 Q. All right. Did you see any other girls in 13 that video that was on the CPU? 14 MR. PIKE: Form. 15 THE WITNESS: There was someone else but 16 just can't recall who it was. 17 BY MR. KUVIN: 18 Q. Where is that CPU now if you knovfl 19 A. With the FBI. 20 Q. Was there any other digital information 21 that was seized that you were able to see that you 22 felt was helpful in any way to the investigation? 23 MR. PIKE: Form. 24 THE WITNESS: Not off the computer. Page 14. also shown as 5 (Pages 143 to 146) (561) 832-7500 PROSE COURT REPORTING'AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-fa81-4116-b3b7-dcda51494142 EFTA00298298 Page 147 Page 149 1 BY MR. KUVIN: 2 Q. What about on any of the CD's or 3 flashcards that were taken? 4 MR. PIKE: Form. 5 THE WITNESS: There was a video. It 6 appears to be, it appears to be in the private 7 island of Mr. Epstein when you see a helicopter 8 coming in, and there was some females there 9 dancing 10 BY MR KUVIN: 11 Q. Was this on a computer format like a CD or 12 a flash drive or — 13 A.. I believe it was an — 14 Q. — an eight millimeter? 15 A. I might have been an — 16 MR. PIKE: Form. 17 THE WITNESS: Eight millimeter. 18 BY MR. KUVIN: 19 Q. Okay. Any other media information that 20 you can recall after having reviewed all of the 21 things that you confiscated from the home that you 22 found was helpful in the investigation? 23 MR. PIKE: Form. 24 THE WITNESS: Not that I can recall. 25 1 BY MR. KUVIN: 2 Q. I want to come back to that fora minute. 3 How many CPU's did it appear to you were missing? 4 MR. PIKE: Form and speculation. 5 THE WITNESS: There was one missing from 6 the desk area in the living room with the power 7 cords — all the cords were there. The CPU was gone. 9 MR KUVIN: Okay. 10 THE WITNESS: There was one from the pool 11 house where the cords were there, the monitor 12 was there, the keyboard, the mouse. The CPU 13 was gone. I would say two. 14 BY MR. KUVIN: 15 Q. Okay. Did you ever come to team during 16 the investigation where those CPU units were? 17 MR. PIKE: Form. 18 THE WITNESS: I believe I was told that 19 those CPUs were actually sitting in an 20 attorneys safe. 21 BY MR. KUVIN: 22 Q. Okay. Did you come to learn that they, 23 that Guy Fronstin had actually taken possession of 24 those? Does that refresh your recollection at all, 25 or was it another attorney? Page 148 1 BY MR. KUVIN: 2 Q. Now, it appears that you confiscated as 3 part of the search warrant a number of CPUs and 4 their power cords; is that correct? 5 A. Yes. 6 MR. PIKE: Form. What page are you on? 7 MR. KUVIN: It looks like 43 and 44. 8 Items 43 and 44 are the first power cords and ' 9 CPU. Items 54 and 55 are the second power cord 10 and CPU. 11 BY MR. KUVIN: 12 Q Do you recall how many CPUs you took into 13 custody? 14 • A. We took a couple but obviously one of them 15 was positive that it belonged to Janusz because it had 16 all his personal stuff; his personal photographs of he 17 and his wife. So those were returned to him. 18 Q. Okay. 19 MR. PIKE: Form to that question. 20 BY MR. KUVIN: 21 Q You mentioned at the beginning when you 22 executed the search warrant that you felt in your 23. opinion the house had been sanitized because you 24 noticed things that appeared to be missing. 25 MR. PIKE: Form. Page 150 1 MR. PIKE: Forst 2 THE WITNESS: I was told it was Roy 3 Black's office that had them. 4 BY MR. KUVIN: 5 Q. Gotchat. All right. Let's keep going 6 here. Item 58 was another massage table that was 7 taken as evidence? 8 A. Correct. 9 MR_ PIKE: Form. 10 BY MR. KUVIN: 11 Q. You saw that massage table? 12 A. Yes, sir. 13 Q: Okay. La look at the next page, six of 14 six. It says a green photograph with a naked girl. 15 Do you recall where that was taken from? 16 A. That was taken out of the, I believe, master 17 bedroom. 18 MR. PIKE: Form. 19 BY MR. KUVIN: 20 ' Q. Could you tell by looking at the 21 photograph whether it was an underage girl? 22 MR. PIKE: Form. 23 BY MR. KUVIN: 24 Q. I mean, was it a young girl, a mature 25 girl, old? •••••••••••sts•n eV1---, 204aV vie lS4LS .o.,..., 6 (Pages 147 to 150 ) PROSE COURT REPORTING AGENCY,' INC. Electronically signed by cynthla hopkins (601 Electronically signed by eyntiga hopkins (601 Electronically signed by cynthla hopkins (601 aa2a6ddb-fal11-4116-b3b7-dcda61494142 EFTA00298299 2 3 4 5 .7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 151 A. No, it was a young girl. MR. PIKE: Same objection. THE WITNESS: Very young girl. BY MR. KUVIN: Q. Could you tell the age from the photo? MR. PIKE: Form. THE WITNESS: Younger than ten. BY MR. KUVIN: Q. Could you find any photographs of girls that were victims during the investigation? Did you find any photographs of girls that were victims during the investigation? MR. PIKE: FOUR THE WITNESS: There were photographs taken during the search warrant, topless females that were taken. But no, I did not locate one of the victims in the photos. MR. KUVIN: Okay. If we look at what we'll mark as Exhibit 5, appears to be a supplement of the chain of custody log. two pages. Make sure I have got it. Ifs three pages actually. (Plaintiffs Exhibit No. 5 was marked for identification.) 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 153 touched on this briefly in the beginning, but what happened with the investigation once you filed the probable cause affidavit and got the warrant? At what point did you turn it over to the State Attorney's Office? A. Once I filed the arrest warrant for Mr. Epstein, there were actually three warrant requests to be honest with you. There was a warrant raLmt for Je in, I want to say =, and Q. Okay. What happened with those arrest warrants for all three of them? MR. PIKE: Form. THE WITNESS: Once they were turned over to the State Attorney's office, I was notified several days later that they were going to be requesting a grand jury to listen to the case. BY MR. KUVIN: Q. Okay. And did a grand jury hear the case as far as you know? A. Eventually they did. Q. And do you know what occurred after the grand jury heard the case? MR. PIKE: Form. THE WITNESS: It was true bill. Page 152 1 BY MR. KUVIN: 2 Q. We have got what appears to be a four-page 3 document which happens to be called a chain of 4 custody. I just have a couple quick questions about 5 this. If you would look at the last entry in the 7 • chain of custody, I just wanted to coafum where all 8 the evidence went according to the documentation. 9 A. Everything went TOT, to the FBI. 10 Q. I am sorry, what were the initials? 11 A. TOT. 12 Q. What does that mean? 13 A. Given to the FBI. 14 Q Okay. So the chain of custody which we 15 have marked as Exhibit 5 shows that all the evidence 16 you had in this case was given over to the FBI; is 17 that correct? 18 MR. PIKE: Form. 19 THE WITNESS: The items that were returned 20 to Janusz were returned to Janusz (sic). The 21 items that were not returned were given to the 22 FBI. 23 BY MR. KUVIN: 24 Q. Okay. Great. All right. Ultimately what 25 happened with respect to the investigation, and I Page 154 1 BY MR. KUVIN: Against? 3 A. Mr. Epstein. 4 Q Just for people that may not know what a 5 true bill is, can you explain briefly what that 6 means? 7 A. Grand jury found sufficient evidence to charge 8 Mr. Epstein. 9 Q What was he charged with? 10 MR. PIKE: Form. THE WITNESS: I think it was, it was a 12 procurement for prosecution. 13 BY MR. KUVIN: ' . 14 Q. Have to do with minors? 15 A. Yes. 16 MR. PIKE: Form. 17 BY MR. KUVIN: 18 Q All right. After the execution of the 19 search warrant, your investigation continued; is 20 that correct? 21 A. Correct 22 Q. And during the investigation, did you have 23 occasion to speak with or meet with a gentleman by 24 the name of Juan Alessi? 25 A. Juan Alessi, yes. 7 (Pages 151 to 154) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddbifa81-4116-b3b7-dcda51494142 EFTA00298300 Page 155 Page 157 1 Q. Who was that? 2 A. He was the former houseman of Mr. Epstein. 3 MR. PIKE: Form. 4 BY MR. KUVIN: 5 Q. Did he give you information that you felt 6 was helpful in the prosecution of Mr. Epstein? 7 MR. PIKE: Form. 8 THE WITNESS: He described, he described 9 washing off the vibrator massagers after the 10 massage incidents. He recalled having young 11. girls coming in to do the massages. 12 BY MR. KUVIN: 13 Q. Did he mention that he, whether he 14 witnessed that? 15 MR. PIKE: Move to strike witness's last 16 statement pending hearsay and form. 17 Mr. Kuvin, next question if he has 18 completed it. 19 BY MR KUVIN: 20 Q. Did he mention whether or not he had 21 witnessed young girls coming to the house? 22 MR. PIKE: Same objection. 23 THE WITNESS: Yes. 24 BY MR. KUVIN: 25 Q. If we look back at the incident report 1 THE W/TNESS: No. 2 BY MR. KUVIN: 3 Q. Narrative 18, it looks like you matte 4 telephone contact with another white, looks like WF, 5 I assume it means white female, on November 8. Do 6 you recall which girl that may have been? 7 MR. PIKE: Form. 8 BY MR. KUVIN: 9 Q. Let me ask it this way: Was this a 10 recounting of the incident with Ms. Jane Doe No. 11 103? 12 A. No. 13 Q. This is a different girl? 14 A. Ibis is a different girl. 15 MR. PACE: Form to both questions. 16 THE WITNESS: This was a different girl 17 and I am trying to remember who it was. 18 BY MR. KUVIN: 19 Q. Do you recall the name M? 20 A. Yes. 21 Q. Is that who this was? 22 MR. PIKE: Form. 23 THE WITNESS: Yes, it was. 24 BY MR. KUVIN: 25 Q. Okay. And apparently she had reported Page 156 1 Page 47 — got it there — it looks like you made 2 contact, telephone contact with another girl on 3 November 7 of 2005, and took another taped 4 statement, sworn taped statement. Can you determine by looking at your swnmary there in Narrative 16 of 6 November 7,2005, which girl that was? 7 MR. PIKE: Form. 8 THE WITNESS: I believe that was■ 9 MR. KUVIN: 10 THE WITNESS: 1 1 BY MR. KUVIN: 12 Q. Do you recall wha.s state of mind or 13 emotional condition was when she spoke to you about 14 this event? 15 MR. PIKE: Form. 16 THE WITNESS: I can't recall. 17 BY MR. KUVIN: 18 Q. Let's take a look at Narrative 17. It 19 looks like you made contact with someone else, you 20 along with Detective Dawson made contact with 21 somebody and left a business card at the front door. 22 Do you see that? 23 A. Yes. Yes,' do see it. 24 Q. Do you recall which girl that was? 25 MR. PIKE: Form. 1 2 3 4 5 6 7 8 9. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 158 sexual intercourse with Mr. Epstein? A. That is correct. MR. PIKE: Form, leading. BY MR. KUVIN: Q. Did she report any sexual contact with Mr. Epstein? A. Yes, she did. Q. What type? MR. PIKE: Form. THE WI NESS: She was paid to have vaginal intercourse. MR. PIKE: Form, move to strike. BY MR. KUVIN: Q. Did you determine how old she was when she reported having this vaginal intercourse with Mr. Epstein? MR. PIKE: Form. THE WITNESS: Sixteen years of age. MR. PIKE: Spencer, can you hold on? MR. KUVIN: Yes, sir. MR. PIKE: Letts go off the record for a second. (A discussion was held off the record.) MS. EZELL: If I could interject, I was fumblin on mute and I wanted to move to strike ••••••••••••• 8 (Pages 155 to 158) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a6ddb•fa81-4ff6•b3b7-dcda51494142 EFTA00298301 Page 159 1 the witness's comment that she was paid to have 2 vaginal intercourse with Mr. Epstein. 3 MR. KUVIN: Okay. 4 BY MR. KUVIN: 5 Q. Do you recall the demeanor ofM when 6 she was recounting this for you? 7 MR. PIKE: Form. 8 BY MR. KUVIN: 9 Q. Was she upset, calm? How did she appear 10 to you? 11 MR. PIKE: Form. 12 THE WITNESS: She did — I recall her 13 being upset, talking to me. Occasionally 14 crying. It wasn't like a hysterical cry but 15 she was visibly upset 16 BY MR. KUVIN: 17 Q. Okay. Do you recall Ms. Ms date of 18 birth? 19 A. Not off the top of my head. 20 MR. KUVIN: All right. Let me see if I 21 can help you here. It looks like we have an 22 unredacted copy of the PC affidavit That will 23 help. This document will remain sealed 24 pursuant to all previous agreements in the case 25 with respect to any documents that we referred 1 2 3 4 5 6 7 8 10 11 12 13 15 16 17 18 19 20 21 22 23 24 25 Page I(_ MR. PIKE: Form. BY MR. KUVIN: Q. Does she describe whether or not she had gone to Mr. Epstein's home? A. Yes. MR. PIKE: Form. BY MR. KUVIN: Q. Did she describe whether or not she brought anyone with her during that time? MR. PIKE: Form. THE WITNESS: If I can read — MR. KUVIN: Yes. You can refer back to it if you need to. MR. PIKE: For the record you're referring back to Exhibit 1, correct? THE WITNESS: Correct. Yes, she did. BY MR. KUVIN: Q. Okay. Now, if we look at Page 16 of 22 there with respect to Ms.■ it mentions something about a Christmas bonus. Do you see that? A. Yes. Q Can you explain to us what she told you about that? MR. PIKE: Form. THE WITNESS: She received a wire, a Page 160 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Q. 14th, correct. Thank you. And her date :2she 25 . A. to. 2 THE WITNESS: That's Exhibit 1? 3 MIt KUVIN: Bingo. Do you have a copy? 4 MR. PIKE: Thank you. 5 MR. KUVIN: If you turn to Page 15 of 22 — MR. EDWARDS: I have one thanks. BY MR. KUVIN: Q. Do you have Page 15? A. Uh-huh. Q. If we look there, what was Ms date of birth? A. MR. PIKE: Form. BY MR. KUVIN: Q. All right Let's go to, let's stay with this because it's unredacted because it will be a ' little gasier. November 15 you apparently met withE is that correct? PIKE: Form. THE WITNESS: 14th I believe it was. BY MIt KUVIN: Page 162 1 Western Union wire to what she referred to as a 2 Christmas bonus. 3 Q. Who did it come from? 4 A. Mr. Epstein. 5 MR. PIKE: Form. 6 BY MR. KUVIN: 7 Q. All right. On November 15 you met with 8 someone with the initials= is that correct? 5 A. Correct. 10 Q. Do you agawho that was? 11 A. Yes, it's= 12 Q. . What was her date of birth? 13 MR. PUCE: Form. 14 THE WITNESS: 15 • BY MR. KUVIN: 16 Q • Did she recall going to Mr. Epstein's 17 bony? 18 MR. PIKE: Form. 19 • THE WITNESS: Yes. 20 BY 1ViR. KUVIN: 21 Q. What was her emotional state when you 22 'talked to her? 23 ' A. She was nervous, scared, and embarrassed. 24 Q Okay. Did she recount going to 25 Mr. E • tein's home? PROSE COURT REPORTING AGENCY, 9 (Pages 159 to 1 62) INC. Electronically signed by cynthia Hopkins (601 Electronically signed by cynthia hooking (601 Electronically signed by cynthia Hopkins (601 aa2a5ddb.fa81-4116-b3b7-ckda51494142 EFTA00298302 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 i-age 163 A. Yes. 2 MR. PUCE: Form. 3 BY MR. KUVIN: 4 Q. Was she underage? 5 MR. PIKE: Form. THE WITNESS: Yes. BY MR. KUVIN: Q. Do you recall how old she was when she went there? MR. PIKE: Form. THE WITNESS: Sixteen. BY MR. KUVIN: Q. Okay. Much like all the other occasions that we have talked about today, was Mr. Epstein naked and received a massage from her? A. Correct. MR. PIKE: Form. BY MR. KUVIN: Q. She was given money like all the other girls for that massage? MR. PIKE: Form. THE WITNESS: Yes. BY MR. KUVIN: Q. And also much like all the other girls, was there also a massager and vibrator involved in Page 164 1 that incident? 2 MR. PIKE: Form. 3 THE WITNESS: I believe so. 4 BY MR. KUVIN: 5 Q. Next page, 18 — one thing I forgot to ask 6 is during the execution of the warrant, if we look 7 then at Line 4 it says: "Numerous photographs of 8 naked young females, some of which appeared to be 9 the girls I previously interviewed, were on display 10 throughout the house.' Do you see that? 11 A. Yes, 12 Q. Do you resell that? 13 MR. PIKE: Form. 14 THE WITNESS: That was on the photos 15 hanging on the way up the stairwell to the 16 second floor. Some appeared to be the girls 17 but under closer observation, no. 18 BY MR. KUVIN: 19 Q. But they were naked, or pictures of naked 20 girls leading up that stairwell? 21 MR. PIKE: Form, asked and answered. 22 THE WITNESS: Yes. 23 BY MR. KUVIN: 24 Q. And the stairwell, where was it located? 25 A. Off the kitchen. There was apassage door —ter® Page 165 1 that would swing open and it led you up a stairwell that 2 just went up and around. 3 Q. All right. And bottom paragraph on 4 December _ ? SI_Detective and I met within Do you 5 recall whonis? 6 A. Yes, Jane Doe No. 2. 7 Q. What was her date of birth? MR. PIKE: Form. 9 THE WITNESS: 10 BY MR. KUVIN: 11 Q. And it say.' made arrangements to take 12 t o the house. Did that mean to Mr. Epstein's 13 14 MR. PIKE: Form. 15 THE WITNESS: Correct. 16 BY MR. KUVIN: 17 Q. Who is 18 A. Jane Doet. 3. 19 . Q. Did you determine whether or not e, 20 Ms. Doe No. 2, was taken to Mr. Epstein's home when 21 she was minor, in other words under the age of 18? 22 MR. PIKE: FOrM. 23 THE WITNESS: Correct 24 BY MR. KUVIN: 25 Q. And once again didErecount a sexual Page 166 1 encounter with Mr. Epstein while at his home? 2 A. That's comet. 3 MR. PIKE: Form. 4 BY MR.. KUVIN: 5 Q. Once again encountered Mr. Epstein where a 6 massage took place? 7 MR. PIKE: Form. 8 THE WITNESS: Correct. 9 BY MR. KUVja 10 Q. When recounted her incident to you, 11 what was her demeanor? 12 MR. PIKE: Form. 13 THE WITNESS: Crying, upset, embarrassed. 14 BY MR. KUVIN: 15 Q. Did she mention whether or not she told 16 Mr. Epstein where she was attending school? 17 MR. PIKE: Form. 18 THE WITNESS: I believe she did. I 19 believe she did. 20 BY MR. KUVIN: 23. Q. And Pm looking at Page 19 of 22. It 22 appears there is an encounter she describes where 23 Epstein rubbed her breasts and asked her if she 24 liked having her breasts rubbed. Do you recall 25 that? - I" aft' llis00..."..•4.1 10 (Pages 163 to 166) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-fa81-4116-b3b7-dcda51494102 EFTA00298303 Page 16'• Page 169 3 4 5 6 7 8 10 11 • • 13 14 15 16 17 18 19 20 21 22 23, 241 25 MR. PIKE: Form, move to strike. THE WITNESS: Yes. BY MR. KUVIN: Q. What did ML say to you with respect to that issue? MR. PIKE: RPM THE WITNESS: I believe she didn't, she didn't want to have her breasts touched, if I recall. BY MR. KUVIN: Q. It says here — well, let me ask you this: Was this interview recorded? A. Yes, Q. And during the entire interview was she upset, crying? MR. PIKE: Form. THE WITNESS: I wouldn't say the entire interview. There was times she would cry. She would regain her composure, continue. BY MR. KUVIN: Q. Okay. It says here that she told you Epstein had moved her thong panties to one side and began stroking her clitoris, andlEsaying he commented on how hard my cht was. Do you see that? MR. PIKE: Form 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 his fingers out. Pm trying to recall. MR. PIKE: Form, move to strike, nonresponsive. BY MR. KUVIN: Q. Do you recall anything else? A. No. That would be a no. I'm sony. MR. PIKE: I'm sony. I didn't hear the question. MR. KUVIN: You didn't recall anything else (sic)? MR. PIKE: Form. BY MR. KUVIN: Q. All right. Let's talk about the next entry in some detail here. The next entry is an interview that took place on January 9 of 2006; is that correct? A. Yes. Q. Was that a taped interview? A. Yes, taped. thsakay. And the initials• are used. Is MR. PIKE: Form. THE WITNESS: ThaVs correct. BY MR. KUVIN: Q. What wasins date of birth? Page 168 1 MR. KUVIN: Right in the center of the 2 paragraph. 3 THE WITNESS: Yes. 4 BY MR. KUVIN: 5 Q. Did she ten you that? 6 A. Yes, she did. 7 MR. PIKE: Form. 8 BY MR. KUVIN: 9 Q. Did she appear upset when she was 10 describing that to you? 11 MR. PIKE: Form. 12. . THE WITNESS: Yes. 13 BY MR. KUVIN: 14 Q. Did she then describe whether or not 15 Mr. Epstein penetrates her with his fingers? 16 MR. PIKE: Form. 17 THE WITNESS: Digitally, yes. 18 BY MR. KUVIN: 19 Q. What was Mr. Epstein's response when she 20 voiced concern about that maneuver? 21 MR. PIKE: Form. 22 THE WITNESS: I think originally he told 23 her he was not going to go inside and began 24 touching her. Once his fingers were inside of 25 her I think she tried to back • to to net 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 110 A. Q. Okay. How did you identify her as a potential victim or witness? MR. PIKE: Form. THE WITNESS: It was during an interview of another, of another female that was interviewed. Told me thatM was brought to the house if I can recall. BY MR. KUVIN: Q. And do you recall where you initially interviewed her? A. I went to her school. She was attending a — it was not like a regular school. It was a different school, as I recall. Q. And when you went to that school, describe for us what you saw. !don't vault to hear anything about statements, just what you witnessed when you first went there. MR. PIKE: Form. THE WITNESS: I identified who I was and my purpose for being there, and I wanted to talk to her about this ongoing investigation. She started to cry. She got visibly upset, shaking. 11 (Pages 167 to 170) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 easaddb-fa81-06-b3b7-dcdo61494142 EFTA00298304 Page 171 1 BY MR. KUVIN: 2 Q. Did you, in fact, conduct the interview on 3 that initial occasion? A. No, I did not. 5 Q. How come? 6 A. Because of the fact that she was a minor and I 7 was at the school. 1 wanted to inform her father or her 9 parents that I was going to be conducting an interview. 9 Q. Okay. Did she appear to you in a physical 10 or mental state capable of discussing anything with 11 you at that point based on just what you witnessed, 12 not what she may have said but just what you were 13 able to witness? 14 MR. PIKE: Form. 15 THE WITNESS: No. 16 BY MR. KUVIN: 17 Q. Can you describe why? 18 MR. PIKE:. Same objection. 19 THE WITNESS: She was shaken. She was 20 physically upset. 21. BY MR. KUVIN: 22 Q. Okay. Did you have to then follow-up? 23 A. Yes, I did. 24 Q. Tell me about that. 25 MR. PiKE: Form. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 • 25 Page 173 have asked, because you have literally objected to eves), question I have asked. MR. MICE: I have. MR. KUVIN: And if that's the standing for the objection, you can have a standing objection as to all of that And then what I would I like to know is with each individual question, if there is a way that I can fix the form of that question because of some reason that you think is objectionable, I would like to know that so Jean try to fix it MR. PIKE: Well, let me also say that the form elicits third-party testimony. Almost every one of your questions here today, every one of them elicit third-party testimony which is hearsay and opinion. And no, I will not agree, although I appreciate your offer to have a standing form objection, I think that each objection needs be to raised individually based upon the tenor and structure of your questions. Some of your questions I have not objected to form because the question is was there an investigation. Okay. I am not going to object to form. Page 172 1 MR. KUVIN: Hang on one second. Objection 2 to form to 'tell me about that"? 3 MR. PIKE: It's an investigation and jam 4 not going to waive anything I want to preserve. 5 MR. KUVIN: is there a particular form 6 that I can fix? 7 MR. PIKE: Quite frankly I am not quite sure you can fix any of this deposition today. 9 I believe that this deposition, once again, is 10 completely- 11 MR. KUVIN: • The question. 12 MR. PiKE: -- completely fruitless because 13 it is involving an investigation. None of it, 14 in my research or understanding is admissible 15 in the civil cases.' So, there are various 16 things that while your questions in and of 17 themselves may seem correct, the background in 18 which you're eliciting them from is not 19 admissible, so as a result it makes the 20 form incorrect. 21 MR. KUVIN: Let's do this then, why don't 22 we do a standing objection as to all questions 23. during the deposition as to the taking of 24 anything regarding statements, so that you 24 25 don't hannio2liec........a ct to every that I _,...a 25 a. (561) 8-32-7500 1 2 3 4 5 6 7 a 9. 10 11 12. 13 14 15 16 17 18 19 20 21 22 23 Page 174 But when you get into what occurred during that investigation, how he learned of it, who he spoke to, and how many third parties discussed it with the first person that he spoke to, and how those individuals learned the information, I must assert the form and preserve. MR. KUVIN: All right. Les talk about this though for a minute because this is • important And I'm sorry for taking up your time, Detective, but these questions — THE WITNESS: No. MR. KUVIN: — involve my client= so any statements that she made to this Officer • are admissions by a party opponent obviously are admissions by a party. So the hearsay issue is frivolous. With respect to anything that she said to him is completely admissible in this proceeding and clearly what he witnessed is admissible because that is eyewitness. He witnessed it himself. So anything with respect to what he saw and what he witnessed, any objections regarding h .......2Ljarsa t abo that is comletel frivolous. 12 (Pages 171 to 174) PROSE COURT REPORTING AGENCY, :INC. Electronically signed by synth's hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by Cynthia hooklike (601 aa2a5ddb.fa81-4H6-b3b7-dcda51494142 EFTA00298305 Page 1', Page 177 1 What I need to know is when' 2 questions specifically with respect 3 which I am about to do, I need to know ether 4 or not there is a particular objection to the 5 form of my question that is specific to that 6 question as opposed to the structure of the 7 deposition, which if you want to object 8 generally, then that's fine. I need to know 9 that because if I ask a question specific to my 10 client, l want to know if there is a way that 11 you feel that it needs to be fixed that I can 12 take care of and fix presently with Detective 13 Recarey in the room. 14 MR. PIKE: Okay. As to your statements 15 regarding the frivolous hearsay objections, you 16 seem to forget that this deposition has been 17 cross-noticed by several attorneys who are 18 sitting here today. So, as a result you're 19 taking this deposition, but this is a 20 cross-noticed deposition. And as a result I 21 have to maintain the form assertions as well as 22 various privileges for these other individuals 23 who are representing several other alleged 24 Plaintiffs in these cases. That's Number 1. 25 So, just because you're asking the Page 176 1 questions here today, Mr. Kuvin, maybe you 2 should talk to your co-counsel about 3 cross-noticing these depositions because maybe, 4 in fact, it is prejudicing your case. That's 5 Number I. 6 As Number 2, with regard to his eyewitness 7 accounts, whether or not he observed someone's 8 mental state or whether or not they were in a 9 specific state when he spoke to them, he is not 10 an expert. So, you andllcnow, you and I try 11 several cases, and we know good and well that 12 police officers are not‘xpcilb when it comes 13 to the psychological state and mental condition 14 - of a particular person on a particular time or 15 a particular day, how did they feel, how did 16 they look, you know, layperson observations. 17. But how did they feel, their mental state, I am 18 going to preserve the form. 19 MR. KUVIN: Okay. 20 MR. PIKE: Thanks. 21 BY MR. KUVIN: 22 Q. With respect to this July 9,2006, 23 interview that you took of C.I.. did she provide to 24 you the date of her birth? 25 MR. PIKE: Form. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 1.6 17 18 19 20 21 22 23 24 25 THE WITNESS: Yes, she did. BY MR. KUVIN: Q. And did she tell you how old she was when she went to Mr. Epstein's home? MR. NICE: Form. THE WITNESS: Yes, she did. BY MR. KUVIN: Q. How old did she tell you that she was when she went to it. Epstein's home? MR. PIKE: Form. THE WITNESS: I believe she said she was 15. BY MR. KUVIN: Q. Okay. And did she tell you who took her to Mr. Epstein's home? MR. PIKE: Form. THE WITNESS: I believe, `-I think it was. BY MR. KUVIN: Q. Did she recount to you what-explained about this visit to Mr. Epstein's home? MR. PIKE: Form. MR. KUVIN: And if you can't recall, you can refer to the probable cause affidavit, Pages 19 and 20. Page 178 MR. PIKE: Just for purposes of the record something else just came to mind is that you said s line of questioning is to your client h ied case against Jeffrey Epstein, an has not provided any sort of information re anve to she being, her being your client So, in that regard I also have to assert form and preserve. MR. KUVIN: She will. MR. PIKE: I know. BY MR. KUVIN: • Q. Okay. Did she explain what Ms. old her about the visit to Mr. Epstein's home? k Ifl can refer to the — Q. Please do. MR. PIKE: Form. THE WITNESS: She was to model lingerie . for a wealthy person in Palm Beach. BY MR. KUVIN: Q. Okay. Was there any notice given according to what Ms. told you that she would have to get naked or doing anything sexual? MR. PIKE: Form.. 13 (Pages 175 to 178) PROSE COURT REPORTING AGENCY, INC; :(5'61) 832.7506 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a6ddb-ta81 -4116-b3b7-dcda51494142 EFTA00298306 Pagc: Page 181 1 BY MR. KUVIN: 2 Q. And you can refer to your tcpo, t if you 3 don't recall. 4 A. Ism going to have to refer. 5 Q. That's fine. 6 A. It was some time ago, so... 7 Q. When described what she was supposed 8 to do at the home of Mr. Epstein, was there any 9 discussion about being naked or having a massage or 10 anything like that? 11 MR. PIKE: One second becaace I don't 12 understand the question. When MI described 13 to or to Detective Recarey? 14 MR. KUVIN: Correa. 15 BY NIR. KUVIN: 16 Q. When= talked to. about what to 17 expect at Mr. Epstein's home, was there any 18 discussion about getting naked initially? 19 MR. PIKE: Form 20 THE WITNESS: Not initially. 21 BY MR. KUVIN: 22 Q. All right. What clic=tell you 23 happened when she got at the home, got to the home? 24 MR. PIKE: Form. 25 THE WITNESS: I believe the private chef 1 THE WITNESS: Yes, he did. 2 BY MR. KUVIN: 3 Q. Where? 4 A. I believe he stroked her vagina. 5 Q. Do you recall whether she discussed if he 6 touched her breasts as well? 7 MR. PIKE: Form. 8 THE WITNESS: He may have. I'm trying to 9 recall. I believe so. 10 BY MR. KUVIN: 11 Q. Okay. What did she tell you Mr. Epstein 12 was doing during this massage? 13 MR. PIKE: Form. 14 ME WITNESS: Masturbated. 15 BY MR. KUVIN: 16 Q. Did he, did she tell you whether he 17 ejaculated eventually? 18 MR. PIKE: Form. 19 THE WITNESS: I believe he did. 20 MR. PIKE: And leading. 21 BY MR. K Silk: 22 Q. Did •'scuss anything with you about 23 threats made . Epstein to hell 24 MR. PIKE: Form. That would be double 25 hearsay. Page 180 1 prepared dinner for them. At the conclusion of 2 dinner, they went upstairs to do the massage. 3 (Mr. Epstein left the deposition room.) 4 S: And that was the time that I 5 believe anted of this massage. 6 BY MR. KUVIN: 7 Q. And how did-initially react to that? 8 MR. PIKE: Form. 9 THE WITNESS: She had ask why they 10 were going to do the massage instead 11 modeling. 12 BY MR. KUVIN: 13 Q. . All right MIN have to get or did 14 she get undressed according to her? 15 A. Yes, she did. 16 MR. PIKE: Form. 17 BY MR. KUVIN: 18 Q. And did she tell you whether or not she 19 gave Mr. Epstein a massage while he was naked? 20 MR. PIKE: Form. 21 WE WITNESS: Yes. 22 BY MR. KUVIN: 23 Q. Did she explain to you whether Mr. Epstein 24 touched her? 25 MR. PIKE: Form. Page 182 1. /vM. KUVIN: Actually double admission, so 2 it comes in. 3 MR. PIKE: Well, only now you bring up 4 another whole point which is why I keep 5 objecting to form, just so the record is clear 6 is only admissions against interest are 7 admissible, and you have been talking about 8 your client and other alleged victims. And I 9 haven't heard any admissions — or let me not 10 identify them — but I haven't heard you 11 specifically identify admissions against 12 interest to survive my form objection. So you 13 can proceed. 14 MR. KUVIN: It's actually a commonly 15 misinterpreted concept in the law. And it's 16 not admission against interest. It's actually 17 admission by a party opponent. Under the 18 Florida Rules it doesn't have to be against 19 interest, but we can research that later. 20 BY MR. KUVIN: 21 g All right With respect to Mr. Epstein's 22 threats did Mr. Epstein, did -- let me clarify. Did 23 say whether Mr. Epstein threatened her after 24 the massage took place? 25 MR. PIKE: Form. 14 (Pages 179 to 182) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb.fa81-466-b3b7.dcda51494142 EFTA00298307 Page 183 1 THE WITNESS: She stated that if she spoke 2 of this to anyone, bad things could happen 3 BY MR. KUVIN: 4 Q. Did Ms.. tell you that she was afraid? 5 MR. PIKE: Form. o THE WITNESS: Yes. 7 BY MR. KUVIN: 8 Q. Did she explain why she was afraid? 9 MR. PIKE: Form. 10 THE WITNESS: Yes, she did. She explained 11 that because he was very wealthy, you know, 12 that he could pay someone to hurt her or her 13. family. 14 BY MR. KUVIN: 15 Q. Did Ms explain whether or not she 16 received any atonal contact from Mr. Epstein or 17 one of his agents? 18 MR. PIKE: Form. 19 THE WITNESS: I believe she went another 20 time to the house. 21 BY MR. KUVIN: 22 Q. All fight. If you wovulelice a look at 23 Page 20 of 22. It says here: stated that 24 sever he recei a telephone call 25 from MEM who coordinated for= to return 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 184 to, quote, work Do you see that? A. Yes. egjaii ever able to verify and document that actually contacted.by telephone records? Il ranced joilt ne lerds were obtained during the investigation. I believe that, yes, through the — I believe I remember seeing individual girls' cellphone numbers off cellphone record. Q. Okay. MR. PIKE: Form, move to strike. BY MR. KUVIN: Q. And did Ms.Mreturn, did she tell you that she returned to Mr. Epstein's home — MR. PIKE: Form. BY MR. KUVIN: Q. — a second time? A. Yes. I believe so. Q. The second time that she returned to the home, was she still a minor? In other words, how — well, let me ask it this way: When she returned according to her to Mr. Epstein's home, how old was she? MR. PIKE: Form. 1 2 3 4 5 6 10 11 :2 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 185 THE WITNESS: Well, she, when she went she was 15. BY MR. KUVIN: Q. Okay. The second time she went though, did she describe that it occurred, you know, a year later, weeks later, a month later? MR. PIKE: Form. THE WITNESS: I'm trying to recall. I don't believe it was hie a year later. It was more. lam trying to recall exactly. Could have been a week, two weeks, a month. I'm not 100 percent certain but I know it wasn't a year later. BY MR. KUVIN: Q. All right. So, did you determine how old she was that second time she returned? MR. PIKE: Form. BY MR. KUVIN: Q. In other words was she still 15? Had she turned 16 by then? MR. PIKE: Form. THE WITNESS: I can't recall without looking at the report MR. KUVIN: Take a look if you would. MR. PIKE: And just so we're clear, while Page 186 1 he is looking, the other issue I have is that a 2 lot of these questions, for instance the first 3 time, the second time, the third time, it deals 4 with not onlyIII but in some of your 5 questions these deal with other third parties 6 and there is no predicate or foundation having 7 been laid relative to the dates these 8 individuals actually or allegedly came to the 9 home. 10 So, then the follow-up question of how did 11 you determine how old they are, ! don't believe 12 the proper predicate is there. So, that's 13 another basis. I mean, you asked, right? 14 MR. EDWARDS: Predicate is there to 15 detennine her age at the time; is that what you 16 are saying? 17 MR. PIKE: Yes, proper predicate had not 18 been laid. 19 BY MR. KUVIN: 20 Q. All right. With respect to the second 21 time she went to the home, let's talk about that: 22 Did you determine how old she was the second time 23 she came to the home? 24 A. It would have been several days later. 25 MR. PIKE: Form. (561) S32-7500 PROSE COURT REPORTING 15 (Pages 183 to 186) AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5cldb-fa81-4116.b3b7,dcda51494142 EFTA00298308 Page Page 189 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. KUVIN: Q. And what occurred during this second time she was at the home — MR. PIKE: Form. BY MR. KUVIN: Q. —according to her? A. She returned to the home wittMand another massage was conducted. Q. All right. And did this massage involve Mr. Epstein again getting naked? A. Correct. MR. PIKE: Form. BY MR. KUVIN: Q. Did this massage, according to her, involve any touching by Mr. Epstein of ha? MR. PIKE: Form. THE WITNESS: Yes. BY MR. KUVIN: Q. Where did she tell you that Mr. Epstein touched her? MR. PIKE: Form. THE WITNESS: She informed me that her vagina was touched digitally while he was masturbating. 1 MR. PIKE: Form. 2 BY MR. KUVIN: 3 Q. What was her demeanor dining this 4 interview with you? 5 A. She was scared. She was nervous. Obviously 6 she was still crying. 7 Q. If we look at Page 21. You met with a 8 gentleman by the name of Alfredo Rodriguez -- 9 A. Yes. 10 Q. — who was the houseman? 11 A. Yes. 12 MR. PIKE: Form. 13 BY MR. KUVIN: 14 Q. Have you come to learn recently that he 15 was arrested by federal authorities? 16 A. Correct 17 Q. Did you also come to learn recently that 18 he has pled guilty? 19 A. I have not seat I heard it. It was in, I 20 guess, the news either last night or this morning. 21 Q. Do you know what he pled guilty to? 22 A. No. 23 Q. Are you aware that — well, when you met 24 with him, did he explain to you whether or not he 25 had any telephone books or telephone logs or any 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 188 BY MR. KUVIN: Q. Okay. Did she describe during the second time whether or not Mr. Epstein climaxed? MR. PIKE: Form. THE WITNESS: Yes, she did. BY MR. KUVIN: Q. And did she recount for you whether or not Mr. Epstein made another threat to her at the conclusion of this massage? MR. PIKE: Form. Who are we talking about? MR. KUVIN: THE WITNESS: Yes. BY MR. KUVIN: Q. What did she tell you? MR. PIKE: Form. ME WITNESS: She said that she was not to speak of this to anyone; bad things could • haPPen. BY MR. KUVIN: • Q. When you talked to her, was she afraid, bless you, was she afraid that Mr. Epstein would do something to her or her family? A. Yes. She was afraid that someone would hurt either her or her family. Page 190 1 kind of information of girls that had come to the 2 home? 3 MR. PIKE: Form. 4 MR. KUVIN: Documents in other words. 5 THE WITNESS: When I spoke with him, he 6 had advised that he had a, originally he stated 7 journal. But what he provided me was a green 8 folder with different pieces of papers inside 9 the folder. 10 BY MR. KUVIN: 11 Q. Did he ever give you any kind of a journal 12 or binder of names? 13 A. No. 14 Q. Are you aware as you sit here today that, 15 in fact, he did possess such a journal of names? 16 A. Yes, I did. 17 MR. PIKE: Form. 18 BY MR. KUVIN: 19 Q. How did you team that? 20 MR. PIKE: Form. 21 THE WITNESS: I read it through the 22 newspapers. 23 BY MR. KUVIN: 24 Q. Did you ever see that journal? 25 A. No. 16 (Pages 187 to 190) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia honking (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-fa81-4f16-b3b7-dcda51494142 EFTA00298309 Page 193. Page 193 1 MR. PIKE: Form. 2 MR. KUVIN: Let me show you a stack of 3 message books that were apparently — well, let 4 me ask you about them. It's all of them. 5 (A discussion was held off the record.) 6 BY MR. KUVIN: 7 Q. Ni going to show you a stack first and 8 then what I'll do is I'm not going to mark the 9 entire stack, but I will pull out individual ones so 10 I'll ask you about them. Just take a look at the 11 stack of documents I am showing you. 12 Do you recognize what it is? And if you 13 do, then if you could just describe it for us. 14 A. These are copies of the, some of the phone 15 pads, of phone message pads taken from the home. 16 Q. Okay. Let me take it and I will just ask 17 you some individual questions. 18 MR. PIKE: One second. I want that entire 19 document marked as an exhibit And it's clear 20 that the witness just refreshed his 21 recollection based upon your past questioning 22 regarding trash pulls and documents that were 23 allegedly taken from the home. 24 So, I want that entire — he has looked at 25 it. Ifs in his possession. I want the entire Page 192 1 document, put a clip on it and have the court 2 reporter mark it. 3 MR. EDWARDS: Are you talking about the 4 Page I that he looked at? 5 MR. PUCE: He didn't just look at Page 1. 6 You should ask him that. He's flipping through 7 the documents. 8 MR. EDWARDS: Every single page? We had 9 this discussion in your client's deposition as 10 well. 11 MR. PIKE: Yeah, that was my 12 attorney-client work product for that witness. 13 So I just want the document marked. That's 14 all. 15 KUVIN: It's not going to be turned 16 over. It's my document. 17 MR. PIKE: The witness has just looked at 18 it. 19 MR. KUVIN: He looked at the first couple 20 pages, so I am not turning it over. I am 21 turning over the documents that I marked from 22 my stack of documents. 23 MR. PUCE: Thai I am going to move to 24 strike every question relative to the documents 25 that the witness looked at. The witness 1 2 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 has flipped through that document les not a big deal. You can mark it as an exhibit. It has none of your attorney notes on it, none of your work product on it. It's been in the witness's possession, and as a result, I am entitled to it pursuant to the law. MIL KUVIN: This is Mike Pike on the law. MR. PUCE: Well, then this is what I am going to instruct you to do, preserve that document in whole. MR. KUVIN: Sure. MR. PIKE: Mark it as an exhibit in whole, preserve it Okay. MR. KUVIN: Why don't you just do a request to produce the phone logs if you don't have these already? MR. PIKE: Why should I wait 30 days for something? I don't know exactly what's in there, Mr. Kuvin. There could be -- I could have all of that in full. I 'could be missing one document I don't know what it is that you have. So, if you just want to move forward, you can move forward and you can mark the document, or I am going to move to strike because you haven't marked it as an exhibit. Page 194 MR. KUVIN: You do whatever you feel appapriate. BY MR. KUVIN: Q. Do you ver come to learn who a woman was by the name of A. No, I ' not Q. What about a Dr. Jarecki, J-a-r-e-c-k-i, did you ever learn who that was? A. No. Q. What about a Jane Doe, (Spells first name). A. No. Some people were not identified off those phone logs. Q. Okay. It appears that some of the phone logs are, the names of the individuals are whited out. Was that done at some point by the department? MR. PIKE: Form. THE WITNESS: No, nothing was ever whited out BY MR. KUVIN: Q. On the phone logs, no? A. No, not by me. Q. Okay. Did you ever come to learn who the gentleman by the name of Jean Luc was? A. Jean Luc had a modeling enc , I believe. 17 (Pages 191 to 194) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkIns (601 aa2a5ddb-fa81-4ff6-b3b7-dcda51494142 EFTA00298310 Page 195 Page 197 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MC2. Q. Did you ever determine whether or not there was any connection between Mr. Epstein and that modeling agency of MC2? MR. PIKE: Form. THE WITNESS: I recall a phone message, duplicate phone message to Mr. Epstein from Jean Luc which said I have a girl for you and then it had two times eight. MR. KINN: Let me see if I can find that one. MR. PIKE: Form to that, the other question. MR. KUVIN: This one I will mark. MR. PIKE: Well, I just want it clear for the record that there is a difference between looking at a document and refreshing your recollection on a document. And it's clear under Florida Jur. So, what I would like you to do, Mr. ICuvin, before you categorize these documents, is I would like you to mark this document in full. You can keep it in your possession. All right And then we can talk about it later instead ot you know, marking 1 Q. Let me take a quick look. 2 A. 1 don't know if you saw this one. 3 Q. Let me take a quick look. All right. 4 Just so the record is clear, this message appears to 5 say: Ile has a teacher for you to teach you how to 6 speak Russian. She is two times eight years old. 7 Not blonde. Lessons are free, and you can have 8 first today if you call." Did I read that 9 correctly? 10 MR. PIKE: Form. 11 THE WITNESS: That is correct. 12. BY MR. KUVIN: 13 Q. Okay.- Did you ever determine what that 14 meant? 15 MR. PIKE: Form. 16 THE WITNESS: I never spoke with Jean Luc 17 but it appears that two times eight is 16. 18 BY MR. KUVIN: 19 Q. Could it mean two 8-year-old girls? 20 MR. PIKE: Form, move to strike the 21 witness's testimony. • 22 . MR_ EDWARDS: He hasn't said anything yet 23 MR. PIKE: Two times eight equals 16. You 24 didn't hear him say that I don't thinlc you 25 did, and I move to strike it. Page 196 1 several different documents. 2 Maybe it would be easier if you just 3 marked it and we took it up with the cote 4 later. Otherwise you're going to, you're going 5 to kind of mess with the structure of the 6 document as the witness has utilized to refresh 7 his recollection. 8 MR. KUVIN: Okay. I appreciate your 9 objection. 10 (Plaintiffs Exhibit No. 6 was marked for 11 identification.) 12. BY MR. KUVIN: 13 Q. Him going to give you what1marked as 14 Exhibit 6. Is that the message that you're 15 referring to? 16 A. Yes. 17 Q. And that message or that photocopy page 18 appears to have four messages in it; is that 19 correct? 20 MR. PIKE: Form. 21 THE WITNESS: Correct. 22 BY MR. KUVIN: 23 Q. Where does the message you're referring to 24 appear on the document? 25 A. Top left. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 198 Mr. Edwards, this is, if you, if you find something funny here, then maybe we can take a MR EDWARDS: You're striking things that were not said, funny. MR. PIKE: You didn't hear something said and it was said. I move to strike it. MR. EDWARDS: It was the previous ' question. I get it. I'm with you. MR PIKE: Were going to take a break. Mr. Edwards needs a break, because there is, by no stretch of the imagination — lam not here all day to hear Mr. Edwards laugh over there in the corner trying to do a job. MR. KUVIN: To that extent I am not here to hear Mr. Epstein laugh about questions that I am asking either. But he is over here snickering, and I don't mention it every time he snickers at one of the sexual questions that I ask. MR. EDWARDS: I was laughing because I thought you were objecting to the witness's answer and he hadn't yet answered. I understand now. You're objecting to the vious answer then fine. 18 (Pages 195 to 198) PROSE COURT REPORTING -AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a6eldb.ta81-4H6-b3b7-dcda51494142 EFTA00298311 Page 199 Page 201 1 MR. PIKE: Lets just take a break 2 MR. EDWARDS: I'm fine. 3 MR. PIKE: Let's take a break and everyone 4 can gather their senses and everyone can get 5 back to doing their job on each side of the 6 table: 7 (A brief recess was held.) 8 MR. KUVIN: Are you ready? 9 MR. PIKE: Let's go back on the record. 3.0 Mr. Kuvin, do you have any idea how much 11 longer? I am trying to get an idea as to 12 whether or not we want an opportunity to 13. question the witness today. And there are 14 other lawyers. I know Mr. Edwards wants an 15 opportunity to go after you, Pm sure. . 16 I don't know if Ms. Finnigan is going to 17 be asking questions or Ms. Arbour. 18 So, I would like to get an idea as to how 19 much time you have and then Mr. Edwards and 20 Ms. Finnigan and Ms. Arbour. 21 MR. KUVIN: I'm almost done. I'm going to 22. go through some of the messages and then I have 23 got some probation violation stuff I want to 24 talk about. So, once I am done with that, I 25 should be about done. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 200 And then I don't know, we can talk about this, whether or not you-all can go before the rest Of the Plaintiffs go. I don't know their feelings on that, but we'll leave it up to them. MR. PIKE: We're fine with letting them go. MR. EDWARDS: I am going to try to make this easy for you. I think we talked earlier that the deposition has to end today at 5. And given those parameters, there is no way that I can get through my questions. We're going to need a second day for this deposition anyway. I am assuming that it's because lit Weinberg is down from Massachusetts today and he wants to ask questions. I don't care what order I go in. So, if you want to ask questions next, that's perfectly fine with me. It doesn't really matter. Whatever is easiest. I am amenable to whatever your suggestion is. That really is fine. MR. PIKE: hut for the record when you say you spoke to, when you said you spoke recarxiine the deposition ending at 5, just to 25 1 2 3 5 6 7 C 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 make the record clear you spoke to Ms. O'Connor, correct, at the beginning of today? MR. KUVIN: It was actually a discussion with Kathy Ezell as to whether or not they would get to her, and that's where the discussion went MR. PIKE: I just want to make sure that discussion wasn't with me, because I am here for as long as it takes to get everyone done. But it's clear that I guess Ms. O'Connor and the witness need to be done at 5. So, 5 is 5. MR. EDWARDS: Right And given that it's already pretty late, I know that we're not going to get it done, so that's why — MR. PIKE: Understand. MR. EDWARDS: Do you want to ask questions, that's fine, whatever. MR. PIKE: Can I speak with my client for a minute? MR. EDWARDS: Let's take two minutes. MR. PIKE: Just while we're still on the record, Mr. Kuvin, you have agreed not necessarily today but with regard to the message pads, you have agreed to go ahead and Page 202 1 flip through them. I don't know — 2 MR. KUVIN: I have agreed, you're going to 3 get a copy of them all. 4 MR. PIKE: I am going to get a copy of 5 them all? 6 MR. KUVIN: Yes. 7 MR. PIKE: Thank you. 8 (A discussion was held off the record.) 9 MR. PIKE: We are going to go back on the 10 record. 11 MR. KUVIN: Okay. 12 MR. PIKE: We're going to just go ahead 13 and follow foam with regard to the Plaintiffs 14 finishing, and we'll come back later on. 15 MIL KUVIN: Okay. 16 MIL PIKE: That way you guys can keep that 17 order going. • ' 18 MIL KUVIN: All light. Just keep the 19 phone stuff separate because I only have one 20 copy of that and I just want to make sure I 21 -don't lose it. 22 THE WITNESS: Okay. 23 MR. KUVIN: Lefinext Mark this one as 7. 24 That's the next one I am going to ask him about. ?ROSE COURT REPORTING AGENCY, —4 19 Rages 199 to 202 INC. • Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia bodkins (601 aa2a5ddb-la81-4116.1,3b7-dcda51494142 EFTA00298312 Page 203 Page 205 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. KUVIN: Q. And while they are looking at that one, let me ask you about the last one we were talking about which is Exhibit 6. Jean Luc Brunel, did you ever establish any, or did you ever determine whether there was any connection between Mr. Brunel and John Casablancas? Did that name ever ring a bell? A. No. I have heard of the modeling firm. Q. Eight. A. But, no, no connection. Q. That you were able to determine? A. Right. Q. Okay. With respect to Mr. Brunel, did you ever determine whether or not Mr. Brunel had ever stayed at Mr. Epstein's home on occasion? A. I can't recall. Q. Did you ever determine whether or not Mr. Brunel was present when any underage girls were performing sexual acts for Mr. Epstein? MR. PIKE: Form. THE WITNESS: Not that I'm aware of. BY MR. KUVIN: Q. Did you ever determine whether or not Mr. Brunel was, in fact, providing underage girls to Page 204 1 Mr. Epstein — 2 MR. PIKE: Form. 3 BY MR. KUVIN: 4 Q. - for sexual activities? 5 MR. PIKE: Same objection. 6 THE WTINESS: Based on the phone message 7 it appears that it may be someone. 8 BY MR. KUVIN: 9 Q. Anything else other than Exhibit 6? 10 MR. PIKE: Wait one second. Move to 11 strike witness's last testimony as 12 nonresponsive, and then form to Mr. Kuvin's 13 follow-up question. 14 MR. KUVIN: You can answer. 15 'IRE WITNESS: Outside of the phone 16 message, no. 17 (Plaintiffs Exhibit No. 7 was marked for 18 identification.) 19 BY MIt KUVIN: 20 Q. All right. Let me show you what we have 21 marked as Exhibit 7. There appears to be three 22 messages regarding someone with the last name 23 Meister. Do you see those? 24 A. Yes. 25Sfinesvho that was? PROSE COURT 1 A. No. 2 MR. KUVIN: This is what we'll mark as 8. 3 (Plaintiffs Exhibit No. 8 was marked for 4 identification.) 5 BY MR. KUVIN: 6 Q. All right. Take a look at what I've 7 marked as Exhibit 8 with two messages on the 8 right-hand side. Let me ask you about those for a 9 moment. Do you see one there from David 10 Copperfield? 11 A. Yes. 12 Q. What does it say in the text of the 13 message? 14 A. "Magic David called." 15 Q. Did you come to learn that this was, in 16 fact, David Copperfield the magician? 17 A. Yes. 18 Q. When you went through the phone message 19 pads did you find a number of messages from 20 Mr. Copperfield to Mr. Epstein? 21 A. Yes. 22 MR. PIKE: Form. 23 BY MR. KUVIN: 24 Q. Did you become aware during the 25 investigation that Mr. Copperfield was, in fact, Page 206 1 charged with raping a girl? 2 MIt PIKE: Form. 3 THE WITNESS: I recall reading through the 4 media that I know that they executed search 5 warrants either at his home or hotel room, one 6 or the other. 7 BY MR. KUVIN: 8 Q. Okay. Did you learn that prior to this 9 investigation or did that, is that something you 10 learned subsequent to this pending investigation? 11 MR. PIKE: Form. 12 THE WITNESS: It was during the 13 investigation. 14 BY MR. ICUVRsl: 15 Q. Did you ever have conversations with the 16 federal authorities about Mr. Copperfield that you 17 can recall? 18 A. Not that I can recall. 19 Q. Okay. Do you recall whether or not you 20 learned about the federal investigation regarding 21 Mr. Copperfield before or after the Feds took your 22 information of Mr. Epstein's investigation? 23 (Mr. Goldberger entered the deposition 24 room) 25 THE WITNESS: I want to saz it was just 20 (Pages 203 to 206) REPORTING AGENCY, INC.. Electronically signed by cynthia hopkins (801 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 sa2a5ddb•fa81-41f6-b3b7-dcda51494142 EFTA00298313 Page 207 Page 209 after. 2 MR. KUVIN: Okay. 3 THE WITNESS: Just after everything was 4 given to the FBI. 5 BY MR. KfJViN: 6 Q. Do you know whether or not the FBI 7 utilized any of the information that they may have 8 obtained from your investigation such as message 9 pads in the prosecution of Magician David 10 Copperfield? 11 A. I have no idea. 12 Q. Do you know whether or not Mr. Epstein and 13 Mr. Cooperfield were, in fact, sharing underage 14 girls for sexual acts? • 15 MR. PiKE: Form. 16 THE WITNESS: I do not know. 17 BY MR. KUVIN: 18 Q. Do you know whether or not Mr. Epstein and 19 Mr. Copperfield were, in fact, sharing information 20 about girls for sexual acts? 21 MR. PIKE: Form. 22 THE WITNESS: That 1 don't know. 23 BY MR. KUVIN: 24 Q. Did you ever interview Mr. Copperfield? 25 A. No. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. PIKE: Form. THE WITNESS: Not really. i didn't get involved in any of the political aspects of that. BY MR. KUVIN: Q. Okay. Do you recall ever having any conversations directly with Mr. Goldsmith about the Epstein case? .. A. No. MR. KUVIN: Okay. This is 10. (Plaintiffs Exhibit No. 10 was marked Ihr identification.) BY MR. KUVIN: Q. All right. Let me show you what we marked as Exhibit 10. There mars to be a message there from someone named Do you see that? A. Yes. Q. What's the date of that message? A. March, it looks Bice 19th of '05. MR. PIKE: Form. MR. KUVIN: What is wrong with the form? MR. PIKE: That's what the message pad says. Whether or not it came through or not, I'm not sure. MR. KUVIN: Okay. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 208 Q. All right. MR. PiKE: May I see Exhibit 7? Just give me one second, Spencer, before you start. MR. KUVIN: Sure. MR. PiKE: Can i see 6? Thank you. MR. KUVIN: No problem. (Plaintiffs Exhibit No. 9 was marked for identification.) BY MR. KUVIN: Q. Here is 9. All right. Take a look at Exhibit 9. It appears to be a message there from Jerry Goldsmith. Do you see that? A. Yes. Q. Do you know who that is? A. He is a town resident. • Q. Do you know whether he ran for office in the Town of Palm Beach. • A. Yes, he did. He ran for mayor. Q. And during the deposition with Chief Reiter in this case, Chief Reiter testified that he had some communications with Mr. Goldsmith about Mr. Epstein. And my question to you is do you know anything about those conversations that may have taken lace? 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 210 MR. PIKE: Form. BY MR. KUVIN: Q. Okay. Could you take a look for me at Exhibit 1 which is the PC affidavit. A. Yes. Q. And tell us, if you would remind us again what was the date that the investigation of Mr. Epstein began? A. -March 15th. Q. Of? A 2005. Q. This message from occurred according to the document, occurred when? A. March 19th, 2005. Q. All right. And what was the message that was taken down and written on that phone message pad? A "She will be here at 4:00 p.m. but she needs to talk to you before that. Please call her back." MR. PIKE: Form. BY MR. KUVIN: Q. Did you ever come to learn what- wanted to talk to Mr. Epstein about just days after the investigation began of him? A. No. 21 (Pages 207 to 210) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801 Electronically signed by cynthia hopkins (801 Electronically signed by cynthia hopkins (801 sa2a5ddb-fa81-4f16-b3b7-dcda51494142 EFTA00298314 Page 21i Page 213 1 MR_ KUVIN: This one is II. 2 (Plaintiffs Exhibit No. 11 was marked for 3 identification.) 4 BY MR. KUVIN: 5 Q. While they are looking at that, were these 6 message pads taken from Mr. Epstein's home during 7 the search warrant? 8 A. Correct. 9 MR. PIKE: Form. 10 BY MR. KUVIN: 11 Q. And what was done with them when they were 12 taken from his home? In other words once they were 13 taken into custody, what did you-all do with them? 14 A. We reviewed them for evidentiary purposes. 15 Q. Okay. 16 A. Provided the State Attorney's Office with a 1.7 copy; obviously, with the filing packet for the arrest 18 warrants, and eventually turned over to the FBI. 19 Q. Okay. All right. Take a lookat Exhibit 20 11. It appears to be a message from Jean Luc again. 21 Take a look at that message. 22 A. Okay. 23 Q. Did you ever determine whether or not 24 Mr. Epstein ever had any sexually transmitted 25 diseases? 1 A. April 1st, 2005. 2 Q. Had the investigation begun against 3 Mr. Epstein at that time? 4 A. Yes. 5 Q. Do you know why Mr. Goldsmith, did you 6 ever learn why Mr. Goldsmith was contacting 7 Mr. Epstein about a month after the investigation 8 began? 9 MR. PIKE: Form. 10 THE WITNESS: No, I did not. 11 BY MR. KUVIN: 12 Q. .Did you ever get a chance to talk to 13 Mr. Goldsmith about the Epstein investigation at 14 all? 15 A. No, I did not. 16 MR. KUVIN: Exhibit 13. 17 (Plaintiffs Exhibit No. 13 was marked for 18 identification.) 19 BY MR. KUVIN: 20 Q. Let me show you Exhibit 13. Does that 21 appear to be another message by Mr. Goldsmith on 22 that message pad? 23 A. Correct. 24 Q. What is the date of that message? 25 MR. PIKE: Form. Page 212 1 MR. PIKE: Form. 2 THE WITNESS: I was not aware. 3 BY MR. KUVIN: 4 Q. Okay. Let me take a look real quick at 5 Exhibit 11. There was something in this note that 6 talks about Mr. Jean Luc speaking to a doctor about 7 symptoms which can shorten your sex life. Did you 8 see that in the message? 9 A. Yes, I did. 10 MR. PIKE: Form. 11 BY MR. KUVIN: 12 Q. Were you ever able to determine what he 13 was talking about in that. message? 14 MR. PIKE: Form. 15 THE WITNESS: No. 16 MR. KUVIN: All right. Exhibit 12. 17 (Plaintiff's Exhibit No. 12 was marked for 18 identification.) 19 BY MR KUM: 20 Q. Does this appear to be more messages from 21 Mr. Goldsmith? 22 A. Correct 23 Q. Are those dated at all? 24 A. One is and one is not. 25 O. What was the date of the one that is? 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16. 17 18 19 20 21 22 23 24 25 Page 214 THE WITNESS: 12/4/04. BY MR. KUVIN: Q. This was before the investigation began? A. Coffees. Q. And Exhibit 14, while they are looking at that, did you also find that them were messages from Mr. Leslie Wexner contained within the message pad at Mr. Epstein's home? A. Yes. Q. Did you come to learn who that was? A. Yes MR. PIKE: Form. BY MR. KUVIN: Q. Who? MR. PIKE: Form. THE WITNESS: He is the CEO of Express, Victoria Secrets. BY MR. KUVIN: Q. Okay. Did you ever get a chance to interview Mr. Wexner? A. No. MR. KUVIN: Exhibit 14. (Plaintiffs Exhibit No. 14 was marked for identification.) 22 (Pages 211 to 214 (561) 83277500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 ea2a5ddb-fa81.4n6-b3b7-dcda51494142 EFTA00298315 Page 215 Page 217 1 BY MTh KUVIN: 2 Q. Take a look at 14. Okay. Does that 3 appear to be a another message from Mr. Goldsmith? 4 A. Correct. 5 Q What is the date of that message? 6 A. The date of the message is 12/14/04. 7 Q. Prior to the beginning of the 8 investigation? 9 A. Correct. 10 (Plaintiffs Exhibit No. 15 was marked for 11 identification.) 12 BY MR. KUVIN: 13 Q. Let me take a look at that real quick. I 14 would like you to take a look at what we have marked 15 as Exhibit 15 at the top right message. Do you see 16 that? 17 A. Yes, sir. 18 Q. AU right. Who does that message purport 19 to be from? 20 A. Jean Luc. 21 Q. And we talked before about Jean Luc. Did 22 you come to learn during your investigation whether 23 or not he had or worked with a modeling agency? 24 MR. PIKE: Form. 25 THE WITNESS: I believe so, ma which was Page 216 1 the modeling agency. 2 BY MR KUVIN: 3 Q. Okay. Did you ever learn why the name . 4 ?Apr 5 MR. PIKE: Form. 6 THE WITNESS: No. 7 :BY MR. KUVIN: 8 Q. Okay. Mr. Epstein's initials are 9 • obviously E, right? 10: A. Yes. 13. Q. Okay. Do you know what E equal ma means? 12 Did you ever hear that phrase before? 13 A. Yes. 14 Q. Okay. Now, with respect to the message in 15 the top-right corner of Exhibit 15, what is the 16 content of the message there? 17 MR. PIKE: Form. 18 THE WITNESS: It says LC2models.com; 19 . MC2models can was already taken. 20 BY MR.1CUVIN: 21 Q. Okay. Do you know whether or not Jean Luc 22 was working on his modeling agency with Mr. Epstein? 23 MR. PIKE: Form, speculation. 24 BY MR. KUVIN: 25 Q. In other words whether they were partners 2: 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in the operation of the modeling agency? A. That I don't know. MR. PIKE: Form. . MR. KUVEN: Okay. Let's mark 16. (Plaintiffs Exhibit No. 16 was marked for identification.) • BY MR. KUVIN: Q. Take a look at Exhibit 16. A. Yes. Q. What is the date of the message according to the pad? A. 12/9/04. Q. Before the investigation began? A Correct. Q. When you were conducting the investigation of Mr. Epstein and interviewing all of these girls that you interviewed; did you learn of events, of any events that were occurring involving underage girls going back into 2004 and 2003? MR. PIKE: Form. BY MR. KUVIN: Q. In other words did all these events that were described in the probable cause affidavit occur in 2005 or did they occur prior to that? A. They occwred prior to that. Page 218 MR. PIKE: Form. BY MR. KUVIN: Q. Okay. So, is it safe to say that when Mr. Goldsmith is calling Mr. Epstein in roughly December of 2004, that that period of time is within the time frame that some of the girls described that Mr. Epstein was bringing underage girls to the house? MR. PIKE: Form. • THE WITNESS: anted. BY MR. KUVIN: Q. Did you ever come to learn whether or not Mr. Goldsmith was at Mr. Epstein's home when underage girls were there? MR. PIKE: Form. THE WITNESS: That never came up. BY MR. KUVIN: Q. Okay. Did you ever come to learn why Mr. Goldsmith was calling Mr. Epstein so much — MR: PIKE: Form. MR. KUVIN: During this period of time from December through March. MR. PIKE: I'm sorry. BY MR. KUVIN: Q. - from December through Marc h of 2004 and 23 (Pages 215 to 218) . "(561) 832-750.0 PROSE COURT REPORTING AGENCY, INC. • ' Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-1081-016-b3b7.dcda51494142 EFTA00298316 Page 219 Page 221 1 2005? . 2 MR. PIKE: Fomi. 3 THE WITNESS: No. 4 (Plaintiffs Exhibit No. 17 was marked for 5 identification.) 6 MR. KUVIN: Let's take a look at 17. 7 MR. PIKE: Can I see that for a second? 8 BY MR. KUVIN: 9 Q. Exhibit 17. 10 A. She may be gone. 11 MR. PIKE: Kathy, are you gone? 12 BY MK KUVIN: 13 Q. Looking at Exhibit 17, does it appear that 14 there was another message from Mr. Goldsmith? 15 A. Yes, sir. 16 Q. What was the date of that one? 17 MR. PIKE: Form. 18 THE WITNESS: January 9th, 2005. 19 (A discussion was held off the record.) 20 MR. KUVIN: Okay. Let's take a look at 21 Exhibit 18. 22 (Plaintiffs Exhibit No. 18 was marked for 23 identification.) 24 BY MR. KU-VW: 25 Q. Let me take a quick look and see why I was Page 220 1 asking about that one. There is a massage there on 2 the left from David Copperfield. Do you see that? 3 MR. PIKE: Forth. . 4 171E WITNESS: Yes, sir. 5 BY MR. KUVIN: 6 Q. What's the content of the message? 7. MR. PIKE: Form. THE WITNESS: "It's Jackpot." 9 BY MR. KUVIN: 10 Q. It's Jackpot, correct? 11 A. Yes, sir. 12 Q. Did you ever come to learn what that might 13 be referring to? . 14 A. No. 15 Q. What's the date of that message? 16 A. January 22nd, 2005. 17 MR. PIKE: On the pad. 18 BY MR. KUVIN: • 19 Q. According to the pad, correct? 20 A. Yes, sir. 21 MR. KUVIN: Okay. 19. 22 (Plaintiffs Exhibit No. 19 was marked for 23 identification.) 24 MR. KUVIN: Let me take a look at it. 25 THE WITNESS: Yes. sir. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. KUVIN: Q. Mere are two of them I wanted to ask you about. The bottom left corner, it's another message from Mr. Goldsmith, correct? A. Yes, sir. Q. What's the date of that — MR. PIKE: Form. BY MR. KUVIN: Q. — according to the message pad? A. According to the pad it states January 25th, 2005. Q. And the message to the right, do you see that? A. Above it? Q. To the right. A. To the right. Q. Do you see how there is a section that appears to be whited out? A. Yes, sir. Q. Do you remember whether or not the original of that actually had someone's name there? A. It might have. We — I didn't white anything out. Q. Do you know if the State Attorneys may have whited stuff out? MR. PIKE: Form. THE WITNESS: It's possible. MR. KUVIN:. Okay. (Plaintiffs Exhibit No. 20 was marked for identification.) MR. KUVIN: 20. You can put that with the rest. MR. PIKE: I think Mr. Edwards wanted to take a look at that. MR. KUVIN: Do you want to see this? (Telephone interruption.) MR. KUVIN: We kept going, sorry. MS. EZELL: No, I want you to. I'm sony. My phone is just copping out today. MR. KUVIN: That's all right We're still going. MS. EZELL: Good. MR. KUVIN: Take a look at what we have marked as Exhibit 20. THE WITNESS: Yes, sir. BY MR. KUVIN: • Q. All right. In the top right corner there is a message there. Could you tell us what that message according to the pad is? R. MR. PIKE: Form. Page 222 I 24 (Pages 219 to 222) PROSE COURT REPORTING 'AGENCY, INC. . ' Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 lia2;15ddb-fa81-4ff6-1)3b7-dcda51494142 EFTA00298317 Page 223 1 THE WITNESS: The top right coma is a 2 message from the Duchess of York. 3 MR. PIKE: Kathy, can you hit mute on your 4 phone? MS. EZELL: I can't on this one. I'm 6 going to another room. 7 MR. KUVIN: All right 8 MS. EZELL: Okay. 9 BY MR. KUVIN: 10 Q. And the date on that message is what? 11 A. January 25th, 2005. 12 Q. And is there a number left there? 13 A. Yes. 14 Q. And what's the content of the message? 15 • A. She's expecting your call. 16 Q. Did you ever come to learn why the Duchess 17 of York may be contacting Mr. Epstein? 18 A. No. 19 MR. KUVIN: rn show you what we'll mark 20 as Exhibit 21. 21 (Plaintiffs Exhibit No. 21 was marked for 22 identification.) 23 BY MR. KUVIN: 24 Q. If you take a look at Ethibit 21, message 25' on the bottom. It looks like the person who it came Page 224 1 from has been deleted, but is there a date on there? 2 A. Yes, sir. 3 Q. What's the date according to the pad? 4 A. According to the pad it states 1/29/05. 5 Q. And what is the content of the message at 6 the bottom there? 7 A. I have 2 females for him. 8 MR. PIKE: May I see that? 9 THE WITNESS: Yes, sir. 10 MR. PIKE: I believe that that 11 mischaracterizes the language of the exhibit 12 Just for purposes of the record, it says: I 13 have a female for him. 14 THE WITNESS: A? 15 MB. PIKE: There is no Son female. 16 BY MR. KUVIN: 17 Q. Take a look. Do you agree with that? 18 MR. PIKE: There is still a form objection 19 to the question, so I am not waiving„ and I am 20 just correcting the language of the exhibit 21 because it's clear there is no S on the end of 22 the word female to make it plural. 23 MR. KUVIN: And it uses the singular A if 24 you wanted to be grammatically correct about 25 it. I don't know. It could be a 2 or it could 1 be an A. 2 BY MR. KUVIN: 3 Q. Can you tell whether or not ifs the 2 or 4 the letter A? 5 A. It looks like a 2 that I would write so... 6 Q. Okay. 7 A. I don't know. MR. KUVIN: All right. Fair enough. 9 We'll let the document speak for itself on that 10 issue. Let me show you what we'll mark as 22. 11 (Plaintiffs Exhibit No. 22 was marked for 12 identification.) 13 BY MR. KUVIN: 14 Q. 22 appears to be any additional messages 15 according to the pad for Mr. Goldsmith. 16 A. Yes. 17 Q. Is it Goldsmith or Goldberg? I've 18 forgotten now. 19 A. Goldsmith. 20 Q. Goldsmith, thank you. All right. At some 21 point last year did you come to learn — well, let 22 me back up. Eventually did you come to learn that 2 3 Mr. Epstein pled guilty to certain charges — 24 A. Yes. 25 Q. — criminal charges — Page 226 1 A. Yes, sir. 2 Q. — against him where he was put in jail 3 fora period of time? 4 A. Yes, sir. 5 Q. And after that point in time, did you conic 6 to leant that he was on supervised release with 7 probation? 8 MR. PIKE: Fenn. 9 THE WITNESS: Yes, sir. 10 BY MR. KUVIN: 17. Q. And did you come to leant the terms of 12 that probation; in other words what he could or 13 could not do as far as the community control was 14 concerned? 15 A. I believe it was house arrest. 16 Q. All right_ At any time that you can 17 recall in 2009, did you cornett:deem that 18 Mr. Epstein was not at his house? 19 MR. PIKE: Form. 20 THE WITNESS: Yes. 21 BY MR. KUVIN: 22 Q. Tell me about that. 23 A. While driving in the Town of Palm Beach down 24 along South Ocean Boulevard, I saw Mr. Epstein and his 25 bodyguard walking along South Ocean Boulevard along, PROSE COURT REPORTING 25 (Pages 223 to 2 2 6) AGENCY, INC. Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkIns (601 Electronically signed by cynthla hopkIns (601 aa2a5ddb-fa81.4ff6•b3b7-dcda51494142 EFTA00298318 Page 227 Page 229 1 along South Ocean Boulevard. 2 Q. All right. Did you notify Captain Frick? 3 A. I notified my supervisor, Sergeant Silvestri 4 who was with Captain Frick at the time. 5 Q. Okay. Did you take any photographs of 6 Mr. Epstein when you saw him? 7 A. Yes, sir, I did. 8 MR. KUVIN: All right. Let's go ahead and 9 well mark Exhibits 23 and 24. 10 (Plaintiff's Exhibit No's 23 and 24 was 11 marked for identification.) 12 BY MR. KUVIN: 13 Q. All right. Take a look at what we have 14 marked as 23 and 24. Are those copies of 15 photographs that you took? 16 A. Yes, sir. 17 Q. All right. Do those photographs show 18 Mr. Epstein as you saw him that day? 19 A. Yes. 20 Q. And where did you see him? 21 A. This was taken in the area of Australian 22 Avenue and South Ocean Boulevard. 23 Q. Okay. South Ocean Boulevard being along 24 the ocean? 25 A. Yes. Asa matter of fact I was standing right 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. PIKE: Form. MR. KUVIN: — on that day? MR. PUCE: Form. THE WITNESS: I believe he stated he was walking to work. BY MR. KUVIN: Q. Do you knovv how far it is from Mr. Epstein's home on El Brillo way to the building, we're at today where he supposedly has an office? A. I'd have to say several miles. Q. Is Ocean Drive in the direction of his house and this building here? A. No. Q. Is it, in fact, in the opposite direction towards the ocean? A. Yes. Q. And Mr. Epstein's home is on the Bay? A. On the Intracoastal side. Q. Gotcha. Based on where you saw Mr. Epstein walking, did you believe that this was a violation of his probation? MR. PIKE: Form. THE WITNESS: That's what I had thought which is why I notified my supervisor. Page 228 1 on the ocean wall when this one was taken. 2 Q. That one being 24? 3 A. Correct. Q. Did Mr. Epstein see you taking the 5 photographs as far as you know? 6 A. I have no idea. 7 Q. Okay. Was there a memorandum to the town 8 that was issued as a result of this incident? 9 A. I know that Captain Frick spoke with 10 Mr. Epstein at Clark and South Ocean, Clark Avenue and 11 South Ocean in the Town of Palm Beach. And I understand 12 that Captain Frick spoke with, I don't know her fast 13 name, but 1 know her last name is Sloan (phonetic). 14 Q. Okay. 15 A. From the Department of Corrections. 16 MR. PIKE: Form. 17 MR. KUVIN: Okay. 18 BY MR. KUVIN: 19 Q. Did you come to team - 20 ' MR. PIKE: Sony, Spencer, I want to get 21 form to that. It's kind of like a race between 22 question and answer. So form to that one. 23 BY MR. KUVIN: 24 Q. Did you come to learn what excuse 25 Mr. Epstein gave for being along Ocean Drive -- Page 230 1 (Plaintiffs Exhibit No. 25 was marked for 2 identification.) 3 BY MR. KUVIN: 4 Q. All right. Let me show you what we have S marked as Fathibit 25. • 6 MR. PIKE: Wait a second. Did you fmish 7 your response? 8 THE WITNESS: Yes. 9 BY MR. KUVIN: 10 Q. While they are looking at that, do you 11 know how far Mr. Epstein's home is from any church 12 or school? . 13 MR. PIKE: Fonn. 14 THE WITNESS: Ifs over a thousand feet. 15 I blow that. 16 BY MR. KUVIN: 17 Q. Do you know what the closest church or 18 school is in that area of the island? 19 MR. PIKE: Form. 20 THE WITNESS: The school would be, the 21 closest school would be Crippled Children's 22 Society which is on Royal Palm Way. The church 23 would be Bethesda by the Sea. 24 MR. KUVIN: Okay. 25 THE WITNESS: Which is further, even 26 (Pages 227 to 230 PROSE COURT REPORT ING . AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb•fa8141f6-b3b7-dcda51494142 EFTA00298319 Page 23'1 Page 233 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 BY MR. KUVIN: 2 Q. Okay. Are there any additional 3 conversations that you can recall having withM 4 that we haven't already discussed? 5 We've recounted two conversations that you 6 can recall with her. 7 A. Right. 8 Q. One is at the school where we talked about 9 where she broke down. The second one is when she 1o.• explained to you the circumstances that you had in 11 the probable cause affidavit. I was wondering if 12 there was anything else. 13 MR. PIKE: Form, move to strike. 14 THE WITNESS: I spoke, 1 believe, briefly 15 with her father. I delivered a letter to her 16 home and hand delivered it to her father. 17 BY MR. KUVIN: 18 Q. • And what was that letter? 19 A. It was letter drafted by former Chief Reiter. 20 Q. What did it discuss? 21. A. It was a letter — 22 • MR. PIKE: Form. 23 THE WITNESS: — that he had generated to 24 the parents of the victims. 25 illaNACEISaaa•MKAMA PROSE further north. BY MR. KUVIN: Q. Further north. Do you know if part of his conviction as a sexual offender prevents him from being a certain distance from schools or churches? MR. PIKE: Form. THE WITNESS: I believe so. But his residence is within compliance. BY MR. KUVIN: Q. Okay. During your investigation, while they are still looking at that, did you ever speak with a girl by name of that you can recall? A. No. Q. Did you ever discuss with, all of the girls that she may have brought? you ever have a chance to get into that conversation with her? MR. PIKE: Form. THE WITNESS: Obviously I asked that same question to everyone I interviewed. MR. KUVIN: Right. THE WITNESS: Some girls I was able to identify. And other girls I couldn't identify. The name was so common I couldn't pinpoint, but, no, the name does not ring a bell. Page 232 1 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. KUVIN: Q. Do you remember the content of that letter, generally what it said? A. It was basically — . MR. PIKE: Fonn. THE WITNESS: II minter looking at it. I looked it over prior to delivering them. It mentioned that the case would probably — this is after the grand jury, after the arrest MR. KUVIN: Right THE WITNESS: That the case would be referred to the FBI to see if there was any federal nexus to it. BY MR. KUVIN: Q. So this was after the referral to the FBI? A. Yes. Q. Befogsget back to Exhibit 25, just briefly again= that name in particular, do you know whether she was a part of any of the federal investigation? A. I have no idea. Q. All right If she was not of your investigation and not a part of the federal investigation, as you sit here today do you know whether or not additional charges may be brought Page 234 1 against . Epstein based upon the acts alleged by 2 Ms. 3 MR. PIKE: Form. 4 BY MR. KUVIN: Q. Do you know? 6 A. 'have no idea. 7 Q. Do you know what the Statute of 8 Limitations is for a sexual assault or a sexual 9 battery?' 10 A. I )(now under 12 there is no statute of 11 limitations, however — 12 Q. We're talking about 15. 13. MR. PIKE: Form. 14 MR. KUVIN: With person over the age of 15 15. 16 MR. PIKE: Wait a second. I believe the 17 witness is attempting to respond. So if he has 18 a response, please less him respond and don't 19 inte.nupt him. 20 BY MR. KUVIN: 21 Q. Fair enough. I am looking for whether or 22 not you know the Statute of Limitations for the 23 prosecution fora person over 15. 24 A. I believe it's five years. 25 Q. Okay. Am I correct in sayinetaszou sit .,„ te 27 (Pages 231 to 234) COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a6ddb-141-4(16-b3b7-dcda51494142 EFTA00298320 Page 235 1 here today you don't know whether or not was a 2 part of the ultimate nonprosecution agreement that 3 was entered into with Mr. Epstein and the federal 4 authorities? S . A. I have no idea. 6 Q. Okay. All right. Take a look at Exhibit 7 25. Let me ask you generally while you're looking 8 at that, have you ever seen that before today? 9 A. No. 10 Q. Then that's going to limit a lot of my . 11 questions. Do you appear anywhere in that summary 12 that you can tell? 13 MR PIKE: I am sorry, what exhibit number 14 is that? 15 MR. KUVIN: Twenty-five. 16 THE WITNESS: Twenty-five. 17 MR. PIKE: I just want the record to 18 reflect it. 19 BY MR. KUVIN: 20 Q. And I may have missed it, but I don't see 21 • your name in there so — 22 . • A. No, I don't see it in there either. 23 Q. Were you, in fact, the one, though, that 24 saw Mr. Epstein walking along Ocean Drive? 25 A. Yes, sir. Page 237 1 Q. Do you know if the U.S. Attorney's Office 2 has developed any additional new information with 3 respect to new charges to be brought against 4 Mr. Epstein? 5 A. I have no idea. 6 Q. Has anyone shared with you information 7 with respect to what the U.S. Attorney's Office may 8 have generated through conversations with 9 Mr. Rodriguez who just pled guilty? 10 A. No,J do not. 11 Q. • Do you know whether he cut a deal and gave 12 over additional information to the U.S. Attorney's 13 Office to bring additional charges against 14 Mr. Epstein? 15 A. No, sir. 16 Q. Are you aware of any girls that 17 Mr. Epstein has trafficked across state lines? 18 MR. PIKE: Form. 19.. THE WITNESS: No,. sir. 20 BY MR. KUVIN: 21 Q. Are you aware of any young girls wider the 22 age of 18 that he may have brought onto his jets or 23 planes? 24 .MR. PIKE: Form. 25 THE WITNESS: No, sir. Page 236 1 MR. PIKE: Fonn, asked and answered. 2 BY MR. KUVIN: 3 Q. And you called it into your superior at 4 the time? 5 MR. PIKE: Asked and answered. 6 THE WITNESS: Correct 7 BY MR. KUVIN: 8 ill you know a woman by the name of at the State Attorney's office? 10 A.. Yes. 11 Q. Did you speak with her at the U.S. 12 Attomey's.Office about your investigation? 13 A. One time I spoke with her. 14 Q. Okay. Has she contacted you at all 15 recently? 16 A. No. 17 Q. Do you know whe an r w girls 18 have met with or spoken to with the 19 U.S. Attorney's Office? 20 MR. PIKE: Form. 21 THE WITNESS: Not that I am aware of 22 BY MR KUVIN: 23' Q. Do you know whether B.B. has now spoken 24 and interviewed with the U.S. Attorney's Office? 25 A. Not that Pm aware of. 1 2 3 4 5 6 7 8 9 ' 10 11 12 13 14 15' 16 17 18 19. 20 21 22 . 23 24 25 Page 238 BY MR. KUVIN: Q. Okay. Do you know whether or not the U.S. Attorney's Office has that type of information one way or the other? MR. PIKE: Form. THE WITNESS: I have no idea. BY MR. KUVIN: Q. Okay. Do you know whether or not Mr. Epstein Ina a security company now working at his house called Wackenhut? A. Yes. Q. Do you know when they were retained? A Shortly, shortly after. his release from the county jail. Q. Okay.. A Or just prior to his release. One or the • other. . Q. During the search warrant, was any terminal used to chock for DNA throtighout the house? MR. PIKE: Form. • • THE WITNESS: Not 100 percent, not in the house. I believe the massage table. BY MR. KUVIN: Q. How were the massage tables checked? MR. PIKE: Fonn. 28 (Pages 235 to 238) .1561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601 Electronically signed by cynthla hopkins (601 Electronically signed by cynthla hopkins (601 aa2a6ddb.fa81-4f16-b3b7-dcda51494142 EFTA00298321 Page 239 THE WITNESS: That you will probably have 2 to refer to Mr. Parkinson on that, Greg 3 Parkinson, 4 BY MR. KUVIN: Q. And he is who? 6 A. The manager at the crime scene unit. 7 Q. Okay. Do you know whether the FBI also 8 took video surveillance at all of Mr. Epstein? 9 Mk PIKE: Form. 10 THE WITNESS: I have no idea. 11 BY MR. KUVIN: 12 Q. Did any of the surveillance video that you 13 or your department took of Mr. Epstein show any of 14 the potential victims that are listed in your 15 probable cause affidavit? 16 MR. PIKE: Form. 17 THE WITNESS: The surveillance log, i 18 remember there were some people that were 19 interviewed because of their recent visits to 20 Mr. Epstein's home that appeared to be young 21 females. 22 BY MR. KUVIN: 23 Q. On the surveillance video? 24 A. Yes. Well, it would have been under the 25. surveillance of either B.S.F. or surveillance video, one Page 241 1 Q. All right. What's beneath the blacked out 2 portions since you created this document, if you 3 know? 4 A. The names and cellular phone numbers of the 5 girls that were interviewed. 6 jail So, did you confirm that, in fact, 7 was calling some of the girls you 8 interviewed? 9 MR.PLICE: Form. 0 THE WITNESS: Yes. 11 MR. KUVIN: Let's mark this as 27. I 12 think 27 — I will have you explain it — is a 13 copy of the letter that you delivered that you 14 mentioned before to C.L. 15 (Plaintiff's Exhibit No. 27 was marked for 16 identification.) 17 BY MR. KUVIN: 18 Q. Take a look at Exhibit 27. Is that a copy 19 of the letter you hand delivered to C.L.? 20 MR. PIKE: Form. 21 THE WITNESS: That is correct. 22 BY M. KUVIN: 23 Q. Okay. All right, I think I am about done 24 but I just have to ask: Did you have anything to'do 25 with the incident involving Gerald() Rivera? Page 240 or the other. 1 2 Q. Who is Michelle Pagan? 2 3 A. Michelle Pagan is an officer with the Town of 3 4 Palm Beach Police Department. 4 5 Q. That's right. I'm sorry. I forgot. 5 6 (Plaintiffs Exhibit No. 26 was marked for 6 7 identification.) 7 8 BY MR. KUVIN: 8 9 Q. Let's take a look at what's been marked as 9 10 Exhibit 26, and if you could explain what this 10 11 document is. Would you explain what that document 11 12 is, Exhibit 26? 12 13 A. That was a document I created just to show 13 14 der rs, either called in or called out 14 15 from cellular phone. 15 16, Q. Okay. There are some things blacked out 16 17 on there. Why are they blocked out? 17 18 MR. PIKE: Form. 18 19 BY MR. KUVIN: 19 20 Q. Let me ask you this: Did you black them 20 21 out? 21 22 A. No, l did not. 22 23 Q. Does the original of this document have 23 24 that information on it? 24 25 A. Yes. 25_ at, PROSE COURT REPORTING Page 242 MR. PIKE: Form. THE WITNESS: No. BY MR. ICUVIN: Q. No. Did you come to team at any time that Gerald° Rivera was standing outside of Mr. Epstein's home -- MR. PIKE: Form. BY MR. KUVIN: Q. And someone called 911? Did you hear about that? MR. PIKE: Form. . THE WITNESS: Iheard rumors about that in the police department, but no, I had no involvement or knowledge of that. BY MR. KUVIN: Q. Okay. Do you know if that occurred while he was in jail or after he had been released on house arrest? A. I have no idea. . MR. KUVIN: Okay. All right. I appreciate it. That's all the questions I have at this time. MR. EDWARDS: Who is up? MR. PIKE: Take a quick break off the Jeard. Everybody agree? 29 (Pages 239 to 242) AGENCY, INC.: Electronically signed by cynthla hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthla hopkins (801 aa2a5ddb.to81-4I16-b1b7-dcda51494142 EFTA00298322 Page 24 Page 245 MR. EDWARDS: Yes. 2 (A brief recess was held.) 3 (Plaintiffs Exhibit No. 28 was marked for 4 identificatica.) 5 CROSS (DETECTIVE JOSEPH RECAREY) 6 BY MR. EDWARDS: 7 Q. Good afternoon, Detective. 9 A_ Good afternoon. 9 Q. I have just handed you what we have marked 10 as Plaintiffs Exhibit 28. And I will show it to 11 defense counsel. Have you seen that document 12 before? 13 A. Yes. 14 Q. What's the date on that? 15 A. 11/28/04. 16 Q What is that document? 17 A. The Palm Beach Police Department Intelligence 18 Report. 19 Q. What is an Intelligence Report? 20 A. It is a report that is generated by an officer 21 on any information received not deemed to be an incident 22 report; something for detectives to follow-up on. 23 Q. Okay. Who's the officer that was the 24 author of that report? 25 A. It would be Keith Munyan. Page 244 1 Q. And have you spoken with Keith Munyan, 2 fist question is about anything related to Jeffrey 3 Epstein or the investigation? 4 A. I know fora time there was a time where he 5 was on B.S.F., the Burglary Strike Force, that conducted 6 the surveillance. 7 Q. Okay. 8 A. But actual conversation with him regarding the 9 investigation, no. 10 Q. Did you ever have a conversation with 11 Officer Munyan at any time from the beginning of the 12 world until today about that particular report that 13 was authored in November of 2004? 14 A. No, I did not. 15 (Mr. Epstein entered the deposition room.) 16 BY MR. EDWARDS: 17 Q. From my understanding of the previous 18 testimony, the investigation of Mr. Epstein began 19 sometime in March of 2005 upon a telephone call by 20 some relative o1 21 A. Correct. 22 Q. And it's also my understanding that your 23 testimony was it was your belief that that was the 24 first knowledge that the police department had of 25 possible interactions with underage girls by Jeffrey 1 Epstein; is that correct? 2 MR. PIKE: Form. 3 THE WITNESS: Knowledge to me. 4 MR. EDWARDS: Okay. 5 THE WITNESS: lam — as far as the police 6 department I have no idea when. Obviously this 7 was prior to the investigation; however, this 8 was not a public record report that was passed 9 around from officer to officer to officer. 10 MR. EDWARDS: All right. So — 11 THE WITNESS: When this is evaluated by 12 the supervisor and submitted, this actually 13 goes to independent units. 14 BY MR. EDWARDS: 15 Q. And do you know what supervisor that 16 particular November, 2004 — what are we calling it 17 again? 18 A. Intelligence report 19 Q. Intelligence report. Do you know who the 20 supervisor would have been at the time? 21 A. It looks like it might have been at that point 22 Sergeant Maio. That looks like his initials. 23 Q. Is Sergeant Maio somebody that you have 24 had any conversations with related to the 25 investigation into Jeffrey Epstein? Page 246 1 A. No. 2 Q. All right. The first time that you saw 3 that particular report that you're looking at, 4 Plaintiffs Exhibit 28, do you remember when that 5 was? 6 A That would have been after my investigation 7 began. 8 Q. Okay. After your investigation began 9 which would have been September of 2005? 10 A Correct. 11 Q. Do you know if -- well, when you reviewed 12 all of the materials to catch yourself up to speed, 13 I believe you testified that that was initially done 14 by Officer Pagan? 15 A. Correct. 16 Q: When you reviewed all of the materials to 17 catch yourself up to speed with the investigation, 18 was that particular report included in those 19 materials? 20 A. No, it was not 21. Q. So Plaintiffs Exhibit 28 is something 22 that was produced to you or shown to you sometime 23 after your investigation into Jeffrey Epstein began 24 in September of 2005? 25 A. Correct PROSE COURT REPORTING 30 (Pages 243 to 246) AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb fa81-016.b3b7-dcda51494142 EFTA00298323 Page 247 1 Q. And do you remember if it was before or 2 after the execution of the search warrant in October 3 of 2005 that you first saw that document? 4 A I don't know the exact date that I was shown 5 this document, but I )(now that I would have liked to 6 have it prior to my interview with the person that I 7 interviewed on this case. 8 Q. Are you talking about Jane Doe No. 103? 9 A. Correct. 10 Q. She's the person that was allegedly, 11 according to this report that's been marked as 12 Plaintiffs Exhibit 28, was at Jeffrey Epstein's 13 house in November of 2004? 14 MR. PIKE: Form. 15 THE WITNESS: That is correct. 16 BY MR. EDWARDS: 17 Q. And from what I understand based on the 18 report, house manager Alfredo Rodriguez, calls the 19 police because of a suspicious vehicle in Jeffrey 20 Epstein's driveway? 21 MR. PIKE: Form. 22 THE WITNESS: Correct. 23 BY MR. EDWARDS: 24 Q. Officer Munyan is the one reporting to the 25 scene and finds Jane Doe No. 103. Page 244 I tour. It might be just after the ending of their tom. 2 They're jotting information down. They provide it to 3 the supervisor. The supervisor then initials off on the 4 bottom of it. 5 And then it gets disseminated to what is 6 now the Organized Crime/Vice and Narcotics Unit. It 7 is the sergeants responsibility then of that unit 8 to disseminate it to other units depending on the 9 information provided. 10 Obviously, if it, if this contained 11 information on narcotics, it would stay with 12 Organized Crime/Vice, and Narcotics. If it had 13 information on gypsy thefts, it would go to the 14 detective bureau. If it had an officer safety 15 information, you know, I stopped a kid and he had a 16 necklace with a, if you pulled it apart and it 17 became a knife, then it would go to the entire 18 police department. 19 Q. Okay. And do you know how that document 20 was disseminated or to which department it went? 21 A. This was disseminated to the Organized 22 Crime/Vice and Narcotics Unit. 23 Q. Why is that? 24 A. I don't know. 25 MR. PIKE: Form. Page 248 1 A. Correct. 2 MR. PIKE: Form. 3 BY MR. EDWARDS: 4 Q. Then you read the officer's comments 5 within the report about, you know, what muscle is 6 she massaging. And maybe that's not a direct quote 7 but that's from memory. 8 Seems like there is some idea on his 9 behalf that something was going on inside the house 10 that may not be correct, is that right? 11 MR. PIKE: Form, move to strike, compound, 12 confusing, leading, speculative. 13 MR. EDWARDS: If you understand that bad 14 question, go ahead. 15 l'HE WITNESS: ft appears that he came up 16 with his own opinion. 17 BY MR. EDWARDS: 18 Q. Okay. And when a report like that is 19 drafted, and you say is it always turned ova to the 20 captain or the sergeant? 21 A. Usually when an officer completes an 22 intelligence report in the Palm Beach Police Department, 23 they give it to their direct supervisor or the next 24 oncoming shift supervisor. The intelligence report may 25 or may not be completed during their shift, during their zw•Yel•MI.ms.A.VIC4C.C..“ MVO.. •Yi•••••, :•, "., ....•••..S•b1•14[10•••••Saillia Page 250 1 THE WITNESS: I don't know. That was — 2 the supervisor at that particular time kept it 3 within Organized Crime. 4 BY MR. KUVIN: 5 Q. Do you know if there was any internal 6 follow-up to that report done by the Palm Beach 7 Police Department? 8 MR. PIKE: Form. 9 THE WITNESS: Not that frn aware of. 10 BY MR. KUVIN: 11 Q. You have obviously seen that intelligence 12 report You have been presented with that 13 intelligence report sometime after your 14 investigation. Have you ever gone back to look was 15 there a follow-up to that report? 16 A. I did look to see if there was a follow-up on 17 that report, and there was not much of a follow-up done 18 on it. 19 Q. Did you see any follow-up that — 20 A. I — 21 Q. —at all? 22 A. I believe that they attempted to contact 23 Ms. Jane Doe No. 103 several times with negative 24 results. 25 Q 31 (Pages 247 to 250) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-fa81-4116-b3b7-tkda51494142 EFTA00298324 Page 253 3 4 5 6 7. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 251 MR. PIKE: Form. BY MR. EDWARDS: Q. Is there any documentation memorializing those telephone calls? MR. PIKE: Form. THE WITNESS: I don't believe so. BY MR. EDWARDS: Q. Why do you believe that they attempted to contact her with negative results? MR. PIKE: Form. THE WITNESS: Because the person that was assigned to this, I spoke with who is now sergeant, Sergeant 'Crawl. And he said he attempted to contact her on several times to discuss with her this case. BY MR. EDWARDS: Q. I don't know that I can put my finger on the exact document right now, but I believe I read something and Fm not sure if it was authored by you or Chief Reiter about information back as early as 2001 of young females frequenting Mr. Epstein's house. Do you recall seeing something like that? MR. PIKE: Form. THE WITNESS: Them may have been some information received. There may have been some 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. EDWARDS: Q. Okay. So, 1 am just going to direct your attention to the document that is tabbed 2001 on Page 2. A. Correct. Q. So flip it to Page 2, and just read that paragraph that begins with the information in 2001. Okay? A. Okay. Q. Have you seen that information before? A. Like I said, I had heard that there was previous indications of young females frequenting the house, but it was my understanding that it was Palm Beach Atlantic college girls coming over. Q. And would there be a file with the Palm Beach Police Department related to any investigation, interviews, surveillance, or any other evidence that was discovered during that 2001 investigation? A. Not that I am aware of. Q. It appears from reading that document that there were interviews taken, correct? MR. PIKE: Form. THE WITNESS: It appears. 1 2 3 4 5 6 8 9 10 11 12 13. 14 15 16 17 18 19 20 21 22 23 24 25. Page 252 information received as to females young in appearance visiting or frequenting Mr. Epstein's home earlier than that, but I believe that was deemed to be Palm Beach Atlantic College kids back then. BY MR. EDWARDS: Q. Okay. And as early as 2001 it was reported to the Palm Beach Police Department there were numerous young women visiting his residence. And you're testifying that those youth women, to the best of your knowledge, were determined to be college kids? MR. PIKE: Form. THE WITNESS: I believe so. BY MR. EDWARDS: Q. So, there were interviews taken into the • 2001 information that was delivered to the police department related to these young women, correct? MR. PIKE: Form. THE WITNESS: I'm not sure. MR. EDWARDS: All right. Might as well go ahead and use a couple of stickers that we have there. You might want to show him Page 2. 3/28/02 is the date on this. Page 25 1 BY MR. EDWARDS: 2 Q. It also appears that there was 3 surveillance? 4 A. Correct 5 MR. PIKE: Fonn. 6 BY MR. EDWARDS: 7 Q. And thafs a document that's being 8 generated years later, correct? 9 MR. PIKE: Form. 10. THE WITNESS: Yes, sir. 11 BY MR. EDWARDS: 12 Q. So, just based on your knowledge and 13 experience as a police officer or a detective, do 14 you have any idea where that information or evidence 15 would be kept or stored if at all? 16 A. I have no idea. 17 Q. Okay. If I wanted to find out related to 18 that specific incident, terntse I know we did a 19 Florida request, and I believe it was all 20 information related to Mr. Jeffrey Epstein. And for 21 the most part we only got information related to 22 this particular investigation that you were a part 23 of. 24 Is there some other designation that I 25 need to send to the Palm Beach Police nt to 32 (Pages 251 to 254) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801 Electronically signed by cynthia hopkIns (801 Electronically signed by cynthia hopkins (801 aa2a5dclb-th81-4n4037-ciccia514941412 EFTA00298325 Page 255 1 get information about a 2001 investigation? 2 MR. PIKE: Form. 3 THE WITNESS: I have no idea. You might 4 want to check with the custodian of records, 5 Laura Oregero. 6 BY MR. EDWARDS: 7 Q. Okay. And why do you believe that this 8 particular 2001 investigation related to college 9 students? 10 MR. PIKE: Form. 11 THE WITNESS: Because I recall, I recall 12 someone, and I can't, I don't know who exactly 13 stated that there was information years prior 14 of girls going to the house, but it turned out 15 it was all college girls coming to work for 16 Mr. Epstein at the residence. 17 MR. PIKE: Form, move to strike. 18 BY MR. EDWARDS: 19 Q. And are you aware of what these college 20 girls were doing in terms of work? 21 A. I have no idea. 22 MR. PIKE: Form. 23 BY MR. EDWARDS: 24 Q. All right. The term work and the term 25 matcnee has been used by you and many other 1 2 3 4 5 0 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 256 witnesses in this particular case. And by that, by those terms is it your understanding that those terms refer to the scenario wherein Jeffrey Epstein pays underage girls to ;Amorally assault them? MR. PIKE: Form. THE WITNESS: As far as the case that I investigated, 05368, the girls referred to it as work. And when I asked, because i, in my interviews I asked them what do you mean work, and that's what they referred it to. BY MR. EDWARDS: Q. When you say that's what — I mean I was trying to shorten it because I have listened to you testify about many girls, the same scenario over and over again. But are we talking about — well, I will let you put it in your own words. When the girls said I am going to Jeffrey Epstein's house to work, what did they ultimately elaborate and tell you what that meant? . MR. PIKE: Form, move to strike, narrative and leading. THE WITNESS: Providing massages whether them being naked or partially clothed, and some obviously being fondled or touched. Page 257 1 BY MR. EDWARDS: 2 Q. Okay. And I believe you told us in your 3 background you worked in narcotics before? 4 A. Yes, sir. 5 Q. in narcotics specifically, are there code 6 words that are used related to criminal activity? 7 MR. PIKE: Form. 8 111E WITNESS: Yes. 9 MR. PIKE: Relevance. 10 BY MR. EDWARDS: 11 Q. When people talk over the telephone about 12 what kinds of drugs they are selling and things like 13 that, is it your training and experience that code 14 words are often used? 15 A. Correct 16 MR. PIKE: Form 17 BY MI!: EDWARDS: 18 Q. In this particular case regarding Jeffrey 19 Epstein, the words work and massage in your training 20 and experience, are those code words that were used 21 by Jeffrey Epstein and the other people working for 22 him? 23 MR. PIKE: Form. 24 -THE WITNESS: As far as I know the girls 25 all referred to it as work. I don't ;mow if Page 258 1 that is a specific code word. 2 BY MR, EDWARDS: 3 Q. Do you know where they learned that word 4 front? 5 MR. PIKE: Form. Were you finished with 6 your response? 7 THE WITNESS: Yes. 8 MR. PIKE: Okay. 9 THE WITNESS: NorI have no idea. 10 BY MR. EDWARDS: 11 Q. Well, you've looked at several message 12 pads today and the word work is used on those, 13 correct? 14 A. Correct. 15 Q. And those, that was not written by the 16 girls. Those are things that are written by Jeffrey 17 Epstein's assistants to the best of your knowledge; 18 is that correct? 19 A. Yes. 20 MR. PIKE: Form. 21 BY MR. EDWARDS: 22 Q. Regarding the message pads, were those 23 taken, were all the message pads taken at the same 24 time? 25 MR. PiKE: Form. (561) 832-7500 33 (Pages 255 to 258) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aaiascIdo-la81-488-b3b7-dcda51494142 EFTA00298326 Page 259 1 THE WITNESS: Yes. 2 BY MR. EDWARDS: 3 Q. And by taken i mean retrieved at the same 4 time? 5 A. During the search warrant. 6 Q. All right. Were any the message pads, and 7 that is what in reading the report I have had a 8 tough time deciphering, were some taken from the 9 trash pulls and some from the house or were they all 10 taken Ia the search.warrant? 13. MR. PIKE: Form. 12 'THE WITNESS: The message pads were 13 double-sided. You would write the message onto 14 its pad.. The top layer would peal off 15 depending on who the message was for, and then 16 there would be a carbon copy kept underneath. 17 And the pads that you're seeing, the majority 18 of those messages were carbon copies. 19 BY MR. EDWARDS: 20 Q. And taken when? 21 A. During the search warrant. 22 Q. All right. Were any of the messages that 23 we have copies of taken from trash pulls where it's 24 the actual message that's been crumpled up and 25 thrown away? 1 2. • 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 261 during the investigation? A Correct. Q. So, if it came down to trial would it be, would you be the person that would be able to say this is a fair and accurate representation of what was taken into evidence at this particular time? MR. PIKE: Form. THE WITNESS: Based on the trash pulls that I requested, that I conducted, yes, I would be the one. I could tell you I could see it, and that's the one that I put into evidence. • • BY MR. EDWARDS: Q. And with respect to the message pads that were retrieved during the search warrant, would you also be able to identify them and indicate whether they are a fair and accurate representation of what was taken into evidence? • • A. 'Yes. ' MR PIKE: Form. THE WETNESS: Yes. BY MR. EDWARDS: Q. And not only with respect to the message pads, but with all the evidence that is listed on your property receipt, assuming that one day we get Page 260 1 MR. PIKE: form. 2 THE WITNESS: Correct. 3 MR. PIKE: You're talking about messages. 4 Are you talking about the 2-inch stack of 5 documents that Mr. Kuvin earlier showed the 6 witness? And I am not talking, Mr. Kuvin 7 MR. EDWARDS: The format is similar to 8 that. 9 MR PIKE: Mr. Kuvin has already agreed to 10 produce them to us. Ifs not a trick. I just 11 want to understand what we're talking about. 12 Is it those message pads? 13 MR. EDWARDS: Right 14 BY /vfR. EDWARDS: 15 Q. Are those the message pads that you were 16 referring to? 17 A. Yes. 18 Q. I want to make sure that we're on the same 19 page. Were communicating. 20 A. But to answer your previous question from the 21 trash pulls, we did obtain originals, the top layer of 22 the message. 23 Q. Okay. And when documents, any papers, any 24 documents were retrieved from trash pulls and taken 25 into evidence, were those taken into evidence by you Page 262 1 to see the evidence, would you be the one to 2 identify it? 3 A. Yes. 4 MR. PIKE: Porta 5 BY MR. EDWARDS: 6 Q. And I know you have testified that the FBI 7 took possession of all of the documents and items 8 that are listed in the property receipt, right? 9 A That is correct? 10 . MR. PIKE: Form. 11 BY MR. EDWARDS: 12. Q. Did you or your department — 13 A.. Let me, let me correct that. 14 'Mar. 15 - A. The items that were returned to Janusz had 16 nothing to with the FBI. That was determined that he 17 was the rightful owner of the items collected, and that 18 was !chimed back to him and it contained no contraband 19 or any kind of images or anything like that. 20 Q. No evidence of any criminal activity that 21 you could tell? . 22 A Correct • • 23 MR. PIKE: Form. 24 BY MR. EDWARDS: ...m."22_ 2:_!......Sumn o with to items TLI.LtaLIA2re 34 (Pages 259 to 262) PROSE COURT REPORTING AGENCY.i:: INC. - Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-fa81-41f6-b3b7-ticda51494142 EFTA00298327 Page 263 1 determined to be evidence and listed on the property 2 receipt, and just so that we're clear, the documents 3 that were not Janusz Banasiak, did you or your 4 office make any copies of any of that material? 5 A. No, because I actually signed out the message 6 pads to review them. I know that the State Attorney's 7 Office was provided a copy with the filing packet. 8 Q. Okay. Do you know approximately -- well, 9 not approximately. Do you know how many messages, 10 how many message squares were retrieved or how many 11 pages from the message pads were retrieved during 12 the search warrant? 13 MR. PIKE: Form. 14 THE WITNESS: I couldn't give you an 15 accurate number. I know some were. 16 BY MR. EDWARDS: 17 Q. More than one message pad? 18 A. As far as carbon copies are concerned? 19 Q. Right. 20 A. The carbon copies, there were several books 21. taken. 22 Q. That's what I am asking. .23 A. There were several books taken. If you look 24 at the property receipt, it will say phone message book, 25 phone message book and the location where it was taken 1 2 3 4 5 6 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 265 A. No. MR. PIKE: Form. BY MR. EDWARD& Q. Were you aware of any of donations that he has ever made? A. I recall a donation he made to purchase equipment, video enhancing equipment shortly thereafter that case. Q. Okay. Are you aware of a 550,000 donation back in 2002 by Mr. Epstein that was delivered personally to Chief Reiter by Gerald Goldsmith? A. No. Q. Has anybody ever made you aware that he donated $50,000 to the Palm Beach Scholarship fund April 1st, 2002? MR. PIKE: Form. THE WITNESS: No. BY MR. EDWARDS: Q. Has anybody ever made you aware that he donated $36,000 to the purchase of a forensic video analysis system in October of 2003? A. That, that was the — MR. PIKE: Form. THE WITNESS: — video enhancing equipment Page 264 1 from. 2 Q. Okay. The way that they have been 3 presented to us, at least the copies, are four per 4 page. Is that how it appears on the book? 5 A. Yes. 6 Q. When is the first time that you had any 7 contact with Jeffrey Epstein? 8 A. I met Mr. Epstein during an investigation 9 where someone had broken into his home and stolen money 10 and I believe a firearm. And, ifl recall, I came over 11 to assist other detectives to install a covert camera in 12 hopes to catch the person breaking into the house. 13 Q. Okay. And I have seen that report 14 somewhere. And 1 think that will take a long time 15 to get into, and I don't believe we have that much 16 time, but that was sometime in 2003; is that 17 correct? 18 A. That's correct. That's the fast time I met 19 Mr. Epstein. 20 Q. Had you heard of him or known of him prior 21 to that time? 22 A. No. 23 Q. All right. Arc you aware of various 24 • donations that he has made to the Palm Beach Police 25 over the years? 1 2 3 4 5 6 7 8 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 266 BY MR. EDWARDS: Q. Okay. That's what you were just talking about? A. Yes, sir. Q. And these donations, when they have been made, is it your understanding that they are made through a company owned or controlled by Jeffrey Epstein, COUQ Foundation, Inc.? MR. PIKE: One second. Can you repeat that for the record? MR. EDWARDS: Sure. BY MR. EDWARDS: . . • Q. When the donationthat you're aware of was made, was it your understanding that it was made through the COUQ Foundation, Inc., a company controlled by Jeffrey Epstein? MR. PIKE: Form. THE WITNESS: I have no idea. BY MR. EDWARDS: Q. When these donations are made, who receives the donation? • A. The chief or the town manager. . Q. Okay. So if the chief is the one writing letters thanking Mr. Epstein, the chief would be the best person to ask about these donations? 35 (Pages 263 to 266 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia bodkins (601 Electronically signed by cynthia hopkins (601 matatddb4014fle-Mblada514.4142 EFTA00298328 Page 267 1 A. Correct 2 Q And in terms of how the records are kept, 3 copies of the checks and things ince that, that's 1 something for a record custodian or the chief, not 5 for you? 6 A. Not forme. Tints way above my pay grade. 7 Q. We talked about this November 2004 report. 8 You were not aware of that until sometime in 2005 or 9 2006, correct? 10 MR. PIKE: And for the record yotfre 11 talking about Exhibit 28, right? 12 THE WITNESS: Exhibit 28. 13 MR EDWARDS: I believe so. 14 BY MR. EDWARDS: 15 Q. Were you made aware that December, 16 December 14th, 2004, 15 or 16 days after that report 17 is generated, Jeffrey Epstein donates $90,000 for an 18 electronic firing range technology? Were you aware 19 of that? 20 A. No. 21 MR. PIKE: Form. 22 BY MR. EDWARDS: 23 Q. Do you know who it is that Jeffrey Epstein 24 talks to, if anybody, within the Palm Beach Police 25 Department back in 2004 to ultimately donate money? Page 269 1 over the telephone prior to your investigation that 2 began in September of 2005? 3 MR. PIKE: Form. 4 THE WITNESS: No. Like I said, l may have 5 introduced myself to him when I came over to 6 assist to install the camera during the 7 burglary investigation, but other than that... 8 BY MR. EDWARDS: 9 Q. When you first arrived to the house back 10 in 2003 related to the burglary, were there already 11 cameras in place? 12 MR. PIKE: Form. 13 THE WITNESS: I do not believe so. 14 BY MR. EDWARDS: 15 Q. All right So when you arrived, Jeffiey 16 Epstein was asking for your assistance in helping 17 set these cameras up? 18 A. I take that back It might have been, the 19 cameras might have already been installed as far as the 20 covert clock in the office area because that was the 21 area that was burglarized. 22 . Q. Okay. 23 A. And the only reason why I remember that is 24 because I had interference between his system and our 25 system. Page 268 1 A. Again, it would have to be the chief of police 2 or the town manager or — 3 Q. 'guess what I am asking is there any 4 coordinator of donations -- 5 A. No. 6 Q. — that works -- okay. And do you know 7 what was done with the December 14th, 2004, donation 8 made by Jeffrey Epstein? 9 MR. PIKE: Form. 10 THE WITNESS: I believe that the donations 11 were returned to him, I believe. 12 BY MR. EDWARDS: 13 Q. And by returned, they would have been 14 returned back to whatever company they were written 15 from, COUQ Foundation? 16 MR. PIKE: Font. 17 THE WITNESS: I believe. I have no idea. 18 BY MR. EDWARDS: 19 Q. And do you know if Chief Reiter and 20 Jeffrey Epstein had a relationship where they spoke 21 with each other back in 2004 and 2005 — 22 A. I have no idea. 23 Q. -- on any type of frequent basis? 24 A. I have no idea. 25 Q. Did ou ever speak with Jetitial sw ein Page 270 1 Q. All right. I am going to go back to 2 Plaintiffs Exhibit 29, same page that we looked at 3 last time related to a 2001 investigation, and ask 4 you to read the paragraph just above of that 5 paragraph we reviewed before. 6 A. Yes, sir. This paragraph we're talking about, 7 September 2005? 8 Q. Yes. Are you ready? 9 A. Yes, sir. 10 Q. Do you remember speaking with the Chiefor 11 to Jeffrey Einstein or any of his representatives 12 directly about a 2005 donation that Jeffrey Epstein 13 was calling to make? 14 A. No.' 15 Q. All right When is the first time that 16 you learned that sometime around September of 2005 17 Jeffrey Epstein was calling the police department 18 make a donation? 19 MR. PIKE: Form. 20 THE WITNESS: I didn't even know he was 21 calling in 2005 to make a donation. Like I 22 said, I have no, no involvement in that 23 whatsoever. 24 BY MR. EDWARDS: 25 Q. Okay. That's not something that Chief 36 (Pages Z67 to 270 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia honking (601 aa2a5ddbra81-4fra-b3b7-dcda6149410 EFTA00298329 Page 273 1 Reiter ever talked to you about? 2 A. No. 3 Q. So, right now is the first time that 4 you're learning that? 5 A. Yeah. 6 Q. Okay. Well, it looks like based on this 7 report that it was discussed with Epstein that his a potential donation of funds to purchase an Automated 9 Fingerprint Identification System for approximately 10 $130,000 was never made; is that correct? 11 MR. PIKE: Form. 12 THE WITNESS: Correct. I know we're 13 not — we don't have any system. We go to the 14 Sheriffs office to input fingerprints. 15 BY MR. EDWARDS: 16 Q. And Epstein's response was that was not 17 exactly what he hoped to donate as he wanted to 18 donate something that would provide some direct 19 benefit to police officers such as the services of a 20 chiropractor fora year. 21 Were you ever aware that Jeffrey Epstein 22 was trying to get chiropractic services for the 23 police officers for a one-year period? 24 MR. PIKE: Form. 25 THE WITNESS: No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE WITNESS: No. BY MR. EDWARDS: Q. Did you know that Jeffrey Epstein received a January 2005 citizen award? A. Not that I am aware of. I don't blow. Lite I said, these are things that I don't get involved with. You know, that's strictly the Chief and way above my pay grade. Q. If awards like that are given out, are they given out directly by the chief? A. Yes. Q. I apologize for my ignorance. I am just not sue exactly what goes on in the police department and whose role it is to do that. So you're not the right person. We'll just keep moving on. Some of the documents that we have talked about today have been redacted. I think the explanation is they are minor victims. My question is if we wanted an unredacted version and if we agree that we're entitled to it, would that be something that would be in the possession of the Palm Beach Police Department? MR. PIKE: Form. THE WITNESS: I would assume so. Page 272 1 BY MR. EDWARDS: 2 Q. Today is the first day you're learning it? 3 A. Yes, sir. 4 Q. Any reason that you can think of that that 5 information was not conveyed to you during the time 6 that you're the lead detective on the case against 7 him? 8 MR. PIKE: Form. 9 THE WITNESS: Well, because that's 10 something that really has no —1 mean, I have 11 no direct involvement with any donations to the 12 police department, nor would that have made a 13 diffeleme in the investigation. 14 BY MR. EDWARDS: 15 Q. You testified earlier the search warrant 16 was executed October 21st, 2005; is that correct? 17 MR. PIKE: Form, asked and answered. 18 THE WHNESS: The 20th, I believe. 19 BY MR. EDWARDS: 20 Q. Were you aware of a tel one call made 21 from somebody named 22 asking to get a copy of the January 2005 citizen 23 award that was given to Jeffrey Epstein and ■ 24. (phonetic)? 25 MR PIKE: Form. in November of 2005 Page 274 1 BY MR. EDWARDS: 2 Q. Okay. The information that was provided 3 this week tots, most of which is redacted, is 4 something and was redacted recently for the purpose 5 of producing it to us, is that what you think? 6 MR. PIKE: Form. 7 THE WITNESS: Correct. 8 BY MR. EDWARDS: 9 Q. Somewhere there is an unredacted version? 10 A. Correct. 11 Q. And if I wanted to discuss the 12 investigation of Jeffrey Epstein between March of 13 2005 and September of 2005, is Officer Pagan the 14 person to speak with? 15 A. Yes. 16 Q. With Mr. Kuvin you spoke about many 17 different young females that were at Jeffrey 18 Epstein's home. And you interviewed numerous of 19 those females, correct? 20 A. Correct. 21 MR. PIKE: Form. 22 BY MR. EDWARDS: 23 Q. And did you record those interviews? 24 MR. PIKE: Asked and answered. 25 THE WITNESS: I believe so, yes, the PROSE• COURT REPORTING 37 (Pages 271 to 2 7 4) AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 es.2a6ddb-fatil-4114-tab74ede51494142 EFTA00298330 3 4 5 6 .7 8 9 10 11 12. 13 14 16 17 18 19 20 21 22 23 24 25 Page 275 majority of them. BY MR. EDWARDS: Q. And do you have any copies of those tapes of the interviews? MR. PIKE: Form. THE WITNESS: They were all turned over to the FBL BY MR. EDWARDS: Q. They are not backed up on a computer or anything? A. No, sir. They were microcassettes. The ones that were conducted at the police department were video cassettes, but all those as well were turned over to the FBI. Q. Is it your.understanding that Jeffrey Epstein pled guilty to two felonies related to - restitution, correct? MR. PIKE: Asked and answered. THE WITNESS: Contl BY MR. EDWARDS: Q. In your interviews of these young females, were any of those females prostitutes prior to meeting Jeffrey Epstein — • MR. PIKE: Fonn. Page 277 1 manner, but you are saying that you may have jotted 2 down some 3 A. Correct 4 Q. Where would that, where would that diagram 5 be? 6 A. All that went over to the FBI. 7 Q. Okay. That stuff that's obviously not in 8 the property receipt but that's additional stuff 9 that has gone to the FBI? 10 A. Correct. Like I said, they wanted everything 11 including my working files, my — anything that I may 12 have jotted just so I can keep record of who brought 13 who. 14 Q. And again is that information that you 15 never made a personal copy of either? 16 A. It was all in my thumb drives which I had to 17 actually hand over to them. 18 Q. Okay. • 19 MR. PIKE: Form to that question. 20 BY MR. EDWARDS: 21 Q. What about any notes that you took during 22 the entire course of the investigation, do you have 23 any of those? 24 A. Once I transcribed them onto the rcµnt, those 25 were shredded and discarded. Page 276 2 3 4 5 6 7 8 9 10 13. 12 13 14 15 16 17 18 • 19 20 21 22 23 24 • • 25 WO% SIZ.0•••••••••• 001... Q. You never tried to do it in a formal 25 BY MR. EDWARDS: Q. — to your knowledge? A. No. MR. PIKE: Pm sony. I don't understand the answer. So maybe you can follow-up with that. Tell you what, we'll just keep it at form. BY MR. EDWARDS: Q. • In organized crime you've seen these diagrams where it has a mob boss? A. Organizational chart. Q. Yes, organizational chart. Did you ever prepare any diagrams or charts like that for this case related to which girl brought another girl brought, another girl, the organizational chart so-to-speak? MR. PIKE: Form, move to strike. THE WITNESS: Not a chart, per se, but perhaps Tye done like this person brought these throe girls, this person brought these two girls, this person brought five girls. But That a, you know, like an L.C. chart where you've.got the mob boss, the under-boss. BY MR. EDWARDS: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 278 MR. PIKE: Form. BY MR. EDWARDS: Q. What did you do today to prepare for the deposition, If anything? A. I read over the redacted incident report. That's basically it. Q. Okay. And the redacted incident report, you have been asked questions about who is this person that's underneath the redacted portion. And for the most part you haven't been able to identify a lot of those people. So, am I correct in understanding that you never went back and looked at the unredacted version? MR. PIKE: Form. BY MR. EDWARDS: Q. At least to prepare for this deposition? A. I believe there was just one girl thatl wasn't 100 percent certain. Q. Okay. A. But on the others I was able to based on the body of it identify who the girls were. Q. Okay. During these interviews, how long did you spend with each person? A. Depends on the length of the videos, of the interviews. Some were an hour. 38 (Pages .(5.61) 832-7500 PROSE COURT REPORTING AGENCY, INC. 275 to 278) Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hooking (601 aa2a5ddb-fa81-4tt6.b3b7-dcda51494142 EFTA00298331 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 • 22 23 24 25 Page 2 Q. I mean, I'm sorry for such a bad question, but in looking at these property receipts, I just don't see where it tells me how much time each interview had taken. So, l mean, is there an average? A. That's not going to indicate on any property . receipt. There is no... Q. Right Okay. Have you ever seen the nonprosecution agreement? A. No. . Q. Have you ever seen the attached list of victims that was attached as an addendum to the nonprosecution agreement? MR. PIKE: Form. THE WITNESS: I believe the Chief had a copy of it. He may have, you know, done one of these, but, no, not in my physical hands. MR. PIKE: And just for the record when the witness said -- THE WITNESS: I held it up. MR. PUCE: — one of these, he held up Exhibit 29. MR. EDWARDS: Which said memorandum. MR. PIKE: Memorandum. THE WITNESS: I just held it up. Page 281 1 A. I remember getting doctunents from Alan 2 Dershowitz which were flight logs pertaining to 3 • Mr. Epstein's plant And I subpoenaed the information 4 from Jet Aviation, but I don't, I don't recall preparing a flight log. 6' • • Q. Okay. Do you remember receiving 7 information from Jet Aviation directly? 3 MR. PIKE: Form. 9 -THE WITNESS: Jet Aviation does not keep 10 records according to them as to who flies on 11 what plane. I guess you can just drive up to a 12 plane, board it. They have no idea who's on 13 the, who is flying on the plane. They have 14 records of when the plane comes in, if the 15 plane is serviced, and when the plane leaves. 16 BY MR. EDWARDS: 17 Q. Did you over attempt to check with customs 18 or FAA on any of the passengers that have ever been 19 on international flights with Jeffrey Epstein or on 20 his planes? 21 MR:PIKE: Form. 22 THE WITNESS: I'm trying to recall. 23 BY MR. EDWARDS: 24 Q. At the current time do you have any 25 knowledge of that being done by either the U.S. Page 280 1 BY MR. EDWARDS: 2 Q. If a memorandum exists and it is the 3 attached addendum to the nonprosecution agreement 4 containing the names of the underage victims, would 5 that be something in the possession currently of the 6 Palm Beach Police Department? 7 MR. PIKE: Form. 8 THE WITNESS: I don't believe so. 9 BY lvflt EDWARDS: 10 Q Is that something that's been destroyed or 11 also- 12 • MR. PIKE; Form. 13 THE WITNESS: I never received a copy of 14 it so... 15 BY MR. EDWARDS: 16 Q. Have you ever seen it? 17 A. Like I said, I may have seen it. I may have 18 been shown it, you know, and just by holding it up and I 19 am only using this exhibit as an example. It may have 20 been just shown to me like this but not in my hands 21 where I actually read the entire document. 22 MR. PIKE: Move to strike. 23 BY MR. EDWARDS: 24 Q. In your investigation, did you prepare a 25 flight log summary? 1 2 3 4 5 6 7 8 10, 1I 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 282 Attorney's office or the FBI? A. I have no idea what the FBI does. They are primarily one way. You give them the information and nothing comes back, so... Q. I am starting to get that idea. I am understanding that. Okay. A. But you know, and I work with them almost on a daily basis, so I am in direct contact with them. And still I have yet to see information come back the other way. Q. Just so the record is clear, when you say you're working with them on a daily basis, when you're in the Organized Crime Unit on other cases, correct? A. Yeah, and I am also assigned to the MT, the Joint Terrorism Task force here in West Palm Beach. Q. My understanding from reading your reports is that you also subpoenaed phone records of numerous individuals, correct? A. Correct. Q. One of those individuals is Jeffrey Epstein? A. I believe so. Q. =='? A. Yes. liSVA•c•TWAOZPIA 39 (Pages 279 to 282) PROSE COURT REPORTING. AGENCY, INC. Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 ea2a5ddb-14181-4116.63b7-dcda51494142 EFTA00298332 2 3 4 S 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23. 22. 23 24 25 Page 283 A. Yes. Q. Some of the other victims? MR. PIKE: Fan THE WITNESS: (Witness nods head.) THE COURT REPORTER: Is that a yes? THE WITNESS: Yes. sorry. BY MR. EDWARDS: Q. If you were shown those well, did you issue the subpoena — A. Yes. Q. — personally? A. Yes, I did. I requested it. MR. PIKE: Porn. BY MR. EDWARDS: Q. And did you receive it directly from the carrier? A. Yes. MR. PIKE: Form. BY MR. EDWARDS: Q. And when you received it, were you the person to review that material? MR. PIKE: Form. THE WITNESS: Yes. Page 285 1 him contacted any of these underage females? 2 A. Yes. 3 . MR. PIKE: Form. . 4 BY MR. EDWARDS: 5 Q. And when you say that you were able to 6 make that determination, was the determination that 7 Jeffrey Epstein or one of his assistants had 8 contacted on the telephone these underage females? 9 A. Correct. 10 Q. And where would I be able to find that 11 information to say which underage females were 12 contacted by Jeffrey Epstein and/or his employees? 13 MR. PIKE: Form. 14 THE : I believe on one of these 15 exhibits was the phone log, 16 • Exhibit 26. 17 BY MR. EDWARDS: 18 Q. Okay. And as has been pointed out before, 19 many of those names have been redacted. Am I 20 correct in understanding there was an unredacted 21 version that if we're able to get pursuant to court 22 order or agreement, it's something that could be 23 provided by your office? 24 A. Not by my office. Again everything was turned 25 over to the FBI. Page 284 1. BY MR. EDWARDS: 2 Q. And as part of your investigation, did you 3 look at that material and match it up to the 4 interviews that the young females had given and the 5 accounts they had given you? 6 MR. PIKE: Form. 7 THE WITNESS: Some of the carriers don't a keep information longer than so long. So, 9 based on the information that I was able to 10 acquire, I attempted to match up the 11. information. 12 BY MR. EDWARDS: ' 13 Q. And with certain telephone records, were 14 you able to corroborate portions of the victims or 15 witness's testimony? 16 MR. PIKE: Form. 17 BY MR. EDWARDS: 18 Q. or interview statements that they 19 provided you? • 20 MR.. PIKE: Same objection. 21 MR. EDWARDS: Okay. I will withdraw the 22 question. Poor question. 23 BY MR. EDWARDS: 24 Q. Were you able to determine whether or not 25 JeflreY F steinand/or one of the le empl2ild b Page 286 1 Q. Okay. So, all of the documents that you 2 have kept in your possession — strike that. I 3 thought that in the documents that we received this 4 week pursuant to the public records requaLlhe 5 telephone incoming-outgoing calls from 6 was within those documents. Is that not your 7 understanding? MR. PIKE: Form. • 9 THE WITNESS: There may have been e-mail 10 to Nidde Altomat•o to put into the incident 11 report. 12 MR. EDWARDS: Okay. 13 ME WITNESS: And like I said, that was a 14 document created by me as I was subpoenaed, 15 subpoenaing different phone numbers to identify 16 who these persons were. So that was just a 17 little log that I created. 18 BY 'MR. EDWARDS: 19 Q. Let me do it this way then because it 20 sounds like you haven't looked through this 21 voluminous materials that was produced this week 22 pursuant to a public records request to the Palm 23 Beach Police Department, correct? 24 MR. PIKE: Form. 25 THE WITNESS: I don't know. 40 (Pages 283 to 286) PROSE COURT REPORTING AGENCY,' INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb-falill -4f16.b3b7-deda51494142 EFTA00298333 Page 287 1 MS. O'CONNOR: Correct. Why don't we do 2 it this way: Tell me or I'll look through them 3 and if there are things I know we have that are 4 tmredacted, I will tell you whether or not we 5 have them, and then we can fight about whether 6 we can unredact them. 7 MR. EDWARDS: Sounds good. !just didn't 8 want to get into a fight if it doesn't rods'. 9 MS. O'CONNOR: Right. 10 • BY MR. EDWARDS: 11 Q. Evidence that you collected that is not in 12 this property rillithe taped, the wired 13 vehicle where was in the back seat 14 talking, is that information that was also forwarded 15 to the FBI too? 16 MR. PIKE: Form, asked and answered. 17 THE WITNESS: Yes. 18 MR. PIKE: Can you give me a minute? 19 MR. EDWARDS: Sure. 20 (A brief recess was held.) 21 BY MR. EDWARDS: 22 Q. The originals of the propel y were handed 23 over to the FBL But where it indicates that this 24 material was copied, were all the copies also handed 25 over to the FBI? 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 289 investigation? A. There were several. Q. And on those surveillance videos were you able to identify underage minor females going to Jeffrey Epstein's home? MR PIKE: Object to the form. THE WITNESS: We were able to identify not through the video surveillance but through physical surveillance the actual person standing out there watching the car pull in, jotting down the tag number, that kind of thing. The video surveillance was a, was a vehicle that we had parked and ran a video camera from it just to show the traffic in and out. BY MR. EDWARDS: Q. Okay. And did that video camera capture the traffic that was going in and out of Jeffrey Epstein's house; is that what you are telling me? MR. PIKE: Form. THE WITNESS: Yes, that's what it was intended for. However, for identification purposes it's difficult because of the lighting situation. Page 288 1 A. Yes, sir. 2 MR. PIKE: Form. 3 BY MR- EDWARDS: 4 . Q. Even the copies that were made for 5 P.B.S.O., that was handed over, turned over to the 6 FBI as well? 7 MR. PIKE: Form. 8 THE WITNESS: For P.B.S.O., I don't know 9 what copies were made for P.B.S.O. 10 BY MR. EDWARDS: 11 Q. Where it would indicate hard drive copied 12 from Number 55 to P.B.S.O., isn't that indicating 13 that the hard drive is being copied for the Palm 14 Beach Sheriffs Office? 15 A. The hard drive was taken over by now Sergeant 16 Krouel. That was to be analyzed. If you see further 17 down CPU was actually returnod. 18 Q. All right. You obviously looked at all 19 the evidence that was taken from the house; is that 20 correct? 21 MR. PIKE: Form. 22 THE WITNESS: Yes, sir. 23 BY MR. EDWARDS: 24 Q. And do you remember how many surveillance 25 videos were made by eur office in relation to this 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 1? 18 • 19 20 21 22 23 24 • 25 Page 290 BY MR. EDWARDS: Q. Where was that car positioned? MR. PIKE: Form. THE WITNESS: Flintier up the block from the house, towards by the Intracoastal. This was parked up the block. BY MR. EDWARDS: Q. Did you do any of the personal surveillance writing down tags and whatnot? A. No, that would have been, that would have been the Burglary Strike Force. Q. Did you ever speak with Ghislaine Maxwell? A. No. Q. Did you ever attempt to speak with her? A. No. Q. Did her name come up during your investigation? MR. PIKE: Form. THE WITNESS: I researched her based on the media that I had found dining her association with Mr. Epstein. MR. PIKE: Move to strike. Go ahead. BY MR. EDWARDS: Q. During your investigation did — • MR. KUVIN: What was your response? .a j 41 (Pages 287 to 290) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601- Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ddb.14181-4(16-b3b7-dcda61494142 EFTA00298334 Page 291 1 THE WITNESS: I researched her based on 2 her association. 3 BY MR. EDWARDS: 4 Q. After researching her, did you ever 5 attempt to make any contact with her? 6 A. No. 7 Q. Did other witnesses call into you or your 8 department with information related to Jeffrey 9 Epstein during your investigation? 10 MR. PIKE: Form. 11 THE WITNESS: I don't follow the question 12 on it. 13 BY MR. EDWARDS: 14 Q. Okay. Bad question. During your 15 investigation, did you receive any calls from local 16 citizens saying we have information that could be 17 helpful to this investigation? 18 MR. PIKE: Form. 19 THE WITNESS: Not during the 20 investigation, no. 21 BY MR. EDWARDS: 22 Q. Okay. Who is — sorry. Do remember 23 speaking with somebody named from 24 New York City? 25 A. Yes. Page 292 1 Q. And how did you, what was the occasion to 2 speak with ha? 3 A. That was after the arrest of Mr. Epstein. Sbe 4 phoned in to tell me that she had had dealings with him in the past. She said that she had a relationship with 6 him. 7 Q. Do you remember what she did for a living? 8 MR. PIKE: Wait one second. Move to 9 strike, nonresponsive. And your question is 10 finished or no? 11 BY MR. EDWARDS: 12 Q. Do you remember what Ms. .did for a 13 living? 14 MR. PIKE: Form. 15 THE WITNESS: She was an artist. 16 BY MR. EDWARDS: 17 Q. And when she described the relationship as 18 you just phrased it with Jeffrey Epstein, did she 19 indicate that it included massages? 20 MR. PIKE: Form. 21 BY MR. EDWARDS: 22 Q. If you remember. 23 MR. PIKE: Same objection. 24 THE WITNESS: mat's on a separate case. 25 That's on 061078, correct. Page 293 1 MR. EDWARDS: Correct. 2 THE WITNESS: I remember she said he kept 3 some of her art He inspired her to create 4 another piece of art I am hying to think. I 5 remember her telling me that they had some 6 relationship because he got friskier and 7 friskier. MR. PIKE: Move to strike that as 9 nonresponsive. 10 BY MR. EDWARDS: 11 Q. When you say that is a separate case, 12 061078, what do you mean by a separate case? 13 A. The initial incident report is 05368. That 14 one was generated after the arrest when other people 15 were calling in. 16 Q. Was it because of a different 17 investigation related to Jeffrey Epstein or an 18 additional investiption? 19 MR. PIKE: Form. 20 THE WITNESS: Yes, it would have been 21 people outside of 05368. 22 BY MR. EDWARDS: 23 Q. Olcay. Outside of the telephone call that 24 is memorialized in the =Vs did you have 25 occasion to speak with Ms. on any other Page 294 1 occasions? 2 MR. PHO3: Form. 3 THE WETNESS: I don't believe so. 4 BY MR. EDWARDS: 5 Q. You also remember getting a call from -- 6 A. A girl from California 7 ' Q. "e a 8 A. (phonetic). 9 Q. right Do you remember what she 10 told you? 11 MR. PIKE: Form. 12 THE WITNESS: I believe that she also had 13 a relationship with Mr. Epstein but I am trying 14 to remember. 15 BY MR. EDWARDS: 16 Q. Okay. It's obviously been since 2006 when 17 you wrote the report. Have you looked over this 18 report at all? 19 A. No, I didn't look over that report at all. 20 Q. Do you remember her indicating that 21 Jeffrey Epstein was hying to go further and further 22 with a massage and her asking what, what are you 23 doing, to which he replied don't you want to get 24 into Victoria Secret? 25 MR. PIKE: Form. PROSE COURT REPORTING evAldAtraq 42 (Pages 291 to 294) AGENCY, INC. Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aa2a5ridb-fa81-4116-b3b7-dcda61494142 EFTA00298335 Page 295 1 THE WITNESS: I do recall that. 2 MR. PIKE: Hold on one second. Form and 3 leading. Move to strike. 4 BY MR. EDWARDS: 5 Q. Does that refresh your recollection? 6 A Yes, I do recall that I believe she was an 7 aspiring — and she wanted to become a model. 8 Q. Okay. And we have spoken earlier about 9 Leslie Wexner being the CEO of Victoria Secret, 10 correct? 11 A Correct. 12 Q: Did you ever attempt to talk to Leslie 13 Wexner? 14 A No. 15 Q. Even after this particular comment was 16 made and the association or affiliation that was 17 previously determined between Epstein and Wexner, 18 was there any follow-up related to that connection? 19 A No. 20 MR. PIKE Form. 21 THE WITNESS: No. 22 BY MR. EDWARDS: 23 Q. Did you ever try to speak with Gerald° 24 Rivera? 25 ' No. Page 297 1 something that has been forward to the FBI and you 2 don't have a copy of it? 3 A. Correct 4 Q. Back in 2003 investigating the robbery, I 5 guess it was ultimately determined that Juan Alessi 6 was the person that committed the robbery? 7 A. The burglary, yeah. . And also in the house was 9 and Did you speak 10 with those people? 11 A. No. 12 Q. That's just, you take down their name, 13 date of birth, just responding to the call? 14 A. I don't believe I did a supplement on that 15 case. That might have been some other detective. I 16 believe Melnichok was the investigating detective on 17 that. 18 Q. Okay. 19 A. Like I said, my part was very small and I just 20 put the camera up. 21 Q. So, most of the detailed questions about 22 that particular burglary, if it's at all relevant to 23 this case, would have to go through whoever was the 24 detective on that case? 25 A. (Witness nods head.) Page 296 . Have ou ever spoken with former house managers or 3 housekeepers of Jeffrey Epstein? MR. PIKE: Form. 5 THE WITNESS: No, no. I spoke with the 6 Alessi's and Rodriguez. 7 BY MR. EDWARDS: 8 Q. 'And also I saw the names mentioned Patrick 9 and Evelyn as being formerly employed as house 10 managers. Are those people that you have tried to 11 back down? 12 . MR. PIKE: Form. 13 THE WITNESS: I believe I attempted but I 14 couldn't locate where they vivre. 15 • BY MR. EDWARDS: 16 Q. Were you ever able to get a last name of 17 Patrick and Evelyn? 18 A. I don't recall. I can't recall. 19 Q. Okay. Is that something that you would 20 have in your possession to refresh your recollection 21 or is that something that -- 22 A. No. I think it might have been during the 23 . interviews of the previous housemen but -- 24 Q. Okay. Any those interviews of the 25 previous housekeepers or house managers that's all (561) 832-7500 PROSE COURT Page 298 1 THE COURT REPORTER: Is that a yes? 2 THE WITNESS: Yes. 3 BY MR. EDWARDS: 4 Q. Did you testify before the grand jury -- 5 MR. PIKE: Form. 6 THE WITNESS: Yes, I did. 7 BY MR. EDWARDS: 8 Q. related to Jeffrey Epstein at the State 9 Attorney's Office level? 10 A. Yes. 11 MR. PIKE: Form. 12 BY MR. EDWARDS: 13 Q. Was there a grand jury proceeding at the 14 federal level that you're aware of? 15 MR. PIKE: Form. 16 THE WITNESS: I have no idea. 17 BY MR. EDWARDS: 18 Q. Do you know what was presented to the 19 grand jury relative to the Jeffrey Epstein 20 investigation? 21 MR. PIKE Form. 22 THE WITNESS: The state grand jury? 23 MR. EDWARDS: Correct. 24 THE WITNESS: I don't know aside from my 25 portion of my statement that [provided. 43 (Pages 295 to 298) REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkIns (601 aa2a6ddb.fa81-41164ab7-dcda51494142 EFTA00298336 Page 299 1 stuck around just to assist the victims. 2 : BY MR. EDWARDS: 3 Q. And when you talk about the statement that 4 you provided, did you present testimony related to 5 all of the minor females that you discovered to have 6 come in contact with Jeffrey Epstein or only the 7 four or five names that ultimately were at the end 8 of your probable cause affidavit? 9 ' MR. PIKE: Form and compound. 10 THE WITNESS: As far as my testimony at 11. the grand jury, I only answered the questions 12 that were asked of me by the state. At that 13 • poi lit was Latina Belohiavek. 14 El sorry about the last name. I don't 15 know how to spell her last name. 16 BY MR. EDWARDS: 17 Q. And in talking with the State Attorney's 18 Office during the investigation, did you indicate to 19 them the number of underage females that you were 20 aware had come in contact sexually with Mr. Epstein? 21 MR. PiKE: Form and assumes facts not in 22 evidence. 23 THE WITNESS: Yes, they were aware of the 24 . probable cause affidavit which indicated all 25 the facts. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 '20 21 22 23 24 25 Page 301 between the Palm Beach Police Department and the State Attorney's Office? A. Yes, there was. Q. And -- A. This case was originally brought to their attention very early on in the investigation to which they were, you know, very gung-ho, very let's go, let's do this, up until, up until, up until the meeting with Alan Dershowitz and the State Attorney. And then it, ii all took a turn. Q. Were you at that meeting? A. I attended one meeting where I believe it Dershowitz, Krischer, and Belohlavek. MR. PIKE: Object to form. BY MR. EDWARDS: • Q.: What was said during that meeting? MR. PiKE: All right. With regard to this line of questioning, I just want to be clear that I have form objections to this line of questioningg. And the fact that under various Federal Rules, I believe it's 408, 410 as well as various rules under Florida Evidence Code, some of these discussions are protected as potential plea negotiations. So, having said that... 1 Page 300 1 BY MR. EDWARDS: 2 Q. And can you recall what their position was 3 on the various acts that are related in the probable 4 . cause affidavit? And ultimately I am asking why is 5 it that they were not interested in hearing from all 6 of the girls and only a select few? 7 . MR. PIKE: Form and compound. 8 THE WITNESS: That's a question that . 9 you're going to have to ask Lonna Belohlavek 10 . because she was aware of all the people that I 11 submitted to her, and yet she choose three 12 people to appear before the grand jury, one 13 ;mowing that she was not going to be able to 14 15. 16'. 17. 18 19. 20 21 22 23 24 25 appear. . MR.PIKE: Move to strike. BY MR. EDWARDS: Q. And who was the person that was not going to be able to appear? A. That would have been Jane Doe No. 103. . Q. Do you know why she was unable to appear? A. • Because it was finals week in her university and the limited time that they had scheduled the grand jury and the time that it would have been for her to make arrangements to come down was very short. Q. Was there a disagreement about this case (561) ..832-7500 Page 302 1. BY MR. EDWARDS: .2 • Q. What was said during these, this meeting 3 that you attended? 4. A. Several of the girls' MySpaces were discussed. 5 MySpace being the social network. They all had 6 MySpaces. And the girls, the girls were actually who 7 had the MySpaces had inputted, you know, various 8 different things regarding alcohol use or marijuana use '9 or that kind of thing. 10. Q. And what was broUght up at that meeting as 11 to the relevance of whether or not these females 12 . that had been to Jeffrey Epstein's house while 13 underage used alcohol or drugs? What was the point 14 of that? 15 MR. PIKE: Font 16 THE WITNESS: To show that the character 17 of the girls were not, was not to be believed. 18 .• BY MR. EDWARDS: 19 ' Q. Okay. It was specifically to attack their 20 credibility? 21, MR. PIKE: Form, move to strike. 22' . s THE WITNESS: Correct. 23 BY MR. EDWARDS: 24: • . . Q. So, at that poiM in time who was =Icing 25. • • those arguments on behalfofJeffi ebe 44 (Pages 299 to 302) PROSE COURT REPORTING AGENCY, INC.. Electronically signed by synth's hooking (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (801 aa2a6ddb.fai-iff6-b3b7-dcda61494142 EFTA00298337 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 • 23 24 25 Page 303 1 MR. PIKE: Form. 1 2 THE WITNESS: It was Alan Dershowim. 2 3 BY MR. EDWARDS: 3 4 Q. And was the argument that you can't 4 5 believe these girls about what they're saying 5 6 transpired at Jeffrey Epstein's house because of 6 . 7 what we're viewing, material they chose to put on 7: 8 their MySpace pages? 8 ' 9 ' MR. PIKE: Form and leading and compound. 9 10 And is there a question? 10 . 11 BY MR. EDWARDS: 11. 12 Q. You understood, you understood that ended . 12 • 13 with a question mark, right? 13 ' 14 A. Yes. 14 15 MR. PIKE: I just want to make sure of 15 16 that. Can you reread the question for me, 16 17 please. 17 18 (The requested portion of the record was 18 19 read by the reporter.) 19' 20 M. PIKE: Saute objection. 20 21 THE WITNESS: That's correct 21 22 BY MR. EDWARDS: 22 23 Q. And I ask because I want, I want to make 23 24 sure that — well, I want to understand it was that, 24 25 hey, these girls have done a lot of bad things; 25 Page 305 BY MR. EDWARDS: Q. Happens all the time, right? . A. Yes. . MR. PIKE: Same objection. • BY MR. EDWARDS: . . Q. But for whatever reason the State Attorney's office was entertaining this argument? A. Absolutely. At that point they started to back off. And then they are, like, well, you can't — this girl is not a victim; this girl is this, you know, that kind thing. Q. Was there ever a time when the State Attorney's Office bought into an argument that you can't even believe these girls when they testify about what transpired at Jeffrey Epstein's house? MR. PIKE: Form. THE WITNESS: I had that impression, that kind of thing where these girls were not victims. ..BY MR. EDWARDS: •• • Q. You talked to many girls that didn't even know one another, correct? ' A. Some didn't go to the same schools, correct. . . MR. PIKE: Form. Page 304 therefore, they am not sympathetic enough to 1 2 prosecute the person that committed crimes against 2 3 4 5 6 7 8 9. 10. 11• 12 13 14 15 16 17 18 19 20 21 22 23. 24 25 3 them; or these girls have said a lot of things on 4 their MySpace page, therefore, they can't even be 5 believed about what transpired at his house. 6 Do you understand the difference? MR. PIKE: Fonn. THE WITNESS: Well — MR. PIKE: Wait a second, Detective. Form, compound, and speculative and hearsay. THE WITNESS: It was more to the effect of, you know, these girls are not saints; look at the stuff that they are posting out there for everyone to see, et cetera, et cetera. That kind of thing. BY MR. EDWARDS: Q. Okay. But I mean, you have been a detective for how many years? A. Fifteen. Q. And you investigate an attempted murder, still prosecute the attempted murder even if he is tying to shoot a gang member, right? MR. PIKE: Form, relevance. THE WITNESS: AbSolutely. Page 306 BY MR. EDWARDS: Q. And in speaking with them, they each described an almost ritualistic process that happened inside Jeffrey Epstein's bedroom with each • one of them, correct? MR. PIKE: Form. THE WITNESS: Correct. BY MR. EDWARDS: .Q. And that was something that was made clear to the State Attorney's office? A. Correct. . MR.PIKE: Form. BY MR. EDWARDS: Q. And at some point in time Chief Reiter wrote a letter to Mr. Krischer in May of 2006 indicating that he believes Mr. Krischer should disqualify himself from prosecuting the cases. Are you aware of that? • A. Yes,' am. • Q. And you have seen that letter before? A. Yes, I've seen it before. Q: And he also indicates in it it is regrettable that I am forced to communicate in this manner, but my most recent telephone calls to you and those of the lead detective to our assi s ed (561) 832-7500 45 (Pages 303 to 306 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cyntlga honking (601 Electronically signed by c-ynthia hopkins (601 Electronically signed by cynthia hopkins (601 ae2a6ddb.fa81.4ff6•b3b7.dcda61494142 EFTA00298338 Page 307 1 attorneys have been unanswered and messages remain 2 =owned. Is that a statement that you agree 3 with? 4 A. Absolutely. 5 Q. How many messages do you think that you 6 left the State Attorneys Office that were 7 unearned? 8 A. Quite a few. I actually showed up at Lanna's 9 office because I had left her several messages and 10 didn't, didn't return get a return phone call. And it 11 was during the time where: We're going to the grand 12 jury, no, we're not going to grand jury, yes, we're 13 going no, we're not. 14 And it was, I believe, the following day 15 when we were supposed to go to the grand jury and I 16 still had not heard from her as to what time nor had 17 I received a subpoena. So, I had contacted her 18 numerous times during that day. I would say three 19 to four times during that day. In the afternoon I 20 actually showed up at her office where she was 21 sitting in her office. 22 Q. Did you speak with her? 23 A. Yes, I did. 24 Q. And what happened within that 25 conversation? Page 308 1 MR. PIKE: Form. 2 THE WITNESS: There was actually a time 3 where there was a plea negotiation being 4 discussed where it was to one count of felony, 5 five years probation, and I believe no one had 6 been contacted regarding to that negotiations. 7 BY MR. EDWARDS: 8 Q. When you say no one, are you speaking 9 about the police or victims? 10 MR. PIKE: One second. Form. I'm going 11 to move to strike and I am going to continue to 12 assert the same privileges under the Federal 13 Rules 408, 410, and 401.9. I'm sorry. Go 14 ahead. 15 BY MR. EDWARDS: 16 Q. When you say no one had been contacted, 17 are you speaking about no police officers that were 18 on the case or no victims? 19 A. Both the police officers and the victims 20 because I was getting phone calls from the victims' 21 parents as to what time are we needed. 22 Q. And when you say we were getting phone 23 calls front the victims' parents, are those the 24 victims that ultimately were listed as victims in 25 Cher in the plea that transpired? Page 309 1 A. Correct. 2 MR. PIKE: Form. 3 BY MR. EDWARDS: 4 a. So, are you talking about" 5 and Jane Doe No. 103? 6 MR. PIKE: Form. 7 ME WITNESS: Frowns family I had gotten multiple phone callsduring that day. BY MR. EDWARDS: 10 Q. During any of the meetings — how many 11 meetings are you aware of that Mr. Dershowitz 12 participated in with the State Attorney's Office? 13 A. There were a couple. Like I said,1 attended 14 one. 15 MR.-PIKE: Form. 16 THE WITNESS: I didn't attend the second 17 one. I want to say two to three. 18 BY MR. EDWARDS: 19 Q. And he is a person who also is found in 20 the message pad as somebody who has called Jeffrey 21 Epstein's home, correct? 22 A. As far as I can recall, yes. 23 Q. And did he ever indicate to them that he 24 was actually at the home on various occasions when 25 some of these underage girls would come over to -3 Page 310 1 Mr. Epstein's house? 2 MR. PIKE: Form. 3 . THE WITNESS: Not that I recall. 4 BY MR. EDWARDS: 5 Q. In fact, was he trying to convey to the 6 State Attorney's office that you should not believe 7 these girls that they were at his house at all 8 because they have credibility problem's? 9. MR. PIKE: Form, asked and answered. 10 THE WITNESS: That's, that was the 11 impression I received, yes. 12 MR. EDWARDS: The.next portion is going to 13 take a long time. I mean it's getting into the 14 juice of it. So, are we at a point that you 15 want to stop rather than getting into something 16 that's going to take a long time? 17 MS. O'CONNOR: How long? 18 MR. EDWARDS: Couple of hours. 19 MS. O'CONNOR: I need to stop. 20 MR. KUVIN: Okay. 21 MR. PIKE: Ail right. So we are going to 22• break. We have an agreement on the record that 23 Detective Recarey, and correct me if I am 24 wrong Ms. O'Connor will get back to us through 25 you sometime weekvithi a few available PROSE COURT 46 (Pages 307 to 310) REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 aitaaddbfell1-41164307-deda51464142 EFTA00298339 Page 311 I dates sometime in April. And then counsel who 2 are here at this table will endeavor to pick 3 some dates that are most convenient so we can 4 expeditiously complete Detective Recarey's 5 deposition. 6 MR. EDWARDS: Agreed. 7 MS. O'CONNOR: Complete in one day. 8 MR. KUVIN: Yep. 9 MR. PIKE: I hope to do that. 10 MR. EDWARDS: I can get through mine in 11 three hours. 12 MS. O'CONNOR: We're supposed to only be 13 having one day in your order. 14 MR. PIKE: Well, kind of, sort of; kind 15 of, sort of. 16 MR. KUVIN: We're doing state and federal, 17 so ifs a mixture. There is no state order. 18 (A discussion was held off the record.) 19 MR. PIKE: I can tell you this, at past 20 depositions that deal with witnesses such as 21 Detective Recarey or any other alleged 22 witnesses, despite whether or not a lawyer 23 represents one, two, or seven alleged 24 Plaintiffs, it is not appropriate to rehash 25 background information pursuant to the court's 1 2 3 4 5 6 7 ‘:) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 313 need a mini or any of that. MS. ARBOUR: I don't need a fdl copy. Just a mini. I don't need any of that other stuff. MS. O'CONNOR: We're going to read. (Witness excused.) (Deposition was concluded.) 1 2 3 5 0 3 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 312 orders that have already been entered and waste a witness's time. So hopefully we can all abide by that and concentrate on our individual and particular clients at those depositions. MR. EDWARDS: Certainly no one will intentionally do that but I just wanted to say that since I am questioning right now, I think that I am the only one with an eminent discovery deadline. So, I will get through my portion and whatever happens after that — MR. PIKE: You and me. MR. EDWARDS: Right. (A discussion was held off the record.) THE COURT REPORTER: Do you want to order this? MR. KUVIN: No, I don't. MR. PIKE: You know, I do need that, but I need it regular. And I need it for reasons that I don't want to state. THE COURT REPORTER: Does anyone want a copy/ MS. ARBOUR: Yes. MS. EZELL: I want a copy too. MR. EDWARDS: I just want a copy. I don't 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page .) I •: CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that DETE,CTIVE JOSEPH RECAREY personally appeared before me and was duly sworn on the 19th day of March, 2010. Dated this 1st day of April, 2010. Chia Hopki ti/cc CommissionExpires: My Commission No.: DD 64 Job N1509 5,2011 47 (Pages 311 to 314) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (801 ea2a5ddb-fa81-41f6,b3b7-dcda51494142 EFTA00298340 Page 315 Page 317 2 3 4 5 6 8 9 to 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATE THE STATE OF FLORIDA COUNTY OP PALM BEACH I, Cynthia Hookas. Regiatered Profusion.' Reporter, Florida Professional Reporter, and Notary Pattie in and for the Sate of Florida at large, do hereby cat? ? that lams authorized to and did report Si deposition in stemlym and dal the foregoing ppm emotive Si Carat transcription of my atethand notes of said deposition I father eenify tint said deposition was atm at the toe and place haeinabove set forth and that the taking of mid depositket was commenced and carpeted as haeinabcne moue I pother catilY that I am not money a cowed of any of the penis. nor am I a relative or employee of any attorney or camel of pony connected with the aCteart, nor amp finamially berated in the edict The foregoing cenigration of this trareaipt does not apply to any rtprodatioo of the sane by any men unless under the dna control ancitor diadem of tit certifying repent/. Dated this Iii day of Aga 2010. eckilt 4 i*rs Job/ 1W9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH I hereby certify that I have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. Dated this day of 2010. DETECTIVE JOSEPH RECAREY Job #1509 1 DATE: April 1,2010 2 TO DETECTIVE JOSEPH RECAREY Job81509 JOANNE M. O'CONNOR. ESQUIRE 3 JONES. FOSTER JOHNSON at STUBBS, PA. 503 South Flashy Drive. Suite 1100 4 Wm Pala Beath, Florida 31101 5 JERE Jay Doe No. 2, Jane Doe No. 103, and B B. 6 Please take notice Nate Friday, the Ina of Asa 2010, yen gave your deposition in the 7 aboyearefarei antler. At that that you did not want signalise. his row natessay that you alga 8 your depcsition As a pofessicad «aim. we are sondsag yes 9 evil at 10 . Althea, o e Intnage you at San drab duet. As feu mad year deposition. any 11 Mangos or acre:dons that yon with termite should lie noted* the ernes aka, ening page aid line 12 ember of saki change. DO NOT wile ate rimcuipt itself One you brit read the 13 trawript and rated any dazes. be two to sip Si date the emit* thee* and return these pages to 14 rte. Yoe and id return the entire tranaript. If arm do ace read and aip the topsail within a 15 learnable tims, the caging& *bleb has already been foroarded to the adaieg 'Raney, may be 16 tikd nig& due Clerk of the act If Mu Mat to naive yogi alpenum, sign year rim in the NM* at the bottom of this letter and mnuq it to us. 17 18 19 20 21 22 23 24 793 1!' AS licaltins,RPR,FPR I do hatby nano my signatan. DETECTIVE 3OSPAH RECAREY I do hereby wane my Aspatore: Cc Via trarceript. Bradley J. Eduard., Esquire 25 Katherine W' Ezell Estjuire, Michael Pik Entire., Page 316 Page 318 1 ERRATA SHEET 2 IN RE: Jane Doe No.2, Jane Doe No. 103 and 88. 3 CR: Cynthia' Hopkins, RPR, FPR DEPOSMON OF: DETECTIVE JOSEPH RECAREY 4 TAKEN: Match 19, 2010 JOB NO: 1509 6 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 7 PAGES LINEN CHANGE REASON 8 9 10 11 12 13 14 15 16 17 18 Please Reward the original signed Cat sheet to this office so that copies may be distributed to 19 all punks. 20 Under pawky of perjury, I declare thatlhave read my deposition and that it is tit and correct 21 subject to any changes in form or substance entered hit 22 23 DATE: 24 25 SIGNATURE OF DEPONENT: 48 (Pages 315 to 318) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthla hopkins (601 Electronically signed by synth's honking (601 saddcWall1-4116-b31041cds51494142 EFTA00298341