IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT

1 2 3 Page 320 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.50200SCA0373193000CMB AB 1 2 3 Page 322 APPEARANCES: On behalf °flaw Dora 1 through 8: JESSICA ARBOURESQUIRE utatmusitirt & P.A. 1820513ismne Boulevard B.B. Susie 2218 4 Plaintiff Miami, Phone S 1, 6 ws- VOLUME al OF IV 7 8 Oa behalf of the Plaintiff, Jame Doe No. IL ISIDRO MAKIJEI. GARCIA, ESQUIRE GARCIA, MAINS& BOO-RINGER 9 224 Dan Awnuo Suite 90) West 33401 Dcfaxlinta. 10 tilde Phan( 9 11 ind 10 12 TARA A. MORGAN. ESQUIRE. TARA A. P124141GAN. PA 11 13 224 Datum SEM 12 DEPOSITION OF SAW 900 DETECTIVE JOSEPH RECAREY 14 West ids 33401 13 Plan. 14 15 Tuesday, April 27, 2010 1003 - 5:23 p.m. Is 16 17 Oo bd./gelthe De /W. Setiney Epsiesn: MEI IAN PIKE. 18QUIRE 16 505 South Hagler Drive BURMAN, CRUTCH, Lunrout COLEMAN, LIP Suite 1100 14 303 Rearm nadorsrel 17 West Palm Beach, Florida 33401 Sage 400 18 19 West Pligarida 33401 19 Phone 20 20 and 21 21 22 Reported By: mTI:PON 0. WITINRF.R.G. mot BRE Jena Riociuti, RPR, PPR, CLR 22 LAW OFFICE OF MILTON G. WEINBERG 23 Notary Public. Siam of Florida 20 Park Plant 24 Prose Court Reporting Job No.: 1509 23 24 Suite 1008. Bea Mir 02116 Thaw 25 25 Page 321 Page 323 1 1 Appearances continued... 2 UNITED STATES DISTRICT COURT 2 On behalf of the Witness: 3 SOUTHERN DISTRICT OP FLORIDA 3 JOANNE M. O'CONNOR, ESQUIRE CASE NO. 10-80309 JONES, FOSTER, JOHNSON & STUBBS, P.A. 4 505 South Flagler Drive, Suite 1100 5 JANE DOE NO. 103. West Pa rida 33401 Pkbdiff; Phone: 7 VOLUME DI OFIV 9 JEFFREY EPSTEIN, Degltlallt 7 8 Also Present: Jeffrey Epstein 10 9 11 10 12 DEPOSITION OP 11 DETECTIVE JOSEPH RECAREY 12 13 14 Tuesday, April 27,2010 13 15 10:03 - 5:23 p.m. 14 16 505 South Hagler Drive 15 Suite 1100 16 17 West Palm Beach, Florida 33401 17 18 18 19 20. 19 ,21 20 22 Reported By. 21 Jeana Rkciuti, RPR, IFPR, CLR 22 23 Notary Public, State of Florida 23 24 Prose Court Reporting 24 25 25 2 (Pages 320 to 323) • PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricclutl Electronically signed by Jeana Ricci utl (4082837-a bal-482e4836-be014441447a EFTA00298214 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 324 PROCEEDINGS Deposition taken before Jeana Ricciuti, Registered Professional Reporter and Notary Public in and for the State of I•lorida at Large, in the above cause. Thereupon, (JOSEPH RECAREY) having been fast duly sworn or affirmed, was examined and testified as follows: THE WITNESS: I do. CROSS (JOSEPH RECAREY) BY MR. WEINBERG: Q. Good morning, Detective. A. Good morning. Q. You've been a detective for the Palm Beach Police Department for how long? A. Approximately, 15 years. Q. Some of it is as a detective and some of it in another capacity, or always as a detective? A. I've been with the Town for 19 yews, but I did time on the road and then moved up to the detective bureau. Q. And do they have a written practice in teams of whether or not you're required to preserve rough Page 326 1 Q. And you would type the report into a computer? 2 A. Yes. 3 Q. And that would be essentially signed by you, 4 that would be your personal summary of the interview 5 that you were conducting with one of the many people 6 that gave you information about Mr. Epstein? A. Correct. 8 Q. And it was always your practice in this case 9 to then destroy the notes that you used as a basis for 10 that typed summary; is that correct? A. Correct. 12 Q. And on other cases, is it always your practice 13 to destroy the notes that you would take during the 14 interviews? 15 A. Correct. 16 Q. So you have no notes of any case that you've 17 ever memorialized into a computer or a typed summary; is 18 that correct? 19 A. That is correct. 20 Q. And is that a practice that you've discussed 21 with other detectives in the Palm Beach Police 22 Department? 23 A. Ifs just a practice that I've done all along. 24 Q. And what is the purpose of your destroying the 25 rough notes? Page 325 1 notes or interview notes of different witnesses? 2 A. No policies, no practice. 3 Q. Do you have personal practice as to whether or 4 not you would retain rough notes that you are 5 contemporaneously taking of interviews with the 6 witnesses? 7 A. I take my notes, transcribe them into my 8 supplements and then shred them. 9 Q. So that you have no rough notes or no 10 handwritten notes — 11 A. Correct. 12 Q. of any of the many interviews you took 13 during your investigation of Jeffrey Epstein? 14 A. Correct. 15 Q. It was your practice to take notes while you 16 were interviewing people? 17 A. On occasion, 1 did, yes. 18 Q. Would you take notes even if you were tape 19 recording the people with whom you were conducting an 20 interview? 21 A. On occasion. 22 Q. And at some point thereafter, you would use 23 those notes as a basis of writing a report; is that 24 correct? 25 A. Correct. Page 327 1 A. There's no need to keep them once you've 2 transcribed than into your supplemental. 3 Q. And again, the transcription into the 4' supplemental is done X number of days after the 5. interview? 6 A. If not the same day. 7 Q. Sometimes a week after, sometimes the same 8 day? 9 A. I wouldn't say a week after. I would say 10 either the same day or the day after. 11 Q. So within 24 hours, you would have a typed 12 summary of the interview, is that correct? 13 A. Approximately. 14 Q. And would you just type your rough notes or 15 would you summarize from your rough notes when you 16 • engaged in the process of — 17 A. Summarize. 18. Q. — your report? 19 So the notes would have more than a summary? 20 A. Obviously, if it was taped, everything would 21 be on the tape recorder. As fir as my note-taking 22 concerns, I would jot down things that sparked my 23 curiosity or things I wanted to go back and reinterview 24 the person - and go back and reinterview the person. 25 Q. So the summary that you typed into a computer PROSE COURT 3 (Pages 324 to 327) REPORTING. AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricciuti (601 c6062637-abel-452c-a836-bc614e314d7a EFTA00298215 Page 328 Page 330 1 would be, in part, your notes, part in memory of 1 surveillances of Mr. Epstein's residence as El Brillo on 2 different statements made to you based on the jottings 2 Palm Beach, correct? 3 in your notes? 3 A. Correct 4 A. I would basically go over what the interview 4 Q. And who made that assignment, if you know? 5 transcribed, you know, into my supplement. S A. I can't recalL That was back when 6 Q. But the basis of the supplemental, and I don't 6 Officer Pagan had the case. But they were also 7 mean to torture the subject, but the basis of the 7 utilizing it for various functions. They were primarily 8 supplement would be, in part, your memory, correct? 8 the surveillance units used. 9 A. Correct 9 Q. And did they surveille residences to try to 10 Q. And then, in part, what your notes refreshed 10 stop burglaries as well as stuveilling Mr. Epstein, 11 your memory into recalling from the interview that was 11 right? 12 conducted either at that time, the same day or the day 12 A. And other fractions as well. 13 before? 13 Q. Sure. And in 2005, there was not any kind of 14 A. Correct 14 burglary investigation dealing with his residence; is 15 Q. Did you listen to the tape before you wrote a 15 that correct? 16 supplemental report into a computer? 16 A. Correct. 17 A. Are you saying every time or arc you just 17 Q. So to the extent the Burglary Task Force was 18 saying — 18 involved in investigating Mr. Epstein prior to your 19 Q. Asa regular practice, would you, at the time 19 first involvement in September, it was simply an 20 that you typed in your supplemental report into a 20 assignment made of them to assist Officer Pagan, 21 computer, have the tape recording going? 21 correct? 22 A. See, I have done that on other cases, 22 A. Correct. 23 especially lengthy interviews, interviews that last 23 Q. And if you know, did the Burglary Task Force 24 several hours. 24 use video surveillance in investigating Mr. Epstein? 25 Q. But it's not a standard practice, it's 25 A. I know that there were some videos taken, but Page 329 Page 331 1 something you would do on an occasional basis; is that 1 I don't believe from the video — from the Burglary 2 correct? 2 Strike Force. 3 A. Correct 3 Q. Was there videos taken by others in the Palm 4 Q. Now, let me ask you in particular, on your 4 Beach Police Department of Mr. Epstein's residence? 5 incident report, in essence, is a combination of all the 5 A. There was. There were several tapes. Yes, 6 different supplemental reports that you typed; is that 6 there was. 7 correct? 7 Q. Did you ever direct video surveillance of 8 A. I typed, and other officers as well. 8 Mr. Epstein's residence? 9 Q. Because you came to this investigation at 9 A. What do you mean "direct"? 10 least six months after it began; is that right? 10 Q. In other words, was there any video 11 A. Approximately, yes. 11 surveillance of Mr. Epstein's residence on or after the 12 Q. Again, March of 2005? 12 time that you became the ease agent in the 2005 13 A. Yes. 13 investigation? 14 Q. And it began with Officer Michele Pagan being 14 A. I can't recall. If I did, it would be in the 15 the case agent, if I could call her that? 15 incident report. 16 A. Correct. 16 • Q. But you know that there was such video 17 Q. And it began with surveillances that were 17 surveillance of Mr. Epstein's residence before you 18 conducted by the Burglary Task Force? 18 became the case agent in charge of the investigation? 19 A. Correct 19 ' A. I can't recall if it was before I took over 20 Q. And the Burglary Task Force was a component of 20 the case or after I took over the case. I know that 21 the Palm Beach Police Department designed to try to 21 there was tapes, but i don't know the exact time frame. 22 prevent citizens from being the victims of burglaries; 22 Q. Let me ask you and — let me ask Mr. Pike for 23 . is that correct? 23 one second. 24 A. Correct. 24 MR. WEINBERG: Do we need to use the real 25 Q. And yet, they were assigned the task of doing 25 names? 4 (Pages 328 to 331) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RIcciuti (801 Electronically signed by Jeana Ricciuti (801 c6062637-abol-462c-a836-bc614.314d7a EFTA00298216 Page 332 1 MR. PIKE: Yes, pursuant to the agreement that 2 was entered last time, the real names can be used. 3 MR. WEINBERG: Chuck is not going to be in 4 agreement, but i can use the real names, and then 5 they will be convened in the transcript to the 6 applicable abbreviations. 7 BY MR. WEINBERG: 8 Q. Jane Doe, do you know that name? 9 A. Not that I recall. 10 Q. So that it's fair that as you sit here today, 11 in 2010, you have no recollection of ever interviewing a 1.2 woman, a young woman at the time named Jane Doe? 13 A. i don't recall, no. 14 Q. n, d:erciu have any recollection of ever 15 interviewing M.? 16 A. I went to her home. 17 Q. And what do you recall of going to her home? 18 A. She did not ward to speak to me. 19 Q. And did she tell you why she didn't want to 20 speak to you? 21 A. She was in love with Mr. Epstein and she was 22 not going to speak to me. 23 Q. And how did you come to go to her home? Do 24 you wall, you lawny, what led you to M.? 25 A. Her name came up in the investigation either Page 334 1 yoinself? 2 A. NO, sir. 3 Q. Did you ever discuss with anyone the fact that 4 there was such a victim list that had been generated out 5 of the United States Attorneys Office? 6 A. There was a list, I believe, that was given to 7 chief — former Chief Reiter. I never got to actually 8 physically hold it and look at it i mean, it was one 9 of those things where he showed me the list, but I never 10 got a chance to... 11 Q. Did the Chief represent to you that that list 12 originated with the United States Attorneys Office? 13 A. I believe so. 14 Q. Did he explain that he had received it from 15 them? 16 A. I believe so. 17 Q. And did he explain ho received it from them 18 with the directive that it should be reviewed and then 19 destroyed? 20 A. I recall the destroying part I'm sure he 21 reviewed it 22 Q. What do you recall of the destroying part? 23 A. I remember him telling me that he was given 24 the copy but it must be destroyed immediately 25 thereafter. 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 333 by interviews or — I believe it was interviews. Q. And do you recall who was interviewed, who would have given you for the first time the name of M.? A. There were so many interviews then. I would have documented it in the incident of who supplied what name. Q. So independent of what's documented in an incident report that was largely authored, what's now five years ago, you have no otrecollection of who would have first toM you about ? A. Lilco I said, it would be documented in the incident report You know, we're talking five years ago. You know, tons of interviews. Q. And with Jane Doe, similarly, do you you don't remember interviewing her. Do you remember interviewing anybody else about Jane Doe? A. Jane Doe does not ring a bell. Q. Did you ever see her name on any report? A. No, I don't remember. Q. Did you ever see her name on any list of different complainants, victims, witnesses? A. No. Q. Did you eva sec a list of victims or witnesses that was prepared by someone other than Page 335 1 Q. And did he tell you who directed him to 2 destroy it? 3 A. No. 4 Q. Did he tell you whether or not that directive 5 was in writing or verbal? 6 A. No. 7 Q. Have you ever seen — other than seeing him in 8 the physical possession of the list, have you ever seen 9 it again? 10 A. No. 11 Q. Do you have any reason to believe that he 12 didn't destroy it? 13 A. No. If he says he was going to destroy it, he 14 would destroy it. 15 Q. And do you recall when that was in terms of 16 the evolution of the State case? 17 A. It would have been around December or January 18 time Same of like '06,107. 19 Q. So either the end of '06, beginning of '07? 20 A. I believe so. 21 Q. Or at the time period that would be after the 22 State grand jury met and returned charges against 23 Mr. Epstein? 24 A. It would have been, yes, much after. 25 Q. Would it have bear before there was 5 (Pages 332 to 335) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana FtIcclutl (601 Electronically signed by Jeana Moduli (601 c6062637-abel-452c-a836-bc6144/314d7a EFTA00298217 Page 336 1 sum-ceding information that brought in the charges? 2 A. It would have been — again, I'm going off of recollection here. 4 Q. And again, I understand this is four years ago 5 and we're just trying to get your best unrefreshed recollection. 7 A I'm trying to think back. It would have 8 been — it would have been — see, I would be guessing. 9 Q. We don't want you to guess. 10 A That's the thing, I would be guessing. 11 Q. Did the Chief ask you to come to his office? 12 A Yes, he did ask me. He said the — the list 13 was not going to leave his office, most assured, and 14 I — at that point, I was like, you know, don't even 15 show me. Liman, it was for your eyes only, that's 16 fine. 17 Q. And did he explain to you why he was directed 18 to destroy the list? 19 A. No. 20 Q. Has the Chief ever before invited you to his 21 office to discuss a document that he thereafter told you 22 he was directed to destroy? 23 A. I mean, I've been many times at the Chiefs 24 office — 25 Q. Sure. Page 338 1 Q. And you certainly don't recall him ever saying 2. that on any other occasion that he had been directed by 3 any Federal or State prosecutor - 4. A. Not with me, no. 5 Q. — to destroy a document? 6 A. Not with me. 7 Q. And just so we're clear, this docwnent was 8 being destroyed, not in the regular course of business, 9 but as a result of the directive from the Federal 10 prosecutor, correct, according to — 11 A. I would assume so, yeah. 12 Q. And there was no other copy that you knew of 13 this document? 14 A. No. 15 Q. And you have never seen one thereafter? 16 A. N sir. 17 Q. M., you went to ha house; is that correct? 18 A. Correct 19 Q. Did you speak to either of her parents? 20 A. No, I did not. 21 Q. Was she 18 at the time you went to her house? 22 A. I believe so. 23 Q. Was your practice that when somebody was over 24 18, you would feel Otte it was appropriate to interview 25 them directly, but if somebody was under It, you would Page 337 1 A. — but not — leant recall if there was ever 2 a time that he showed me a document that he must 3 destroy. 4 Q. And have you ever been, yourself, directed by 5 either a State attorney or a US attorney to destroy your 6 document? 7 A. No. 8 Q. And has the Chief ever told you, on any other 9 occasion that you currently recall, that he was directed 10 by a Federal or State prosecutor to destroy a document? 11 • A. I don't know. 12 Q. And other than destroying documents in the. 13 regular course of business, you don't recall the Chief 14 ever before or ever after saying he had been directed by 15 any third party to destroy a document that was relevant 16 to the investigation, correct? 17 A. Fro sorry, can you ask the question again? 18 Q. Oh, sure. Fm sorry. Other than this 19 occasion when the Chief invited you to his office and 20 specifically said that he was in possession of a 21 document, relevant to the Epstein investigation that he 22 had been directed to destroy, do you recall any other 23 occasion where the Chief told you that he was destroying 24 a document relevant to an investigation? 25- A. No. Page 339 1 try to give some parental notification? 2 A. Correct. 3 Q. And your best recollection with is she 4 was over 18 and, therefore, you went directly to her? 5 A. Correct 6 Q. What would you have told her when you rang on 7 her doorbell and she answered the door? 8 A. I would have identified who I am, my purpose 9 for being there. 10 Q. And what would you have said your purpose for 11.. being there was? 12 A. I was conducting an investigation. 13 Q. And wonld.you tell her of who? 14 A. Yes. 3.5 Q. And would you tell her the subject matter of 16 the investigation? 17 A. Yes, absolutely. 18 Q. And her answer was that she did not wish to 19 cooperate with you? 20 A. I never got to the point to explain to her my 21' purpose of being there. Obviously, she knew why I was 22 .- . there. Once I identified myself, l told her I was a . • 23 police officer from Palm Beach and I was here to speak 24- to her in regards to Jeffrey Epstein. At that point, 25. • . she stopped me and said, I have nothing to say about 6 (Pages 336 to 339) PROSE COURT REPORTING AGENCY,..INC. Electronically signed by Jeana Fticciuti (601 Electronically signed by Jeana Ricciuti (601 c5062637-abol-452c-a836-bc6140140a EFTA00298218 Page 34C 1 him, nothing negative to say about him. She is in love 2 with the man, and... 3 Q. So that was literally a 30-second 4 conversation? 5. A. Pretty much. Pretty much. 6 Q. Were you with anyone? 7 A. Yes, I was. • 8 Q. Who were you with? 9 A. I want to say either Sergeant Dawson, who was 10 a detective at the time. 11 Q. Did you follow that tip at all by attempting to 1.2 reinterview her on any other occasion? 13 A. No. 14 Q. So your sum total experience with was 15 essentially a 30-second conversation at her house where 16 she declined your invitation to disci KS Jeffrey Epstein 17 with her? 18 A. Correct. 19 Q. Okay. And you do recall her saying, "fin in 20 love with him*? 21 A. Yes. 22 Q. And you're assuming but don't know that she 23 • had been essentially tipped off that this investigation 24 was ongoing; is that correct? 25 A. Pretty much. I mean, she didn't know why I — 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 342 Q. Do you recall who that was? • A. Yes, I do. Q. Who was that? A. Q. And tell me what you remember of that attempted interview. A. I went up to interview her with Detective Caristo, at her boyfriend's place of employment was where she was at. And she didn't wish to speak to me at that point. Q. And did she tell you why? - A. If l can refer to it. Q. Sure, go ahead. A. She said that she knew there was an investigation and that 1 had spoken to other people and, therefore, I should know what had happened at Mr. Epstein's house. Q. And did she make any other further explanation for her declining your request for an interview? A. No. Q. Did she tell you that she, like M., had positive regard for Mr. Epstein? A. I don't recall any positive regard. ti.3icylou take notes of your conversation with Ms. Page 341 1 allegedly why 1 was there, but yet she... 2 Q. Well, you told her why you were there, and she 3 then said, I'm in love with Jeffrey Epstein and have 4 nothing negative to say about him? A. Correct. 6 Q. And so am I correct that she didn't say that 7 she knew why you were there, that you're assuming that, 8 because of the timing of that interview, that she had 9 discussed the investigation with others? 10 A. It's possible. 11 Q. You don't recall anybody telling you — 12 . A. No. 13 Q. — at this time, that they had talked to M. 14 about your investigation? 15 A. No. 16 Q. Was there more than one such person, meaning 17 did anybody else that you attempted to interview about . 18. Jeffrey Epstein decline to be interviewed, to your 19 current recollection? 20 A. No. I believe she's the only one. 21 Q. Can I ask you to look at page 81, paragraph 1 22 of your incident report, and ask whether or not that • . 23 refreshes your recollection about the events of • . 24 February 15, 2006. 25 A. Yes. Page 343 1 A. No. 2 Ofild you take notes of your conversation with 3 Ms. M.? 4 A. No. 5 Q. Did you write any supplemental report 6 regarding your interview attempts with Ms. 5? 7 A. I believe I did. • 8 Q. And likewise, you have before you a 9 supplemental 1.1 that reflects your attempts to 10 interview Ms. 11 A. Yes. 12. Q. Did you ever attempt to interview a woman 13 nulled a? 14 A. Yes, I did? 15 Q. What do you recall of that interview? 16 A. She was a masseuse. I remember going to her 17 home and interviewing her at her home. And If I recall 18 correctly, she stated that what happened betwom her and 19 Mr. Epstein were between consenting adults, that she was 20 over 18 at that time. 21 Q. And did you write a report on that inns-view 22 attempt? • 23 A. I believe so. 24. Q. And in fact, you interviewed a writs of women 25 - who were over 18 years old,not only at the time of the 7 (Pages 390 to 343) PROSE COURT 'REPORTING. AGENCY, ,INC. . . • (- Electronically signed by Jeana Ricclutl (601 Electronically signed by Jeana Ricciu0 (601 a062637-abel-452c-a836-13c614e314d7a EFTA00298219 Page 344 1 interview, but also at the time of the events between 2 them and Mr. Epstein, correct? 3 A. Correct. Q. And you would incorporate those interviews within the overall 87-page incident report is that correct? A Correct 8 Q. So that the focus of this broad investigation 9 was not restricted to women under 18 and also included 10 women who were over IS; is that correct? 11 A. Correct 12 Q. Now, some of the girls that you interviewed, I 13 don't mean to be disrespectful, but some of the minors 14' you interviewed were emotional at the time of your 15 interview, is that correct? 16 A. Correct 17 Q. And if they were under 18 at the time of their 18 interview, it WAS your practice to precede that 19 • interview with some notification to their parents; is 20 that correct? 21 A. Correct 22 Q. And what would that notification be? In other 23 words, what would you tell the mother or father of a 24 minor? 25 A. That their daughter was a possible victim 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 346 THE WITNESS: Right. Some girls wart under n different ruse. They thought they were going to either model or get a chance to be in Victoria Secrets or that kind of thing, but... BY MR. WEINBERG: Q. That was the exception to the rule. A. Nobody was bound and gagged to go to the house. Q. And those that told you that they thought they were going there for some other purpose were the exception to the rule that was disclosure by whoever invited them, correct? MS. ARBOUR: Object to the fonn. THE WITNESS: Some girls, again, told me that they were going there to give massages, and some girls went there for other reasons. BY MR. WEINBERG: Q. Well, let's take one of them who claimed to have gone there for another reason. Do recall interviewing n young woman named M.? A. Yes. Q. And when did you interview her? Would the date of January 9, 2006 be consistent with your memory as to when you interviewed A. It would have been, yeah, about that time. 1 1 3 4 7 8 9 10 11 12 13 14 15 16 -17 18 19 20 21 22 23 24 25. Page 345 and/or witness in a police investigation involving a gentleman that lives in the Town of Palm Beach. Q. And had you, at the time of say by October of 2005, within 30 days of your commencing of your responsibilities in this investigation, concluded that, as to these minors, that they would not be prosecuted; that they were either victims or witnesses but not targets? A. Rephrase your question one more time, Tm sorry. Q. Sure. Let me give you a predicate. Many, if not all, of the people you interviewed were paid sums of money to give Mr. Epstein a massage at the bottom level, correct? A. Correct Q. And that they went to his house, correct? A. Yes. Q. And that they went to his house voluntarily; is that era met? MS. ARBOUR Object to the form. 311E WITNESS: Yes. BY MR. WEINBERG: Q. In other words, they weren't kidnapped or . coerced into going to his house. MS. ARBOUR: Object to the form. Page 347 1 know 1 attempted it once before and she was emotional 2 and, plus, I needed to get her father's consent because 3 she was still underage. 4 Q. When you went to visit with her father, her S father talked to you, did he not? 6 A. Either 1 telephoned him or spoke to him 7 directly. I believe I might have tel oned him. 8 Q. And the father told you that M. had told him 9 that she had been hired to model lingerie; is that 10 correct? 11 A. 1 believe so. Pm not 100 percent certain on 12 that one. I know I recall the modeling part. I don't 13 know if it was exactly lingerie or... 14 Q. Okay. The father had communicated to you that 15 his daughter had told him that her connection to Jeffrey 16 Epstein was that she went to see him as a model? 17 A. Yes. 18 Q. In other words, what you took from talking to 19 the father is that M. had likely lied to him regarding 20 her experiences with Mr. Epstein, correct? 21 A. I wouldn't say "lied to him," because that's 22 what she claimed to me, that that was the purpose of her 23 going to the house. 24 Q. But the father said that that's what she said 25 was the relationship between him [sic] and Mr. Epstein, 8 (Pages 344 to 347) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RIccluti (601 Electronically signed by Jeana Ricciuti (601 c6062637-abo1-452c-a836-bc6141,314d7a EFTA00298220 Page 348 1 that she went there as a model. 2 A I recall that that's what the father knew of 3 her going over there. 4 Q. Sure. And this isn't the first parent that 5 you interviewed that didn't know what his daughter would 6 later claim occurred to you; is that right? 7 A. What do you mem? 8 Q. In other words, many of the parents that you 9 sought permission to interview their daughters did not 10 know the details of what had transpired between their 11 daughters and Mr. Epstein, correct? 12 A. Correct. 13 Q. And in fact, no parent called you up 14 uninvited, uninitiated and said, I want to complain 15 about something that's happening in Palm Beach regarding 16 Mr. Epstein? 17 A. That's how the case first became originated, 18 but not me directly. 19 Q. Not you. 20 A. Not me directly. 21 Q. So of all of the witnesses that you 22 interviewed, there wasn't a single parent that came to 23 you as contrasted to you going to them? 24 A. No, not tome. I know that 25 Q. I understand and — 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 350 came tome and said that something bad happened to her in relation to Jeffrey Epstein. A. No. Q. And no teacher ever came to you and said, my God, I have a student who is saying that something bad or improper happened in relation to her and Jeffrey Epstein, correct? A. Correct. Q. And no religious figure ever came to you and asked you to investigate Mr. Epstein as a result of some confessional or some complaint that he received from either a minor or from a parent of a minor? A. Correct. Q. And from that, you concluded that — strike that. No doctor ever came to you and said that they had a patient that had been harmed by Jeffrey Epstein during the time period of your 2005/'6 investigation, correct? A. Correct. Q. No psychiatrist or social worker or mental health professional ever came to you and said, I have a patient or client that claims to have been banned by Mr. Epstein? A. Correct 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 349 A. -- Officer Pagan — Q. -- we'll get there. Because you never yourself interviewed .., is that correct? A. No, I did not Q. So any testimony that you have given about was derived from your reading reports that were authored by Officer Pagan and others, correct? A. Correct. Q. And amongst those reports was some indication that one of the parental figures in life had made a proactive phone call to the Palm Beach Police Department in March of 2005, correct? A. Coned. • • Q. And they had overheard some conversation about what .. claimed to have done at Jeffrey Epstein's house, correct? • A. Correct. Q. And that they were not saying, my daughter came to me and said, please call the police, something happened to me; they were claiming that they had overheard a conversation, correct? A. I believe so, yes. Q. So no parent said to you or — and there's no report that reflects a parent saying to Officer Pagan or anyone else in the Palm Beach Police Department, my kid Page 351 1 Q. And no minor ever came herself to the Palm 2 Beach Policy Department and claimed to have been alnico(' 3 or harmed by Jeffrey Epstein? 4 A. Well, after the arrest of Mr. Epstein, we did 5 have people telephone In, but... 6 Q. But not before the arrest and in fact, the -- 7 not before the grand jury returned its charge in the 8 summa of 2006, correct? 9 A. Correct. 10 Q. And then you had occasional calls from people 11 who you reported their allegations, correct? 12 A. Correct. Actually, it's Dawson — 13 Q. One was from New York and California — 14 A. — Sergeant Dawson, right. 15 Q. — and they had — they were kind of jumping 16 on the Internet train that resulted from the publicity 17 of Mr. Epstein's charge. 18 MS. ARBOUR: Object to form. 19 THE WITNESS: I don't know if you want to call 20 that as a publicity train, but some of these 21 victims were legitimate, you know. I mean, we did 22 have people call in as adults, but we had 23 legitimate victims calling in. 24 . BY MR. WEINBERG: 25 Q. And you call them legitimate victims, but just PROSE COURT REPORTING AGENCY, Electronically signed by Jeana !Melon (601 Electronically signed by Joana Ricciutl (601 -1"1""•-'," 9 (Pages 348 to 351) INC. c5062637-aba1.462c.a8341-bc6144414d7a EFTA00298221 Page 352 so the record is clear, you were not present at Page 354 trying to initiate an investigation against Mr. Epstein 7 Mr. Epstein's home on any occasion when he had a with the sole exception of the n. broad family and the 3 one-to-one or contact with any of the so-called phone call that came into the police department six 1 complainants, correct? , months before you became case agent, correct? 5 A. No. 5 MS. ARBOUR: Object to form. 6 Q. So this is not something you — you were not 6 THE WITNESS: Coned. / an eyewitness to any of the events, correct? 7 BY MR. WEINBERG: 8 A. Correct. 8 Q. So let's, if we can, go back to and try 9 Q. There was no video surveillance of what did or 9 to at least focus on one of the interviewees. 10 did not occur in the massage room on the second floor on 10 She told you that she had originally gone to 11 El Brillo; is that correct? 11 the house believing that she was going there for the 12 ' A. 'Correct. 12 purpose of modeling; is that comet? 13 Q. There was no audio surveillance of any 13 A. Correct. 14 conversations that Mr. Epstein participated in with any 14 Q. And somebody must have told her that, correct? 15 of the witnesses or complainants; is that correct? 15 A. I believe the person that took her. 16 MS. ARBOUR: Object to form. 16 Q. And do you recall who took her? Would. 17 THE WITNESS: Correct. 17 ring a bell? 18 BY ta NVIIIIIBBRO: 18 A. I believe, yes, I believe it was M. that 19 Q. You're relying on, A, what you were told and, 19 took her. 20 B, what your investigation derived? 20 Q. Do you recall writing — and this comes from, 21 A. During the sworn taped statement. 21 what I believe, is Exhibit 1 of the Palm Beach Police 22 Q. So going back to the period before he was 22 Department affidavit that "On January 9.1_20306,1 23 arrested and before there was this kind of outflow of 23 located and interviewed another victim, s date of 24 media or attention, there was not any of the different 24 birth April 29, 1988. was identified as a potent .1 25 minors that, who reside in Palm Beach, ever came to 25 victim witness from infonnation obtained during tia.‘,1 Page 353 Page 355 1 their local police department or to the Palm Beach 1 pulls from Epstein's residence." 2 Police Department and made a complaint against 2 And I represent to you I'm reading this 3 Jeffrey Epstein; is that correct? 3 accurate. 4 MS. ARBOUR: Object to form. 4 Does that refresh your memory about the going 5 TIM WITNESS: Are you limiting your 5 ton.? 6 questioning to just the persons that lived within 6 A. Yes. 7 the Town of Palm Beach limits? 7 Q. And during what period of time would they have 8 BY MR. WEIN13ERO: • a these trash pulls? 9 Q. Let me start with the people within this 9 A. That would have been documented in the report. 10 region. Did any minor ever initiate a complaint with 10 Q. Any of them after the search of October 20th? 11 you against Mr. Epstein before you had gone to them? 11 A. It might have been. 12 A. Not that I can recall, no. 12 Q. And by trash pull, we're referencing the 13 Q. And likewise, you don't know that any minor in 13 attempts by the Palm Beach Police Department to derive 14 14 investigatory material by searching the garbage that this region, before the publicity, ever went to their 15 local police department, be it in West Palm Beach or 15 came from Mr. Epstein's residence; is that correct? 16 • Daytona Beach or wherever, and said, I want to report 16 A. That is correct. 17 that I have been injured, harmed, compromised by 17 Q. And the conversations engaged in between you 18 Jeffrey Epstein. 18 and others working for you and different representatives 19 MS. ARBOUR: Object to form. 19 of the Palm Beach Sanitation Department? 20 THE WITNESS: If there was, I wouldn't be . 20 A. The Sanitation Department didn't go through 21 aware of it. ' 21 the trash; all they did was pull it for us. 22 BY Mit. WEINBERG: 22 Q. But there were conversations between the 23 Q. Your 87-page report does not reflect any 23 - police and Sanitation asking Sanitation to have a clean 24 initiative taken by any minor or any parent of a minor 24 and empty truck; is that correct? 25 ' or any professional who is associated with a minor in 25 A. Correct 10 (Pages 352 to 355) 'PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (801 Electronically signed by Jeana Ricciuti (801 C6062637-abol-452c-a336-bc614•314eila EFTA00298222 Page 356 1 Q. To drive the truck to a certain location, 2 correct? 3 A. Correct Q. To collect the trash on certain days from 5 Mr. Epstein's house, correct? 6 A. Correct. Q. You knew that Mr. Epstein's house was enclosed 8 by security gates from your surveillances there, did you 9 not? 10 A. Correct 11 Q. And that one would need to buzz in to come in? 12 A. Not necessarily. I mean, the gates leading to 13 the garage were always left unsecured, opened. 14 Q. Did you not know that the Sanitation people 15 . would buzz in and ask — tell them that they were there 16 to get the trash? 17 A. In the many, many times that I've driven by, 18 I've always seen that gate open to the garage. 19 Q. But when the Sanitation people went to 20 Mr. Epstein's house, they were there pursuant to an 21 agreement with you, that they would bring the trash to a 22 predestined location where it would be made available to 23 Palm Beach -- 24 A. Well, they were watched. 25 Q. They were watched? Page 358 1 A. Correct 2 Q. And that they would go in and you would 3 surveille them going in? 4 A. Correct. 5 Q. They would come out with the trash, correct? 6 A. Correct 7 Q. They would put it in their truck, correct? 8 A. Correct. 9 Q. They wouldn't open it and mix it with the 10. trash? 11 A. No. 12 Q. They would take special care of it — 13 A. Absolutely. 14 Q. - so that it was preserved for search? 15 A. Absolutely. 16 Q. They would drive it to a place where the 17 target wouldn't observe the transfer? 18 • A. Correct. 19. • Q. They would hand over the trash to the polio 20 officer, correct? 21 A. Correct. 22 Q. And the purpose of this trash seizure would be 23 to search the trash for investigative evidence, correct? 24 A. Correct. 25 Q. And to your understanding, that was done Page 357 1 A. They were watched. 2 Q. So you knew when they were going? 3 A. Correct. 4 Q. There was a predestined time tlx:? they worn• 5 going to go; is that correct? 6 A. Correct. Correct. 7 Q. And you saw them go onto Mr. Epstein's a property. 9 A. Correct. 10 Q. You saw them walk into, through the gates, 11 • whether they were opened or whether they were opened for 12 the people; is that correct? 13 A. Correct. 14 Q. You'd see them walk through the driveway 15 area — 16 A. Correct 17 Q. — Into the garage or near the garage, or was 18 there a point in which they disappeared from your sight? 19 A. I wasn't the one that was watching them. 20 There was other representatives of the Police 21 Department. I'm just telling you how I have always done 22 my trash pulls. 23 Q. So standard practice would be to have an 24 agreement on a time that you would meet the trash people 25 outside the target's residence. • • Page 359 1 before you commenced your responsibilities m this 2 investigation? 3 A. Before and during. 4 Q. And there was always cooperation by the Palm 5 Beach Sanitation Department, correct? 6 A. Correct 7 Q. They were, in fact, directed not to disclose 8 to Mr. Epstein that they were seizing his trash, not 9 just to bring it to the dump, but to bring it to the 10 officers, correct? 11 A. Correct. 12 Q. And again, this was done not under your watch, 13 but under your supervision while you were case agent on 14 the 2005 fall Epstein investigation, correct? 15 A. Correct. 16 Q. And from the trash, different leads were 17 found; is that right? 38 A. Correct. 19 Q. Leads that might not have been found had you 20 not gone through the trash? 21 MS. ARBOUR: Object to form. 22 THE WITNESS: I would say some, but not all. 23 BY MR. WEINBERG: 24 • Q. And you saw some message pads? 25 • A. Copies of the messages, yes. • PROSE COURT 'REPORTING AGENCY Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricciuti (601 1 11 (Pages 356 to 359) INC.. ( c6062637-abo1462c-a836-bc614.314d7a EFTA00298223 2 1 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 360 Q. And you later teamed what they were as a result of your having gone to Mr. Epstein's home on October 20th, pursuant to a warrant, and seized large numbers of message pads, correct? A. Correct Q. And there were also notes that weren't on message pads, correct, that were seized from the garbage? A. Correct Q. Notes that were on Mr. Epstein's own pad with his own name on it, correct? A. Correct Q. And some of those notes related to his business, if you know? • A. I don't believe so. Q. But some of the messages led you to phone numbers and the names of different people, such as correct? A. Correct. Q. And since Ms. M. was first interviewed on January 9,2006, is it fair to say that the trash pull from which her identity was first revealed, occurred in the fall 2005 period while you were case agent? A. I don't know. Without seeing the actual • message, I can't commit to that kind of answer. Page 362 1 Q. Was it your understanding that Ms. M. had 2 been there months before January 9, '06 as contrasted 3 two years? 4 A. As far as, I'm sorry? 5 Q. When you interviewed her on January 9,'06 6 A. Right. 7 Q. — was she telling you of events that occurred 8 years before or months before, if you recall? 9 A. I can't recall. 10 Q. But you do meal! M. was her contact; she 11 was the person who invited her to go to Mr. Epstein's 12 home? 13 A. I believe so. 14 Q. And M. was currently in love with 15 Mr. Epstein in or around the same time period? 16 A. That's what she claimed to me. 17 Q. And did your investigation disclose whether 18 Ms. M. was currently seeing Mr. Epstein in the fall of 19 2005 into the early 2006? 20 A. I can't recall if she was still going to the 21 residence. 22 Q. Ms. ■ told you she was originally told she 23 would be able to model lingerie for a wealthy Palm 24 Beecher, is that correct? 25 A. That's what I documented. That's what she Page 361 1 Q. Did Ms... tell you when, in relation to 2 January 9, 2006, she had last been to Mr. Epstein's 3 home? 4 A. I can't recall. 5 Q. Did you ask these witnesses, whom you were 6 interviewing, what time period they recall being at his 7 house? 8 A. Yes. 9 Q. And if there is nothing in the report, would 10 that reflect — II A. Well, you're looking at the probable cause 12 affidavit The report will reflect more. 13 .Q. The incident report was — the probable cause 14 affidavit was a subset of the affidavit — strike that. 15 The affidavit is a subset of the incident 16 teport. 17 A. Correct 18 Q. If it's not in the incident report, then does 19 that reflect that you did not ask that question of .? 20 A. I would have asked regardless. 21 Q. Did it inflect that she didn't give you an • 22 answer? 23 A. Some witnesses were able to recall specifics; 24 others were not able to recall exactly when, pinpoint 25 what time. Page 363 1 told me. 2 Q. And that she was taken to Mr. Epstein's home 3 at El Brillo Way by Ms. M.; is that consistent with 4 your memory? 5 A. Yes. 6 Q. And Ms... introduced her to Mr. Epstein; is 7 that correct? 8 A. Yes. 9 lIlAnd you have no independent memory that 10. Ms. M. ever said that she had any conversation with 11 Mr. ein prior to her being introduced to him by 12 Ms. M.; is that correct? 13 . A. If she had prior conversations with — 14 Q. Yes, with Mr. Epstein before sbe was brought 15 to the house and introduced — 16 A. I can't recall whether she said that or not. 17 I don't believe so. 18 Q. Let me broaden it. Most of the people, if not 19 all of people who you interviewed, were introduced to 20 Mr. Epstein by some other young woman; is that correct? 21 MS. ARBOUR: Object to form. 22 THE WITNESS: Correct. 23 BY MR. WE114BERO: 24 . Q. Whether Ms... was one,.., correct? 25 • A. Right. • 12 (Pages 360 Lo 363) PROSE COURT REPORTING AGENCY INC. ( Electronically signed by Jeana Rlcciuti (601 Electronically signed by Jeana Rlcciuti (601 c5062637abe1.452c-aS3Sbe814a314d/a EFTA00298224 Page 364 Page 366 '1 Q. M. was the second; is that correct, that 1 BY MR. WEINBERG: 2 brought people to his house? 2 Q. Or make phone calls to people that she was not 3 A. (Non-verbal response). 3 introduced to, correct? 4 Q. The routine and practice was for the pimple 4 MS. ARBOUR: Object to fonn. 5 that were introduced to him not to have had any prior 5 THE WITNESS: I knew she made several phone 6 conversations with him until they were introduced by an 6 calls, but it was to people that she knew that had 7 intermediary lace Ms. ■ or Ms. M.; is that correct? 7 been to the house previously. 8 MS. ARBOUR: Object to form. 8 BY MR. WEINBERG: 9 THE WITNESS: I believe so. 9 Q. Sure. So let me take it one step back then. 10 BY MR. WEINBERG: 10 The routine and practice was for one — let's focus on 11 Q. And in fact, there were no exceptions to that 11 — for a woman such as Ms. M., to introduce 12 rule as fares you currently remember? 12 Mr. Epstein to people that she had met or who were her 13 MS. ARBOUR: Object to form. 13 friends, correct? 14 THE WITNESS: As far as I can recall. 14 A. Uh-huh. 15 BY MR. WEINBERG: 15 MS. ARBOUR: Object to form. 16 Q. I mean, you have no — you don't recall any 16 BY MR. WEINBERG: 17 information that Mr. Epstein was out himself personally 17 Q. And likewise, the.. introduction of.. 18 trying to connect with young strange women. 18 fa that standard practice of one woman taking a second 19 A. No. 19 woman to Mr. Epstein and introducing them, correct? 20 Q. And likewise, you have no evidence that 20 MS. ARBOUR Object to form. 21 Mr. Epstein was e-mailing people that he didn't know 21 THE WITNESS: Correct. 22 attempting to ask than or invite than or recruit than to 22 BY MR. WEINBERG: 23 come to his home. 23 Q. And Ms. IIR, at least, told you during your 24 A. No. 24 interview with her in the first week of October 2005, 25 Q. And you have no evidence that Mr. Epstein, 25 that all of the young women that she introduced to Page 365 Page 367 1 himself; personally was on a telephone trying to connect 1 Jeffrey Epstein knew exactly why they were going to 2 with people to whom he had not previously been 2 . Mr. Epstein's home. 3 introduced, correct? 3 MS. ARBOUR: Object to form. 4 A. People not known to him? 4 MS. FINNIGAN: Joined. 5 Q. Yes. 5 THE WITNESS: That is what I recall during the 6 A. No, not that I'm aware of. 6 interview. Q. And so that an one — let me ask the same 7 BY MR. WEINBERG: 8 questions for Ms. You're familiar with 8 Q. And that was corroborated by your reading the 9 her, are you not? 9 report that M. said that she knew what she was doing 10 A. Yes. 10 before she went to Mr. Epstein's home, correct? 11 Q. And you have no evidence that she was out 11 MS. ARBOUR: Object to form. 12 driving around the Palm Beach area looking to meet some 12 • TIME WITNESS: I believe so, yes. 13 young woman who she, herself, could go and introduce to 13 BY MR. WEINBERG: 14 Mr. Epstein, correct? 14 Q. It was corroborated by others who were 15 MS. ARBOUR: Object to form. 15 identified by M. and thereafter interviewed by you and 16 BY MR.. WEINBERG: 16 others working with you, correct? 17 Q. People that she had never previously met? 17 • MS. ARBOUR: Fenn. 18 MS. ARBOUR: Same objection. .18 THE WITNESS: I believe so. 19 THE WITNESS: Not that I'm aware of. 19 BY MR. WEINBERG: 20 BY MR. WEINBERG: 20 • Q. So that at least for the.. group, if I can 21 Q. And likewise, no evidence that she would 21 • • confine than to by definition the people introduced to 22 e-mail people who she was not introduced to? 22 Mr. Epstein by Ms. M., none of them ever informed you 23 MS. ARBOUR: Object to form. 23 that they had gone there under a misapprehension as to 24 THE WITNESS: Not that Im aware of. 24 what was expected of them, correct? 25 25 • MS. ARBOUR: Object to form. 13 (Pages 364 to 367) PROSE COURT REPORTING AGENCY, INC. . • Electronically signed by Jeans RIccliM (601 Electronically signed by Jeana Ricciuti (601 c60626374b01412c4836-bc614•3144ffis EFTA00298225 Page 368 1 TIM WITNESS: Under the ■ group we're 2 taring about? 3 BY MR. WEINBERG: 4 Q. Yes. Let me break it down. Ms... 5 identified approximately six people that she had 6 introduced to Mr. Epstein. 7 A. Correct. 8 Q. And each of them was invited by Ms... to go 9 to Mr. Epstein's residence, correct? 10 A. Correct. 11 Q. And Mr. Epstein did not know any of these six 12 yotmnvomen prior to being introduced to them by 13 Ms. M., correct? 14 MS. ARBOUR: Fonn. 15 THE WITNESS: As far as I 'mow, yes. 16 BY MR. WEINBERG: 17 Q. And you have no knowledge that IMI=, 18 or anyone else that resided at Mr. Epstein's home on 19 El Brillo had any prior or independent relation with any 20 of the six girls that was being introduced to 21 Mr. Epstein by Ms. M.; is that correct? 22 MS. ARBOUR: Form. 23 THE WITNESS: As far as I know. 24 BY MR. WEINBERG: 25 Q. Ms. H.R. was asked by you and told you that Recto 370 1 BY MR. WEINBERG: 2 Q. And they came from her pool of friends or 3 associates or people that she made an independent 4 decision to sec whether or not they wanted to go and 5 me