1 IN 741E CIRCUIT COURT OF THE FIFTEENTH JUDICIAL MOAT

Page 500 1 IN 741E CIRCUIT COURT OF THE FIFTEENTH JUDICIAL MOAT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 CASE No.50200SCA037315000004B AB 3 4 Plaintiff. 5 6 -vs- VOLUME IV OF IV 7 9 10 11 12 13 14 15 16 Defendants DEPOSITION OF DETECTIVE JOSEPH RECAREY Friday, March 19, 2010 10:03 - 5:23 p m 505 South [take Drive Suite 1100 17 West Palm Beach, Florida 33401 18 19 20 21. 22 Reported By. Jana Ricciuti. Mit FPR. CLR 23 Notary Public. Stew of Florida Prose Gault Reporting 24 25 I 14 15 16 17 la 19 20 21 22 23 24 25 1 APPEARANCES 2 On tehalf Janc Den I thectralt 8: JESSICA 1 BOOK ESQUIRE MERME1812:214 & HOROW112, l'A. W205 lagoon nukearr1 Son 2218 S Mphonironit e 6 7 On batonMtn Plaintiff, lane Doe Nall: ISOM MANUEL Minn mom GARCIA. ELKINS & BOEFIFUNGER 9 224 Dina Mew Saito 900 War tide 33401 Phan 11 sad 12 TARA k FINNIGAN, !MUM TARA& FINNIGAN. PA 13 VA Miura Street State WO West Pailliarida 33401 Mono an Wulff of the Datong, hffny Emleos MICHAEL PIKE, ESQUIRE BURMAN, CRIITOR LETT/ER& COLEMAN, LIP 303 014066 Boolean Stile 4'.0 West /MC 33401 Phone' and MIUION O. Whl MIRO. ESQUIRE LAW00110E OF MILTON G. WEINBERG 20 Pin Pima Suite WOO, Bent 02116 Moue: I',-1r 502 I a Page 5C. 1 2 3 5 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 uNDED STATES DISTRICT COURT SOUTHERN DISTRICT OP FLORIDA CASE NO.10-80309 JANE DOE NO. 103. Plaintiff, VOLUME IV OF IV JRPFREY CPSIEIN, Defendant. DEPOSITION OF DEIECTIVE JOSEPH RECAREY Tuesday, April 27, 2010 10:03 - 5:23 pm. 505 Saab Flagler Drive Stitt 1100 Weft Palm Beach, Florida 33401 Reported By: Jam Fticciuti, RPR, FPR, CLR 23 Notary Public, State of Florida Prose Cain Reporting 24 25 Page 503 1 Appearances continued... 2 On behalf of the Witness: ' 3 JOANNE M. O'CONNOR, ESQUIRE JONES, FOSTER, JOHNSON & STUBBS, P.A. 4 505 South Flagler Drive, Suite 1100 West Florida 33401 5 Phone: 6 7 Also Present Jeffrey Epstein 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 .... - 2 (Pages PROSE. COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricci uti (601 ) Electronically signed by Jeana RIccluti (601 ) 500 to 503) bdcd1876•c7242.432(1-8c40-0190e656129/ EFTA00298342 Page 504 Page 506 1 INDEX 2 3 I wrrNESS: COMM CROSS CROSS REDIRECT RECROSS 5 DETECTIVE JOE RECAREY 6 BY MR. WEINBERG 505 BY MS. ARDOUR 636 7 BY MR. GARCIA 636 9 10 - - - EXHIBITS 11 12 NUMBER DESCRIPTION PAGE 13 DEPOSITION EX. 29 MESSAGE BOOKS 592 DEPOSITION EX. 30 HANDWRITTEN NOTE ON 617 14 JEFFREY E. EPSTEIN MEMO PAD 15 DEPOSITION EX. 31 HANDWRITTEN MESSAGE 622 16 17 18 19 20 21 22 23 24 25 1 counsel? 2 MS. ARBOUR: Form. 3 THE WITNESS: I believe so, yes. 4 BY MR. WEINBERG: 5 Q. And that was an offer that was extended by the 6 State Attorney following discussions with the Palm Beach 7 Police Department, correct? 8 A. That was when we had just heard about it. We 9 were unaware that the offer was made. 10 Q. And how did you become aware that the offer 11 was made? 12 A. I had made numerous telephone calls to the 13 State Attorney's office to inquire where we were, and 14 did not receive any return phone calls. I went over to 15 the State Attorney's office personally on an tmrelated 16 incident to drop off some filittpackets, and that's 17 when I went by and I saw =was in her office. 18 Q. was an experienced State attorney, 19 correct? 20 MS. ARBOUR: Form. 21 THE WITNESS: I know she had been there for 22 some time. 23 BY MR. WEINBERG: 24 Q. And you knew she had been a prosecutor for sex 25 offense cases for some time, 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 505 PROCEEDINGS BY MR. WEINBERG: Q. Good afternoon, sir. A. Good afternoon. Q. To finish up the subject that we were talking about right before the recess, do you ever recall dicr-ncsions with the State Attorney's office about an offer that was extended to Mr. Epstein to plead guilty and receive a five-year period of probation for an aggravated assault charge? A. Yes. Q. And that was a subject of discussion between you and members of the State Attornes fice? A. With Assistant State Attorney I don't know if that's her last name, how it's pronounced, but close enough. Q. If we call her =, I think we both know who we're discussing. A. Yeah. Q. And those discussions occurred within or around the winter of 2005,'6? A. I believe so. Q. And was that a sentence and a charge option that was extended to Mr. Epstein through his then Page 507 1 A. She did a lot of crimes against children. 2 Q. And she, on other occasions, advocated 3 prosecution of people on felony charges, correct? 4 A. I hadn't had many dealings with her so I don't 5 know. You know, l knew Mier. She was actually at the 6 office, State Attorney's office, when I was employed 7 there many years ago. 8 Q. And that was how many years ago? 9 A. I've been with Palm Beach almost 19 years. 10 Q. So we're talking about at least 20 years ago? 11 A. Yeah. 12 Q. And she had been there, to your knowledge, 13 continuously from the time that you knew she was there 14 20 years ago? 15 A. Yeah. 16 Q. And you knew her specialty to be charging 17 people that were — for offenses that dealt with 18 violations of underagtal people, mama 19 MS. ARBOUR: Fonn. 20 THE WITNESS: I believe so. I believe so. 21 Like I said, I didn't have many dealings with her. 22 BY MR. WEINBERG: 23 Q. So you saw her in the office that day? 24 A. And that was the time that I just had learned 25 of the offer that was made to previous counsel. PROSE COURT REPORTING AGENCY, Electronically signed by Jeana ificciuti (801M Electronically signed by Jeana Moduli (601 3 (Pages 504 to 507) INC. bdecH 876 c72o.432d-8c10-bt 9ac656129t EFTA00298343 Page 508 1 Q. And did you take a position on that offet? 2 A. Personally, I told her I didn't agree with it, 3 but I couldn't speak for the department. It actually 4 had to come from people with a higher pay grade than 5 mine, so I just relayed the information back to 6 Chief Reiter. 7 Q. And what, if anything, did Chief Reiter do? 8 MS. ARBOUR: Form. 9 THE WITNESS: I believe he tried to make 10 contact with State Attorney Barry Krischer. 11 BY MR. WEINBERG: 12 Q. Did he make contact with State Attorney 13 KriSehe', to your knowledge? 14 A. I'm not 100 percent certain if he did or 15 didn't. I bow there was some time where none of our 16 calls were being returned from the State Attorney's 17 office. 18 Q. Jane Doe 103 was one of the witnesses who was 19 at the center of the State investigation, correct? 20 A. One of them, yes. 21 Q. And you knew that Jane Doe 103 had a MySpace 22 page that was one of the MySpace profiles that was 23 provided to the State Attorney by Mr. Epstein's then 24 counsel, Professor Dersbowitz, correct? 25 A. Yes, I knew that there were pages sent of the Page 510 1 correct? 2 MS. ARBOUR: Form. 3 THE WITNESS: f know that when there's 4 misdemeanor arrests in the Town of Palm Beach, a 5 lot of officers pretty much try to gain any 6 intelligence they can from any of the people that 7 they encounter. Some of the information actually 8 leads to other cases, clearance of minor rocas 9 thefts, bike thefts. 10 BY MR. WEINBERG: 11 Q. And in this case, it led to you going to sec 12 Jane Doe 103, first calling her on October 10th and then 13 visiting ha in Jacksonville on October 11th, correct? 14 A. Yes. I5 Q. And you also, in your investigation, learned 16 that Jane Doe 103 had lost her job at Victoria Secret 17 for stealing, did you not? 18 A. No. 19 Q. You never received any information regarding 20 Jane Doe 103's employment history with Victoria Secret? 21 A. She was actually employed there when I went up 22 to seeker. Thrift where I met with her. 23 Q. Did you ever team at any time that she had a 24 problem that led to her losing her employment? 25 A. No. Page 509 1 MySpaces, but I wasn't sure of whom at that particular 2 time. They provided us copies thereafter, but right 3 there, immediately, I wasn't aware of whom had pages. 4 Q. You eventually received than and reviewed 5 than, correct? 6 A. tJb-huh. 7 Q. And you understood that from even before then, 8 that Jane Doe 103 had a background that involved at 9 least one arrest, correct? 10 A. Yes. 11 Q. And you understood that when she was arrested 12 in early October, she in fact informed the arresting 13 officers that she had information regarding Mr. Epstein, 14 correct? 15 A. I believe so. 16 Q. And if you go to your probable cause affidavit 17 ai page 11, at the bottom of 10, it starts, 'On 18 September 11, 2005, Jane Doe 103 was arrested by the 19 Palm Beach Police Department for misdemeanor possession 20 of marijuana. During the arrest, Jane Doe 103 told the 21 arresting officer that she had information about sexual 22 activity taking place at the residence of Mr. Epstein." 23 A. Yes. 24 Q. Jane Doe 103 essentially was asking the 25 arresting officer to assist in her cooperating; is that Page 511 1 Q. So you knew she had been arrested for 2 marijuana? 3 A. Uhelmh. 4 Q. You knew she had a MySpace page where there 5 was information that was -- that showed her to use 6 thugs, correct? 7 A. Uh-huh. 8 MR. PIKE: Yes or no? 9 THE WITNESS: Yes. 10 BY MR. WEINBERG: 11 Q. You knew that the role of the State Attorney, 12 the prosecutor that would have to present this case to 13 the jury, was to weigh evidence, correct? Not only the 14 evidence you provided but also any evidence that was 15 provided by those representing the target of criminal 16 investigation? 17 A. Yes. 18 Q. And knew that as a result of that weighing 19 process, =, an experienced State Attorney, told you 20 that she believed at least that Jane Doe 103 was a 21 consenting participant and not a victim of criminal 22 offenses by Mr. Epstein, correct? 23 MR. GARCIA: Object to the form. 24 THE WITNESS: I don't — consenting victim, 25 you mean? 4 (Pages 508 to 511) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciutl (601 Electronically signed by Jeana Ricciutl (601 bdcd1876-c720.432d-acre-blbae6561291 EFTA00298344 Page 512 P&p:: .., 14 1 BY MR. WEINBERG: 1 case, "Is it okay to take a taxi". 2 Q. She told you that there were no victims here 2 MS. ARBOUR: Form. 3 when — 3 BY MR. WEINBERG: 4 A. Originally, that was her statement, yes. 4 Q. Is that right? 5 Q. Right. And if there were no victims here, 5 MS. ARBOUR: Same objection. 6 then she's really saying to you that, after reviewing 6 THE WITNESS: Yes. 7 all of the evidence that she received, not only from you 7 BY MR. WEINBERG: 8 but from the defense, she didn't consider Jane Doe 103 8 Q. So whoever was at die Epstein home receiving 9 to be a victim? 9 the call would essentially write this denim on a message 10 MS. ARBOUR: Form. 10 pad that had at least two different layers? 11 111E WITNESS: 1 believe that's what she 11 MS. ARBOUR: Fem. 12 stated. 12 THE WITNESS: Yes. 13 BY MR. WEINBERG: 13 BY MR. WEINBERG: 14 Q. And given her knowledge of what occurred on El 14 Q. And that when you seized the message pad from 15 Brillo Way, she didn't see any victims in this case. 15 the trash pulls, there was only one layer, which was the 16 MS. ARBOUR: Form. 16 original that had been thrown out or crumpled out, 17 THE WITNESS: 1 believe that's what she 17 correct? 18 stated. 18 A. Yes. 19 BY MR. WEINBERG: 19 Q: AM when you went on October 20th and 20 Q. Whether or not she physically did possess the 20 conducted a search and seizure, you would seize the pads 21 message pads or whether she had access to information, 21 that included all of the copies of the original 22 the message pads that you reviewed were in the hundreds, 22 messages, correct? 23 if not thousands, correct? 23 A. Yes. 24 A. Uh-huh. 24 Q. And they were in various handwriting, were 25 Q. And that these pads reflected incoming calls 25 they not? Page 513 Page 515 1 to Mr. Epstein's phone that was in Mr. Epstein's 1 A. Yes. 2 residence on El Brillo, correct? 2 Q. And they provided you with leads to witnesses, 3 A. Correct. 3 did they not? 4 Q. And they reflected messages that came from 4 A. Yes. 5 people that left their phone numbers? 5 Q. And provided you with names and numbers? 6 A. Yes. 6 A. Yes. 7 Q. And it reflected messages that included, for 7 Q. And gave you information that there was lots 8 instance, from.. on July 9, 2004, is available 8 of people who, at least according to these telephone, 9 on Tuesday. Was that a message that was concluded in 9 incoming telephone calls, were inviting themselves to 10 these message pads? 10 Mr. Epstein's home — 11 MS. ARBOUR: Form. 11 MS. ARBOUR: Form. 12 111E WITNESS: Yes, that was some like that, 12 BY MR. WEINBERG: 13 yes. 13 Q. — either directly or through their friends, 14 BY MR. WEINBERG: 14 correct? 15 Q. And that is clutmeteristic of lots of the 15 MS. ARBOUR: Form. 16 messages that were being received by whoever was taking 16 MR. GARCIA: Object to form. 17 down a message at the Epstein residence, correct? 17 THE WITNESS: There were several messages that 18 . MS. ARBOUR: Form. 18 I recall was written to Mr. Epstein indicating 19 THE WITNESS: Iih-huh, yes, correct. 19 girls' names and times that they were available. 20 BY MR. WEINBERG: 20 BY MR. WEINBERG: 21 Q. And the way it worked, if I'm right, is that 21 Q. Like, for instance here, she wants to confirm 22 somebody would answer the phone and, for instance, the 22 a 11:00 tomorrow, message for JAE from a woman's name. 23 message would say on July 19, '04, Mr. Epstein: Phone 23 That would be typical messages on these pads that you 24 call from M., leaving a reply mobile phone number or 24 reviewed? 25 cellular number, and leaven very short message, in this 25 MS. ARBOUR: Form. 5 (Pages 512 to 515 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeans Ricciuti (601 bdcd1876-c720-432(1-8c10-b19iie6.56129f EFTA00298345 21 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 516 THE WITNESS: That would be some, yes. BY MR. WEINBERG: Q. And many of them appeared to be incoming calls from different girls which said, Em in town, can I come over, can I schedule a meeting? MS. ARBOUR: Form. THE WITNESS: Some were like that. BY MR. WEINBERG: Q. And some appeared to be responses to a phone call made by someone at the El Bulb home asking, are you available, and there would be a phone call back saying, Pm available tomorrow afternoon or Wednesday morning or Thursday afternoon. A. Correct. Q. And by and large, these messages did not include any negotiation over dollars? In other words, there was not on a message pad that any of these incoming girls were saying, I will come over ifIeffrey gives me $500 or $300; there was no evidence of that kind of incoming phone call, correct? MS. ARBOUR: Form. THE WITNESS: Not that I can recall, no. BY MR. WEINBERG: Q. And likewise, there was no indication on these message pads that any of the people calling 1 of 18; is that right? 2 A. What groupings? 3 Q. Well, let's say, did you ever interview a 4 woman named II.? 5 A. Yes. 6 O. And youlcnew that her date of birth was in 7 and that she was over 18 when you 8 interviewed her — 9 A. Yes. 10 Q. — and represented herself to be over 18 when 11 she saw Mr. Epstein? 12 MS. ARBOUR: Font 13 THE WITNESS: Yes. 14 BY MR. WEINBERG: 15 Q. And, likewise, was another person who 16 said yes, she had been to Mr. Epstein's house at a time 17 when she was over 18? 18 A. Correct 19 Q. And then M. was in her 20s when you 20 interviewed her? 21. A. Yes. 22 Q. And there was an., who after the publicity 23 came out, called in and said she was 25 at the time she 24 met with Mr. Epstein? 25 A. Yes. I I Page 517 1 Mr. Epstein's home were, in essence, particularizing 2 what they were going to do or what they intended to do 3 or what they might do once they got there, correct? 4 MS. ARBOUR: Form. 5 THE WITNESS: Can you repeat that question? 6 BY MR. WEINBERG: 7 Q. Sure. Theres nothing on these message pads 8 that indicates, I'll come over and give a topless 9 massage to Mr. Epstein? 10 A. No. 11 Q. These are essentially contact and scheduling 12 calls? 13 MS. ARBOUR: Form. 14 THE WITNESS: Yes. 15 BY MR, WEINBERG: 16 Q. And often reflect the fact that the callers 17 are not connecting on the first call, so they're going 18 back and forth and trying to arrange times for a 19 particular woman to come over to Mr. Epstein's home, 20 correct? 21 MS. ARBOUR: Form. 22 THE WITNESS: Yeah. 23 BY MR. WEINBERG: 24 Q. And some of these calls come from a whole 25 grouping of persons that you learned were over the age Page 519 1 Q. And., who you interviewed, who told you 2 that yes, she went to Mr. Epstein's home on many 3 occasions, and she was over 187 4 A. Yes. 5 Q. And a 6 A. She was a licensed masseuse. 7 Q. Licensed masseuse who was over 18. 8 A. Yes. 9 Q. And some of the people interviewed had tumcd 10 18 during the period that they were seeing Mr. Epstein 11 and so told you, correct? In other words, that they had 12 started seeing Mr. Epstein when they were 17, and then 13 they became 18 and continued to see him when they were 14 18 and, in fact, you interviewed them when they were 18? 15 MS. ARBOUR: Form. 16 THE WITNESS: Some, yes. 17 BY MR. WEINBERG: 18 Q. And they, too, are included in Mese book of 19 message pads? In other words, this was not limited, the 20 incoming calls were not limited to girls that were 17 or 21 16, and included girls that were 18, 19,20, 25 and even 22 older, correct? 23 MS. ARBOUR: Form. 24 THE WITNESS: Correct. 25 BY MR. WEINBERG: PROSE COURT REPORTING AGENCY, Electronically signed by Jeana Rlcciuti (401Ia Electronically signed by Jenne Ricclutl (601 6 (Pages 516 to 519) INC. (561) 832-7506 bded18714:726432d4d0-019.44561291 EFTA00298346 9 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 520 Q. Now, when you drafted the search warrant 7 affidavit and you agreed with me that you understood 3 when you drafted it, as an experienced detective of 4 almost two decades, that the judge would be relying on 3 the content of what you preiented to him, correct? 6 A. Yes. 7 MS. ARBOUR: Form, asked and answered. BY MR. WEINBERG: Q. That the judge did not have some external bases to test the representations, either for completeness or for accuracy? MS. ARBOUR: Form. THE WITNESS: Correct. BY MR. WEINBERG: Q. And you made representations in the search warrant affidavit that were repeated in the probable cause affidavit, did you not, that were attributed to A. Yes. Q. And directing myself to the probable cause affidavit, because that's the one that is unsealed and an exhibit in this case, you essentially said to, on the probable cause affidavit, that M. said that Jeffrey Epstein wanted young girls — A. Yes. Page 522 1 now almost five years ago, that she had said to you that 2 Jeffrey Epstein preferred girls between 18 and 20. 3 A. I would have documented that in the incident 4 report, but... 5 Q. Would it be an important modification of the 6 statement attributed to her that Jeffrey Epstein wants 7 young girls, correct? 8 MS. ARBOUR: Form. 9 THE WITNESS: Had she said it, but again, I 10 don't — I 1 BY MR. WEINBERG: 12 Q. I understand. Had she said it, it certainly 13 would have been considered important enough to include 14 in the various affidavits that you drafted that relied 15 in part on what told you. 16 MS. ARBOUR: Form, the tape speaks for itself. 17 BY MR. WEINBERG: 18 Q. Correct? 19 A. Correct. 20 Q. The message pads include messages like, was 21 wondering if she would get work tonight, she couldn't 22 work yesterday because of some family event. That's the 23 messages, those contents, you would have view of the 24 message pads, correct? 25 MS. ARBOUR: Form. It speaks for themselves. Page 521 1 Q. correct? 2 Do you recall that during your tape recorded 3 interview with M., she told you that Jeffrey Epstein 4 preferred to receive massages from girls between 18 and 20 years old? A. I recall her slating, "The younger, the 7 better," but I don't recall that he prefers girls 8 between 18 and 20. 9 Q. Will augrce with me that if the tape 10 recording of interview with you reports that as a 11 statement made by her, that the tape recording would be 12 the most accurate source of what she told you back in 13 early October 2005? 14 MS. ARBOUR: Form. 15 MR. GARCIA: Do you have the tape recording to 16 play, because my understanding is that's under FRI 17. control. 18 MR. WEINBERG: asking questions about 19 whether or not it included — 20 MR. GARCIA: Without playing the tape 21 recording, I think it's an unfair question. 22 MR. WEINBERG: You can object. I'll ask it. 23 THE WITNESS: If the recording indicated? 24 BY MR. WEINBERG: 25 Q. That III. told you in early October of 2005, Page 523 1 THE WITNESS: Oh-huh. 2 BY MR. WEINBERG: 3 Q. Did you ever interview n woman named M.? 4 A. I attempted it, and I don't think she ever 5 returned my calls. 6 Q. Did you cvcr go to her house? A. Let me think. I may have. I mean, I can't 8 recall if I went to her house or not, but I know I 9 telephoned her and I never got any call back from her. 10 Q. Did you, dining this investigation, ever, 11 yourself, go to MySpace pages to conduct any background 12 investigation on the various women that you were 13 proffering to the State Attorney as reliable witnesses? 14 MR. GARCIA: Objection, asked and answered. 15 MS. ARBOUR: Joined. 16 THE WITNESS: Again, I looked at them when 17 they were turned over, but no, l didn't. 18 BY MR. WEINBERG: 19 Q. I'd ask you to look at page 65 of the incident 20 report, paragraph 4, and see if that refreshes your 21 recollection. 22 A. Yes, I did. 23 Q. And do you recall just how you accessed 24 MySpace? Did you run through a list of all your 25 witnesses and saw whether or not certain of them had 7 (Pages 'PROSE COURT REPORTING .AGENCY, INC.. Electronically signed by Jeana Ricciuti (601M Electronically signed by Joana Rlcciu0 (601 520 to 523) bdcd1876c72e-432d-13cf0-b19no6561291 EFTA00298347 Page 524 Page 526 1 2 A. Correct. 3 Q. And you concluded that -- ifs all redacted 4 hero, but it looks like 10 or 12 of your witnesses had 5 6 A. Correct. 7 Q. And did you download the infonnaticm from 8 these MySpace pages into sonic evidentiary format? 9 A. I believe either I printed them or I might 10 have viewed them and made reference of it, that 11 they had a MySpace page. 12 Q Did you ever study the contents of the MySpace 13 page? 14 15 16 17 18 19 20 21 22 23 24 25 MySpace pages? MYSPoce Pages. A. The ones that were viewable, 1 looked at. Thu ones that weren't, eventually they all became private. Q. And the ones that were viewable, did you identify certain of your witnesses as including in their MySpace page evidence that they were involved in the use of drugs? A. I recall pictures of like a marijuana leaf, comments made of being high when the photo was taken and some alcohol use. I remember that as well. Q. And did you include those obsavations in your incident report that ultimately would have gone to the State Attorney to assist the State Attorney in assessing 1 Beach, Mr. Epstein? 2 A. Yes. 3 Q. And the question is: You went on MySpace, you 4 looked at certain pages that reflected at least some of 5 your witnesses who were not only using drugs but 6 bragging about using drugs publically and publishing 7 pictures or references to themselves as drug users, 8 correct? 9 A. On the MySpace page, right. 10 Q. Right. Did you do anything else, as an 11 experienced investigator, to try to determine by 12 through the investigation into the background of any of 13 the witnesses? 1 4 A. I believe I checked than under the local 15 systems to see if they had been arrested. I did like a 16 criminal background check on them and the sworn taped 17 statement that we took as well. 18 Q. October 20th you went to Mr. Epstein's home 19 with a group of others; is that correct? 20 A. Uh-huh. 21. MR. PIKE: Yes? 22 THE WITNESS: Yes. 23 BY MR. WEINBERG: 24 Q. And you went there with a search warrant — 25 A. Correct Page 525 1 the credibility of the people that you were proffering 2 to them as witnesses? 3 A. Did I include those in with the State I Attorney? I believe they had them by then. That was the winter of '05, '06. 6 Q. But this was an independent review of MySpace 7 that was not related to what Professor Dershowitz gave the State Attorney; this was something you were reporting that you did on your own, correct? 10 A. I tray have done it on my own to view it myself 11 after learning from the State Attorney's office. I'm 12 not —I can't recall if I did it totally on my own or 13 when I first heard of the MySpace pages, J researched it 14 myself to view it myself. 15 Q. Did you do anything other Than look at MySpace 16 pages to try to assess the credibility of any of your 17 witnesses based on what you could learn about them from 18 other people? In other words, you were essentially 19 proffering to the State Attorney certain statements that 20 had been made to you regarding what occurred on El 21 Milo Way, correct? 22 A. Uh-huh. 23 Q. And you were relying on those statements and 24 their detail as a basis for asking the State Attorney to 25 bring a criminal prosecution against a residence of Palm Page 527 1 Q. — correct? And in the search warrant, you 2 requested the authority to seize all computers, all 3 equipment, any discs, any DVDs, any media, correct? 4 A. Uh-huh. 5 MS. ARBOUR: Form, asked and answered. 6 THE WITNESS: Correct. 7 BY MR. WEINBERG: 8 Q. And you seized whatever you found there, 9 correct? 10 A. Yes. 11 Q. And you, yourself, looked through what you could look through and asked your forensic people to :3 look through what you couldn't look through; is that 14 correct? 15 A. That is correct. 16 Q. And as a result of the search and seizure, 17 there was no picture of Jane Doe 103 that was seized, 18 correct? 19 A. That's correct. 20 Q. And there was no camera that was found in the 21 massage room, no coven camera found in the second floor 22 massage room of the Epstein home, correct? 23 MS. ARBOUR: Form. 24 THE WITNESS: No, we did not find a camera 25 that day, no. ccers 1/4.-7,- a -2--,44.4aredeSev*......-4t-YeetSiers, Mr-nteaf J 8 (Pages 524 to 527 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana IlIcciutl (601 Electronically signed by Jeans Riccluti (601 bded1876-c726-432da-f041 9666661291 EFTA00298348 Page 529 Page 530 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 BY MR. WEINBERG: 2 Q. The only camera you found was the camera that 3 you knew about from your 2003 investigation, the one 4 that was in the clock aimed at Mr. Epstein's desk and 5 the second camera that was in the garage, correct? 6 A. We found, yes, the second camera in the 7 garage- • 8 Q. Did you ever, on any other day, find any 9 camera other than the cameras you, yourself, installed 10 in 2003 and the camera that Mr. Epstein pointed out to 11 you in 2003 from the lint floor area? 12 A. No, we didn't see — we didn't find any other 13 cameras. 14 Q. And you had only been to his house, twice; is 15 that correct? Once — 16 A. The day of the search warrant and the day that 17 I assisted by putting the cameras. 18 Q. You never went back in and altered his home 19 after October 20, 2005, did you? 20 A. No. 21 Q. Do you know of any audio or wire electronic 22 interceptions that were directed against Mr. Epstein or 23 his residence at any time by anyone? 24 A. No. 25 Q. There were certainly none that was connected 1 THE WITNESS: Yes. 2 BY MR. WEINBERG: 3 Q. At any time prior to that, did Jane Doe 103 4 ever call you and say that she was concerned about an 5 investigator? 6 A. Yes. 7 Q. And did she call — do you recall when she 8 called you? Before or after the service of the 9 subpoena, if you remember? 10 A. It was before. 11 Q. And did she call you at night or in the day 12 time? 13 A. I believe she called me in the evening time 14 and left me a voice mail, and I returned her call in the 15 morning. 16 Q. And when she left you a voice mail, where 17 would she have called, into the office, or... 18 A. Into the Police Department. 19 Q. Did she have your cell phone number? 20 A. I had provided the victims with a cell phone 21 number, yes. 22 Q. Was that a cell phone number that you carried? 23 A. Uh-huh. 24 Q. Was it one of several cell phones you carried? 25 A. Yes. I I Page 529 1 to your State investigation? 2 A. No. 3 Q. So nobody under your command was outside his 4 house at any time trying to intercept telephone 5 communications of any kind? 6 MS. ARDOUR: Form, asked and answered. 7 BY MR. WEINBERG: 8 Q. Is that right? A. Not to my knowledge, no. Q. And not to your knowledge, did anybody try to intercept electronic communications, e-mails, any other form of communication emanating from either his residence or any Internet service provider? MS. ARBOUR: Form, asked and answered. THE WITNESS: No. BY MR. WEINBERG: Q. Do you recall that during the course of your investigation, before you ended up drafting your May 1st affidavit, there was a decision made to conduct a grand jury? A. Yes, a couple of times. Q. Whether it was March or April, a subpoena was served on Jane Doe 103 by yourself in Tallahassee, correct? MS. ARBOUR: Form, asked and answered. Page 531 1 Q. Was it a cell phone that was paid for by the 2 Palm Beach Police Department? 3 A. I believe 1 was paying for that one. 4 Q. Was there a second cell phone — A. Here's the thing: The Town was offering us a 6 stipend onto a cell phone. I had, prior to that, a few 7 months left on another cell phone to the end of 8 contract. So fora time period there I carried two 9 phones until the contract expired, and at which time I 10 shut off that service and then just used the — 11 Q. The phone left was the one that the Town was 12 offering you a stipend? 13 A. Yes. 14 Q. And by the Town," do you mean the Palm Beach 15 Polka Department? 16 A. Palm Beach Police Department. 17 Q. And this was the nut that you began to give 18 out to different witnesses — 19 A. That is correct. 20 Q. — not only in this case but in other cases? 21 A. Correct. 22 Q. Is that a — do you get copies of the cell 23 records that are connected to that phone or do they go 24 directly to the Palm Beach Police Department? 25 A. No, 1 receive the bill, but it's not an 9 (Pages 528 to 531) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (801 Electronically signed by Jeana Rlcciull (601 bdcd1875-8728-4328-8810-819866661291 EFTA00298349 Page 532 1 itemized bill. It's just a regular bill. I pay it and 2 I shred it. 3 Q. You pay it, you shred it and then you get 4 reimbursed by the Town -- 5 A. The Town offers -- 6 Q. -- a flat sum before — A. -- a flat sum, a monthly sum. 8 Q. And with which service provider is that? 9 A. AT&T. 10 Q. And can you give us the number of the cell 11 phone that Jane Doe 103 -- that you would have given to 12 Jane Doe 103 or other witnesses during this time period? 13 A. Hold on one second. 14 MS. O'CONNER: Were going to object. If you 15 don't want to raise this issue in terms of the cell 16 phone records on the motion to compel that's 17 pending, we can address it with the court. 18 MR. PIKE: les noted. 19 MS. CYCONNER: We raised a number of statutory 20 objection to producing information regarding his 21 cell phone. 22 BY MR. WEINBERG: 23 . How about e-mails? You mentioned 24 [sic]. 25 A. That's correct Page 534 1 Q. To any State Attorney? 2 A. Nope. 3 Q. To anyone associated with the investigation of 4 Jeffrey Epstein? 5 A. Norte. 6 Q. Same question for your cell phones: I assume 7 you have a cell phone other than the cell phone that you 8 receive through the Palm Beach PD stipend. 9 A. No. This is the only phone I use. 10 Q. And that's the phone that's subject to the 11 separate inquiry. 12 How about reimbursing expenses? When you have 13 expenses in connection with, for instance, the Epstein 14 investigation, would there be a record of those 15 expenses? 16 MS. ARBOUR: Form. 17 THE WITNESS: We are given investigative funds 18 to utilize an investigation, and sometimes -- 19 BY MR. WEINBERG: 20 Q. Who would give you the funds? 21 A. — sometimes the funds is issued by the 22 Detective Bureau sergeant. 23 Q. Would they give you a flat amount and leave to 24 your discretion the utilization of that amount? 25 A. No. The maximum I think they give you is Page 533 1 Q. Is that an account that you paid for or that 2 the Palm Beach Police pays for it? 3 A. The Palm Beach Police pays for it. 4 Q. Are the copies of your e-mail on the server of 5 the Palm Beach Police Department? 6 A. Yes. 7 MR. PIKE: Can we go off the record for a 8 second? 9 MS. OtONNER: Yes. 10 (Discussion held off the record.) 11 BY MR. WEINBERG: 12 Q. So the e-mail is [sic]. 13 Do you have a separate e-mail account, a personal e-mail 14 account as contrasted to a public e-mail account? 15 A. I do, but that's — lust that for my family 16 and nothing work-related. 17 Q. So it's your representation that none of the 18 witnesses in this case ever e-mailed to you to your 19 personal e-mail? 20 A. Never. 21 Q. And no communications front your personal 22 e-mail to Chief Reiter? 23 A. No. 24 Q. To the FBI? 25 A. Nopc. Page 535 1 $200, and that's to be utilized if you're going out of 2 County to pay for gas or if you run into a situation 3 with a flat tire, to get a tire replaced or repaired, 4 that kind of thing, providing you get a receipt — 5 Q. What about, you do things on video 6 surveillance and you have to continue to buy new 7 equipment to film the 24 hours a day of comings and 8 goings of a residence; would there be records of those 9 purchases? 10 A. For equipment? 11 Q. Yes. 12 A. I'm sum there would be. I don't recall any 13 purchases. 14 Q. How about travel, did you do any travel in 15 connection with the Epstein investigation? 16 A. Up to Jacksonville, Tallahassee, all within 17 State. You know, we didn't leave. • 18 Q. You didn't have to travel to New York or to 19 any other location? 20 A. No. 21 Q. Did you ever contact any law enforcement 22 officers in any other jurisdiction with the exception of 23 this meeting with Special Agent Ortiz and other agents 24 of the FBI? 25 MS. ARBOUR: Form. 10 (Pages 532 to 535) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Moduli (601 Electronically signed by Jeana RIcduti Mit bdcd1878-c720-432d-8cf0-b19ae656129t EFTA00298350 Page 536 Page 538 1 THE WITNESS: I think, during the 2 investigation, I telephoned New Mexico to see if 3 there was any incidences involving the ranch that 4 Mr. Epstein owns. 5 BY MR. WEINBERG: 6 • Q. And what did you learn? 7 A. It was a huge ranch, but they didn't have 8 anything documented. 9 I believe I also called the NYPD to see if 10 they bad any incidences involving Mr. Epstein up in New 11 York. 12 Q. What did you leant? 13 A. They had nothing on file after numerous phone 14 calls up there, once someone returned your call. 15 believe that was it. 16 Q. When you went to Tallahassee to serve the 17 grand jury subpoena to Jane Doe 103, that was a subpoena 18 that required her attendance, was it not? 19 A. Yes. 20 Q. It was fora given date to come to West Palm 21 Beach and to appear in front of a grand jury being 22 conducted by the State Attorney? 23 A. Yes. 24 Q. Did you and her have any conversations 25 regarding that subpoena and her compliance obligations? 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 correct? . A. I believe so. 1 documented it in the incident report Q. But, in fact, nobody got taken care of; nobody over got banned in this case, did they? MS. ARBOUR: Form. THE WITNESS: Not that I'm aware of, no. BY MR. WEINBERG: Q. And there's no evidence that you're aware of that any persons were paid large sums of money not to cooperate with you, correct? MS. ARBOUR: Forrn. THE WITNESS: Not that I'm aware of. BY MR. WEINBERG: Q. So this is simply Jane Doe 103 telling you what said, and that was said to you on this occasion where she received a grand jury subpoena, right? A. Yes. Q. Did you ever interview A. I know that Jane Doe 103 didn't want to pursue the natter any further. I know I forwarded that information to a, and I also subpoenaed ='s cell phone records, which indicated phone calls to Jane Doe 103 when she indicated she did get the Page 537 1 A. I'm trying to recall what we discussed. 1 2 served her with a subpoena and instructed her to call 3 the phone number that was on there to make arrangemans. 4 Q. How long were you with her in Tallahassee on 5 this occasion? 6 A. I'd say about 40 minutes, 50 minutes. 7 Q. And did you decide that you were to be the 8 person to save the subpoena as contrasted to any of the 9 different people working under or with you? 10 A. Yes, I am the one who served the other search 11 warrant — subpoenas. 12 Q. So you served ull of the subpoenas? 13 A. Uh-huh. 14 Q. And was that the only reason to go to 15 Tallahassee that day? 16 A. I spoke to her also regarding some phone calls 17 that she had received which she felt was threatening in 18 nature. 19 Q. And what were the results of those 20 conversations? 21 A. She had received a phone call from =, 22 indicating to her that those that are with Mr. Epstein 23 will be compensated and those that go against him 24 basically would be dealt with. 25 Q. We're talking about March or April of 2006, Page 539 1 threatening calls. 2 Q. But did you ever — did_. ever get asked 3 whether or not that was a statement that she had made to 4 Jane Doe 103? 5 A. No, I didn't, again, bestise Jane Doe 103 did 6 not want to pursue the matter. 7 Q. So at no time WES - did testify 8 or provide you with anarroboration from Jane Doe 9 I03's allegations that had conveyed some sort of 10 threat to her, correct? 11 A. Again, l didn't speak to 12 Q. Nor did anyone else in the Palm Beach Police 13 Department, to your knowledge? 14 A. No, except for that one time I tried to 15 interview her at her boyfriend's job. 16 Q. Nor did any State Attorney, to the best of 17 your knowledge? 18 A. No, not that I'm aware of. 19 Q. Now, this was the last time you saw Jane Doc 20 103? 21 A. I believe there was — there were two grand 22 jury subpoenas. Yes, this would have been the last time 23 I met with her. 24 Q. Did you reserve her for the second, the summer 25 grand jury? 11 (Pages 536 to 539) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Riccluti (601a Electronically signed by Jeana Rlcciull (801 bdcd1876c720-4328-8c10-b19ae6561291 EFTA00298351 Page 540 1 A. The second time, I provided the State where 2 they could serve the subpoenas. 3 Q. And to your knowledge, was she served a second 4 time? 5 A. I have no knowledge. 6 Q. Do you recall any conversations with her 7 regarding that the second grand jury conflicted with her 8 school schedule? 9 A. That is correct, yes. 10 Q. But that was in response to her receiving a 11 subpoena? 12 A. Yes. I went to Tallahassee, correct 13 Q. So you went to 'fallahassee a second time? 14 A. Yes. 15 Q. To serve her with a second subpoena? 16 A. I think the trip — Pm confining the trips. 17 There was a trip that I went up to Jacksonville to 18 interview her. The second time I went up to see her, ii 19 was in Tallahassee. That one time that I went up there 20 to save her, we discussed the issue, but I 21 didn't go back the third time. 22 Q. Somebody else served her, to your knowledge? 23 A. It would have been the State Attorney's 24 office. 25 Q. And as a result of her being served a second 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 542 A. Yes. I was there. Q. In response to a subpoena, correct? A. Yes. I was there. Q. And did you know whether or not she had bad any conversations with anyone other than you about her belief that her finals needed to be attended to rather than a grand jury subpoena? A. That she — Q. In other words, did you ever speak to the State Attorney that she had gotten a pass on appearing in front of the grand jury because of her school schedule? A. Oh, I have no idea. Q. All you do know is that the State Attorney was waiting for her and she didn't come? A. I don't know if she was waiting for her, Q. Didn't they expect her to appear and testify in response to the subpoena and she failed to appear that day? A. Again, I don't know the conversations that she had with the State Attorney's office. I do know that she relayed that information to me. I told her to relay that information to the State Attorney's office. I was— Page 541 1 time, did she have a conversation with you regarding the 2 second subpoena's conflicting with her finals schedule? 3 A. Correct 4 Q. And she made a phone call to you to complain 5 about the service? 6 A. Correct. 7 Q. And what was the conversation between Jane Doe 8 103 and you on that occasion? 9 A. It was finals week and she could not leave and 10 not take her final to come down for the grand jury. I 11 recommended that she contact the State Attorney's office 12 and make recommendations through the State Attorney's 13 office. 14 Q. And did you have any followup with her to see 15 if she had been formally excused from the grand jury by 16 the State Attorney? 17 A. No, 'did not 18 Q. Did you leant that she didn't show up at the 19 grand jury? 20 A. Yes. 21 Q. Did you learn that she had not been excused by 22 the State Attorney? 23 A. I don't think she officially came out and told 24 me that she was not excused. 25 Q. But you do know that she failed to appear? Page 543 1 Q. Did you empathize with her conflict? 2 A. Absolutely. 3 Q. And did you in any way tell her that, I 4 understand that your finals are important and you should 5 tell the State Attorney that you can't come? 6 A. I explained to her that she needed to contact 7 the State Attorney's office and make arrangements 8 through the State Attorney's office. 9 Q. You encouraged her to get excused front the 10 grand jury subpoena? 11. MS. ARBOUR: Form 12 11IE WITNESS: I reconunended that she contact 13 the State Attorney's office and let her know what 14 was going on as far as her finals. 15 BY MR. WItINI3ERG: 16 Q. And whether she did or didn't, you have no 17 knowledge? A. No, but I was present during the entire grand 19 jury, so l blew she wasn't — 20 Q. That she didn't come? 21 A. (Non-verbal response). 22 And you don't recall any conversation where 23 or any State Attorney informed you that she had 24 authorized Jane Doe 103 not to comply with the grand 25 jury subpoena? PROSE COURT REPORTING AGENCY, Electronically signed by Jeans Ricciuti (601 Electronically signed by Jean. Ricciutt (601 12 (Pages 540 to 543) INC. bdcd1876.c72o 432cI.8cf0-b19ao656129f EFTA00298352 Page 544 1 A. No, 1 don't recall any of those conversations. 2 Q. Toll records, you examined some toll records 3 in this case, did you not, telephone toll records? 4 A. Do you mean itemized records? 5 Q. Yes. 6 A. Yes. 7 Q. And, for instance, you told us there was a 8 record between Jane Doe 103 and 9 A. Uh-huh. 10 a And there were records between.. and 11 correct? 12 A. Correct. 13 Q. And it's fair to say that those toll records 14 establish connections between two phones, correct? 15 A. That is correct 16 Q. They don't tell you who was on either end, do 17 they? 18 A. No. 19 Q. They don't tell you the content of the call, 20 correct? 21 A. No. 22 Q. They tell you how long the call was and phone 23 numbers connected, but not the content of the call, 24 correct? 25 A. No, not the content. Date and time. Page 546 1 now, Sergeant Dawson, but back then it was Detective 2 Dawson. 3 Q. Were you a participant in that second 4 investigation — 5 A. Yes. 6 Q. -- that has a separate case number, an 7 '06 number instead of an '05 number? 8 A. Correct 9 Q. And that investigation lasted until when? 10 A. Not very long. It lasted up to when the Feds 11. came in and basically took over. 12 • Q. Again, I think you said the last time when the 13 FBI comes in, it becomes a one-way street? 14 A. That is correct. 15 Q. And that's been your 20-year experience as a 16 State law enforcement officer? 17 A. Correct 18 Q. And yet, this case, ironically, the Feds were 19 invited in by you and Chief Reiter, correct? 20 MS. ARBOUR: Form. 21 THE WITNESS: Correct. 22 BY MR. WEINBERG: 23 Q. And this Is the first time you've invited the 24 Feds into a State investigation? 25 A. I've been a participant in other I Page 545 3. Q. Anywhere in your investigation, were you ever 2 a participant in or hear any phone calls between any of 3 the witnesses in this case? 4 A. In other words — 5 Q. Let me ask it another way. Did you ever, in 6 any way, receive a to recording of any telephone call 7 engaged in by 8 A. No. 9 Q. And certainly never received or heard a tape 10 recording of Jeffrey Epstein, correct? 11 A. No. 12 Q. Or anyone else who was associated with the la 13 Brftlo residence, correct? 14 A. No. 15 Q. The only evidence you have of what transpired 16 during any call is the message pad and what somebody 17 told you happened during a call, correct? 18 MS. ARBOUR: Form. 19 THE WITNESS: And the toll records. 20 BY MR. WEINBERG: • 21 Q. And the toll records. Okay. 22 Now, after the grand jury returned a charge 23 against Mr. Epstein, you conducted a followup 24 investigation, did you not? 25 A. The followup investigation was initiated by, 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 547 investigations where the Feds have come in and worked . with us, and Pve assisted than in — Q. Sure. But this is the first case where you've conducted an over-one-year State investigation of an offense that occurred at a residence in Palm Beach and that the chief of police of your department brought this case to the Federal government; is that correct? MS. ARBOUR: Form. THE WITNESS: Like I said, we've worked with the FBL Is that what you're trying to get at, in the past? BY MR. WEINBERG: Q. Bringing the case to the FBI, this is what's unusual in this case is the chief of police not accepting the charged decisions made by the State Attorney, brought this investigation over to the United States Attorneys office. That's a first for you, isn't it? MS. ARBOUR: Form. THE WITNESS: There were many firsts in this case. BY MR. WEINBERG: • Q. This was one of them? MS. ARBOUR: Form, asked and answered. THE WITNESS: There was — 13 (Pages 544 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricclull (601 to 547) bdcd1876-67243-43241-8cf0-b19666661291 EFTA00298353 Page 548 1 MS. O'CONNER: Is there a question pending? 2 MR. WEINBERG: Yes. 3 BY MR. WEINBERG: 4 Q One of the firsts in this case was that this 5 was the first time that your chief of police brought the 6 case to the Federal government after a year of State 7 investigation, correct? MS. ARBOUR: Form, asked and answered. 9 THE WITNESS: I believe so. 10 BY MR. WEINBERG: 11 Q. Now, Mr. Epstein stays at El Brillo, and hes 12 there on a periodic basis, at least until this case 13 ended up in the Criminal Justice System, correct? He 14 would come there at times and be absent at times, 15 correct? 16 A. Yes. 17 MS. ARBOUR: Form. 18 BY MR. WEINBERG: 19 Q. And the investigation began in March; is that 20 right? 21 A. Yes. 22 Q. And there was an allegation made bye, and 23 resulted horn a phone call by her parents, correct? 24 MS. ARBOUR: Form, asked and answered. 25 THE WITNESS: Yes. Page 550 1 allegation, there was no attempts to charge Mr. Epstein 2 or arrest Mr. Epstein in March, April, May, June, July, 3 August and into September of 2005, correct? 4 A. Correct. 5 Q. And then you picked up this case in late 6 September of 2005, correct? 7 A. Correct. . 8 MS. ARBOUR: Form, 9 BY MR. WEINBERG: 10 Q. And you interviewed M. in the first week of 11 October 2005, correct? 12 MS. ARBOUR: Form, asked 13 THE WITNESS: Correct. 14 BY MR. WEINBERG: 15 Q. And.. gave you certain corroborating_ 16 information that confirmed the information that.. had 17 given you about their joint visit In early '05 to 18 Mr. Epstein's home? 19 A. Correct. 20 Q. Correct? 21 That led to a request for a search warrant 22 rather than a request for an arrest warrant, correct? 23 A. Correct. 24 Q. And surveillance continued on Mr. Epstein's 25 home on occasion when you knew he was in town? asked and answered. and answered. Page 549 1 BY MR. WEINBERG: 2 Q. And then there were trash pulls that, in some 3 respects, were believed to included objects that you 4 thought were reflective of anal sex, correct? 5 MS. ARBOUR: Form, asked and answer