Case Document 291-28 Entered on FLSD Docket 01/21/2015 Page 1 of 5 EXHIBIT 29 Case Document 291-28 Entered on FLSD Docket 01/21/2015 Page 2 of 5 Page 2 Page 4 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL APPEARANCES: . CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA ?52% (?131; 33% :23 CASE AB LE OP OLD 1? UIRE 4 2925 PGA Boulevard 133- Suite 200 4 5 Palm Beach Gardens, Florida 33410 Plaintiff, Phone: 561.515.1400 5 6 6 -vs- VOLUNIE I OF 7 On behalf of the Plainti??s, L.M., E.W. and 7 JEFFREY EPSTEIN '8 Jane AND SARAH KELIEN, 9 BRADLEY J. EDWARDS, ESQUIRE 8 FARMER, JAFFE, WEISSING, EDWARDS Defendants. 1 0 FISTOS LEHRMAN, PL. 9 425 North Andrews Avenue 10 11 Suite 2 1 1 Fort Lauderdale, Florida 33301 12 Phone: 954.524.2820 1 2 DEPOSITION OF 13 On behalfofJane Does 1 through 8: DETECTIVE JOSEPH RECAREY 1 4 JESSICA ARBOUK ESQUIRE 3 . MERMELSTEIN HOROWITZ, PA. 1 4 Frlday, March 19, 2010 1 5 18205 Biscayne Boulevard 15 9:37 - 5:12 pm. Suite 2218 . 1 6 250 Australian Avenue South 1 6 Mann, 33160 1 gg??PHPg . 7 - orowitz exa useattorneycom i; we? Palm Beach Honda 33401 1 8 On behalf ofthe Plaintiffs: Jane Does 101, 102 and 103: 19 19 20 20 KATHERINE W. FZELL, ESQUIRE 2 1 PODHURST ORSECK 2 2 Reported By: 2 25 .West Flagler Street Hopkins, RPR, FPR {30? . 2 3 Notary Public, State of Florida 2 2 Honda 33130 . one. 305.358.2382 2 4 (Coulr; (1){9eport1ng :31 (Via telephone) 25 25 Page 3 Page 5 1 Appearances 2 UNITED STATES DISTRICT COURT 0113113; 3f the ESQ SOUTHERN DISTRICT OF FLORIDA GARCIAMAIELQKWUELS 3 4 224 Datura Avenue, Suite 900 CASE NO. 10-80309 West Palm Beach, Florida 33401 4 5 Phone: 561.832.8033 A 1? IE 6 and ggigfo' 103? 7 TARA A. FINNIGAN, ESQUIRE TARA A. FINNIGAN, PA. 7 -vs- VOLUME I OF 8 224 Datura Street 8 JEFFREY EPSTEIN, Suite 900 9 Defendant. 9 West Palm Beach, Florida 33401 Phone: 561.835.8115 behalf of the Defendant, Jeffrey Epstein: 1 1 1 2 MICHAEL PIKE, ESQUIRE 1 2 DEPOSITION OF BURMAN, CRITTON, LUTHER COLEMAN, LLP DETECTIVE JOSEPH RECAREY 13 @3323?? 30mm 1 3 . 1 4 West Palm Beach, Florida 33401 1 4 Fnday, March 19, 2010 Phone: 561.842.2820 15 9:37 - 5:12 pm. 15 1 6 250 Australian Avenue South 1 6 and Suite 1500 17 A 7 West Palm Beach, Florida 33401 18 250 Australian?Avenue South . 18 Suite 1400 1 9 1 9 West Palm Beach, Florida 33401-5012 2 0 Phone: 561.659.8300 2 32 and 2 2 Reported By: 2 2 MILTON G. WEINBERG, ESQUIRE Hopkins, RPR, FPR LAW OFFICE OF MILTON G. WEINBERG 2 3 Notary Public, State of Florida 23 $233135?? Prose Court 2 4 Boston, Massachusetts 02116 2 4 Job No.? 1509 Phone: 617.227.3700 2 (Pages 2 to 5) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Case Document 291-28 Entered on FLSD Docket 01/21/2015 Page 3 of 5 Electronically signed by hopkins (601 -051 -976-2934) Electronically signed by hopkins (601-051-976-2934) Electronically signed by hopkins (601-051-976-2934) Page 279 Page 281 1 Q. I mean, I'm sorry for such a bad question, 1 A. I remember getting documents from Alan 2 but in looking at these property receipts, I just 2 Dershowitz which were ?ight logs pertaining to 3 don't see where it tells me how much time each 3 Mr. Epstein's plane. And I subpoenaed the information 4 interview had taken. SO, I mean, is there an 4 ?om Jet Aviation, but I don't, I don't recall preparing 5 average? 5 a ?ight log. 6 A. That's not going to indicate on any property 6 Q. Okay. Do you remember receiving 7 receipt. There is 7 information from Jet Aviation directly? 8 Q. Right. Okay. Have you ever seen the 8 MR. PIKE: Form. 9 nonprosecution agreement? 9 THE WITNESS: Jet Aviation does not keep A. No. 1 0 records according to them as to who ?ies on 1 1 Q. Have you ever seen the attached list of 1 1 what plane. I guess you can just drive up to a i 1 2 Victims that was attached as an addendum to the 2 plane, board it. They have no idea who's on i 3 nonprosecution agreement? 1 3 the, who is ?ying on the plane. They have i 1 4 MR. PIKE: Form. 1 4 records of when the plane comes in, if the 1 5 THE WITNESS: I believe the Chief had a 1 5 plane is serviced, and when the plane leaves. 1 6 copy of it. He may have, you know, done one of 6 BY MR. EDWARDS: 1 7 these, but, no, not in my physical hands. 1 7 Q. Did you ever attempt to check with customs .- 1 8 MR. PIKE: And just for the record when 8 or FAA on any of the passengers that have ever been ,2 9 the witness said -- 1 9 on international ?ights with Jeffrey Epstein or on 2 0 THE WITNESS: I held it up. 2 0 his planes? 2 1 MR. PIKE: -- one of these, he held up 2 1 MR. Form. 2 2 Exhibit 29. 2 2 THE WITNESS: I'm trying to recall. 3? 2 3 MR. EDWARDS: Which said memorandum. 2 3 BY MR. EDWARDS: 3 2 4 MR. PIKE: Memorandum. 2 4 Q. At the current time do you have any 2 5 THE WITNESS: I just held it up. 2 5 knowledge of that being done by either the US. i Page 280 Page 282 g. 1 BY MR. EDWARDS: 1 Attorney's of?memorandum exists and it is the 2 A. I have no idea what the FBI does. They are i 3 attached addendum to the nonprosecution agreement 3 primarily one way. You give them the information and 4 containing the names of the underage victims, would 4 nothing comes back, 5 that be something in the possession currently of the 5 Q. I am starting to get that idea. I am 6 Palm Beach Police Department? 6 understanding that. Okay. 7 MR. PIKE: Form. 7 A. But you know, and I work with them almost on a 8 THE WITNESS: I don't believe so. 8 daily basis, so I am in direct contact with them. And 9 BY MR. EDWARDS: 9 still I have yet to see information come back the other 3: 1 0 Q. Is that something that's been destroyed or 1 0 way. i 1 1 also -- 1 1 Q. Just so the record is clear, when you say 1 2 MR. PIKE: Form. 1 2 you're working with them on a daily basis, when i 1 3 THE WITNESS: I never received a c0py of 1 3 you're in the Organized Crime Unit on other cases, 1 4 it 1 4? correct? 1 5 BY MR. EDWARDS: 1 5 A. Yeah, and I am also assigned to the JTTF, the 1 6 Q. Have you ever seen it? 1 6 Joint Terrorism Task force here in West Palm Beach. 1 7 A. Like I said, I may have seen it. I may have 1 7 Q. My understanding from reading your reports 1 8 been shown it, you know, and just by holding that you also subpoenaed phone records of . 1 9 am only using this exhibit as an example. It may have 1 9 numerous individuals, correct? 2 0 been just shown to me like this but not in my hands A. Correct. 3 2 1 where I actually read the entire document. Q. One of those individuals is Jeffrey . 2 2 MR. PIKE: Move to strike. Epstein? a 2 3 BY m. EDWARDS: A. I believe so. 2 2 4 Q. In your investigation, did you prepare a Q. Sarah Kellen? 2 5 ?ight log summary? A. Yes. A 39 (Pages 279 to 282) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Case Document 291-28 Entered on FLSD Docket 01/21/2015 Page 4 of 5 Page 299 Page 3011. 1 stuck around just to assist the victims. 1 between the Palm Beach Police Department and the i 2 BY MR. EDWARDS: 2 State Attorney's Of?ce? . 3 Q. And when you talk about the statement that 3 A. Yes, there was. 4 you provided, did you present testimony related the minor females that you discovered to have 5 A. This case was originally brought to their . 6 come in contact with Jeffrey Epstein or only the 6 attention very early on in the investigation to which 2? 7 four or ?ve names that ultimately were at the end 7 they were, you lmow, very gung?ho, very let's go, let's 8 of your probable cause af?davit? 8 do this, up until, up until, up until the meeting with 9 MR. PIKE: Form and compound. 9 Alan Dershowitz and the State Attorney. And then it, it 1 0 THE WITNESS: As far as my testimony at 1 0 all took a turn. 1 1 the grand jury, I only answered the questions 1 1 Q- Were you at that meeting? 8 1 2 that were asked of me by the state. At that 1 2 A. I attended one meeting where I believe it 3 1 3 point it was Lanna Belohlavek. 1 3 Dershowitz, Krischer, and Belohlavek. 1 4 I'm sorry about the last name. I don't 1 4 MR- PIKE: Obj 60" to form. 1 5 know how to spell her last name. 1 5 BY MR. EDWARDS: 1 6 BY MR. EDWARDS: 1 6 Q. What was said during that meetingtalking with the State Attorney's 1 7 MR. PIKE: All right. With regard to this i 1 8 Of?ce during the investigation, did you indicate to 1 8 line of questioning, I just want to be clear 1 9 them the number of underage females that you were 1 9 that I have form objections to this line of 2 0 aware had come in contact sexually with Mr. Epstein? 2 questioning. And the fact that under various . 2 1 MR. PIKE: Form and assumes facts not in 2 1 Federal Rules, I believe it's 408, 410 as well 2 2 evidence. 2 2 as various rules under Florida Evidence Code, 2 3 THE WITNESS: Yes, they were aware of the 2 3 some of these discussions are protected as 2 4 probable cause af?davit which indicated all 2 4 potential plea negotiations. So, having said 2 5 the facts. 2 5 2? Page 300 Page 302 1 BY MR. EDWARDS: 1 BY MR. EDWARDS: 2 Q. And can you recall what their position was 2 Q. What was said during these, this meeting 3 on the various acts that are related in the probable 3 that you attended? 3g 4 cause af?davit? And ultimately I am asking why is 4 A. Several of the girls' MySpaces were discussed. - 5 it that they were not interested in hearing from all 5 MySpace being the social network. They all had 6 of the girls and only a select few? 6 MySpaces. And the girls, the girls were actually who 7 MR. PIKE: Form and compound. 7 had the MySpaces had inputted, you know, various 3 8 THE WITNESS: That's a question that 8 different things regarding alcohol use or marijuana use 9 you're going to have to ask Lanna Belohlavek 9 or that kind of thing. 5 1 0 because she was aware of all the people that I 1 Q. And what was brought up at that meeting as 1 1 submitted to her, and yet she choose three 1 1 to the relevance of whether or not these females 1 2 people to appear before the grand jury, one 1 2 that had been to Jeffrey Epstein's house while a 1 3 knowing that she was not going to be able to 1 3 underage used alcohol or drugs? What was the point 3 1 4 appear. 1 4 of that? 1 5 MR. PIKE: Move to strike. 1 5 MR. PKE: Form. 1 6 BY MR. EDWARDS: 1 6 THE WITNESS: To show that the character 1 7 Q. And who was the person that was not going 1 7 of the girls were not, was not to be believed. 1 8 to be able to appear? 1 8 BY MR. EDWARDS: 1 9 A. That would have been Jane Doe No. 103. 1 9 Q. Okay. It was speci?cally to attack their 2 0 Q. Do you know why she was unable to appear? 2 credibility? 2 1 A. Because it was ?nals week in her university 2 1 MR. PIKE: Form, move to strike. 2 2 and the limited time that they had scheduled the grand 2 2 THE WITNESS: Correct. :2 2 3 jury and the time that it would have been for her to 2 3 BY MR. EDWARDS: 2 4 make arrangements to come down was very short. 2 4 Q. So, at that point in time who was making 2 5 Q. Was there a dis a eement about this case 2 5 those arguments on behalf of Jeffrey Epstein? A 44 (Pages 299 to 302) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by hopkins (601 -051 -976-2934) Electronically signed by hopkins (601-051-976-2934) Electronically signed by hopkins (601-051-976-2934) Case Document 291-28 Entered on FLSD Docket 01/21/2015 Page 5 of 5 Wm amt-ma: .. 2mm b. widmoac mm a?hwmaw away/Mawm - (561) 832-7500 Electronically signed by hopkins (601-051-976-2934) Electronically signed by hopkins (601-051-976-2934) Electronically signed by hopkins (601-051-976-2934) PROSE COURT REPORTING AGENCY, ?memes. I mm "rs-3,4 oat if; is? 1w} esteem? Page 307 Page 309 1 attorneys have been unanswered and messages remain 1 A. Correct. 2 unreturned. Is that a statement that you agree 2 MR. PIKE: Form. 3 with? 3 BY MR. EDWARDS: 4 A. Absolutely. 4 Q. So, are you talking about A.D., C.L., 5 Q. How many messages do you think that you 5 S.G., and Jane Doe No. 103? 6 left the State Attorney's Of?ce that were 6 MR. PIKE: Form. 7 unretumed? 7 THE WITNESS: From family I had 8 A. Quite a few. I actually showed up at Lanna's 8 gotten multiple phone calls during that day. 9 of?ce because I had left her several messages and 9 BY MR. EDWARDS: 1 0 didn't, didn't return get a return phone call. And it 1 0 Q. During any of the meetings -- how many 1 1 was during the time where: We're going to the grand 1 1 meetings are you aware of that Mr. Dershowitz 1 2 jury, no, we're not going to grand jury; yes, we're 1 2 participated in with the State Attomey's Of?ce? 1 3 going; no, we're not. 1 3 A. There were a couple. Like I said, I attended 1 4 And it was, I believe, the following day 1 4 one. 1 5 when we were supposed to go to the grand jury and I 1 5 MR. PIKE: Form. 1 6 still had not heard from her as to what time nor had 1 6 THE WITNESS: I didn't attend the second 1 7 I received a subpoena. So, I had contacted her 1 7 one. I want to say two to three. 1 8 numerous times during that day. I would say three 1 8 BY MR. EDWARDS: 1 9 to four times during that day. In the afternoon person who also is found in 2 0 actually showed up at her of?ce where she was 2 the message pad as somebody who has called Jeffrey 2 1 sitting in her of?ce. 2 1 Epstein's home, correct? 2 2 Q. Did you speak with hercan recall, yes. 2 3 A. Yes, I didever indicate to them that he 2 4 Q. And what happened within that 2 4 was actually at the home on various occasions when 2 5 conversation? 2 5 some of these underage girls would come over to Page 308 Page 310 1 MR. PIKE: Form. 1 Mr. Epstein's house? 2 THE WITNESS: There was actually a time 2 MR. PIKE: Form. 3 where there was a plea negotiation being 3 THE WITNESS: Not that I recall. 4 discussed where it was to one count of felony, 4 BY MR. EDWARDS: 5 ?ve years probation, and I believe no one had 5 Q. In fact, was he trying to convey to the 6 been contacted regarding to that negotiations. 6 State Attorney's of?ce that you should not believe 7 BY MR. EDWARDS: 7 these girls that they were at his house at all 8 Q. When you say no one, are you speaking 8 because they have credibility problems? 9 about the police or victims? 9 NR. PIKE: Form, asked and answered. 1 0 MR. PIKE: One second. Form. I?m going 1 0 THE WITNESS: That's, that was the 1 1 to move to strike and I am going to continue to 1 1 impression I received, yes. 1 2 assert the same privileges under the Federal 1 2 MR. EDWARDS: The next portion is going to 1 3 Rules 408, 410, and 401.9. I'm sorry. Go 13 take a long time. I mean it's getting into the 1 4 ahead. 1 4 juice point that you 1 5 BY MR. EDWARDS: 1 5 want to stop rather than getting into something 1 6 Q. When you say no one had been contacted, 1 6 that's going to take a long time? 1 7 are you speaking about no police of?cers that were 1 7 MS. How long? 1 8 on the case or no victims? 1 8 MR. EDWARDS: Couple of hours. 1 9 A. Both the police of?cers and the victims 1 9 MS. I need to stop. 2 0 because I was getting phone calls from the victims? 2 0 MR. KUVIN: Okay. 2 1 parents as to what time are we needed. 2 1 MR. PIKE: All right. So we are going to 2 2 Q. And when you say we were getting phone 2 2 break. We have an agreement on the record that 2 3 calls from the victims' parents, are those the 2 3 Detective Recarey, and correct me if I am 2 4 victims that ultimately were listed as victims in 2 4 wrong, Ms. O'Connor will get back to us through sometime with a few available A 46 (Pages 307 to 310) INC. 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