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IN THE FIFTEENTH JUDICIAL CIRCUIT COURT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502008CA037319 XXXX MB AB

B.B.,
Plaintiff,
vs.
JEFFREY EPSTEIN,
Defendant.
______________________________/

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VOLUME I
VIDEO-TAPED DEPOSITION OF MICHAEL REITER
A WITNESS
TAKEN BY THE PLAINTIFF

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DATE: November 23, 2009
TIME: 10:12 a.m. - 7:38 p.m.

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The deposition of MICHAEL REITER, a witness in the
above-entitled and numbered cause was taken before me,
Vanessa G. Archer, Court Reporter, Notary Public for the
State of Florida at Large, at 2925 PGA Boulevard, Palm Beach
Gardens, Florida, on the 23rd day of November, 2009,
pursuant to Notice in said cause for the taking of said
deposition on behalf of the Plaintiff.
APPEARING ON BEHALF OF PLAINTIFF B.B.:
SPENCER T. KUVIN, ESQ.
LEOPOLD-KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, Florida 33410
APPEARING ON BEHALF OF PLAINTIFFS' JANE DOES 2-8:
ADAM HOROWITZ, ESQ.
MERMELSTEIN & HOROWITZ, P.A.
18205 Biscayne Boulevard, Suite 2218
Miami, Florida 33160
APPEARING ON BEHALF OF PLAINTIFF C.A.
JACK HILL, ESQ.
SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
APPEARING ON BEHALF OF PLAINTIFF:
ISIDRO GARCIA, Esq.
GARCIA LAW FIRM, P.A.
The Harvey Building
224 Datura Street, Suite 900
West Palm Beach, Florida 33401

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I-N-D-E-X
November 23, 2009
MICHAEL REITER
DIRECT CROSS
By Mr. Kuvin

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REDIRECT
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By Mr. Garcia

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By Mr. Critton

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364

RECROSS

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EXHIBITS
Marked
Plaintiff's Exhibit No. 1
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(Palm Beach PD Intelligence Report 11/28/04)
Plaintiff's Exhibit No. 2
31
(Incident Reports)
Plaintiff's Exhibit No. 3
99
(Letter to Barry Krischer)
Plaintiff's Exhibit No. 4
131
(Photographs of El Brillo Way)
Plaintiff's Exhibit No. 5
132
(Photo of 358 El Brillo Way)
Defendant's Exhibit No. 6
218
(Subpeona Duces Tecum)
Plaintiff's Exhibit No. 7
356
(Money Transfers)
Plaintiff's Exhibit No. 8
357
(Flight Summary)
Certified Question: Page 160, Line 10
Letter to John Randolph, Esq.
Errata Sheets (to be forwarded upon completion)

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APPEARING ON BEHALF OF DEFENDANT:
ROBERT D. CRITTON, ESQ.
BURMAN, CRITTON, LUTTIER & COLEMAN, LLP.
515 North Flagler Drive, Suite 400
West Palm Beach, Florida 33401
JACK GOLDBERGER, ESQ.
ATTENBURY, GOLDBERGER, RICHARDSON & WEISS, P.A.
250 South Australian Avenue, Suite 1400
West Palm Beach, Florida 33401
APPEARING ON BEHALF OF WITNESS:
JOANNE O'CONNOR, ESQ.
JOHN RANDOLPH, ESQ.
JONES, FOSTER, JOHNSTON & STUBBS, P.A.
505 South Flagler Drive, Suite 1100
West Palm Beach, Florida 33401
ALSO PRESENT: JEFFREY EPSTEIN
VIDEOGRAPHERS: MICHAEL D. DOWNEY
EDDIE GUERRERO
VISUAL EVIDENCE
601 North Dixie Highway, Suite A
West Palm Beach, Florida 33401

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THE VIDEOGRAPHER: This is the 23rd day of
November, the year 2009. The time is
approximately 10:12 a.m. This is the
video-taped deposition of Michael Reiter in the
matter of B.B. and Jane Doe and related cases
Plaintiff versus Epstein, Defendant. This
deposition is being held at 2925 PGA Boulevard,
Palm Beach Gardens, Florida. My name is
Michael Downey, I'm the videographer employed
by Visual Evidence. Will the attorneys please
announce their appearances for the record.
MR. KUVIN: Spencer Kuvin on behalf of
B.B.
MR. HOROWITZ: Adam Horowitz for
Plaintiffs' numbers 2 through 8.
MR. HILL: Jack Hill on behalf of Carolyn
Adriana.
MR. CRITTON: Robert Critton on behalf of
Jeffrey Epstein.
MR. GOLDBERGER: Jack Goldberger on behalf
of Jeffrey Epstein.
MS. O'CONNOR: Joanne O'Connor on behalf
of the witness.
MR. RANDOLPH: I'm John Randolph on behalf
of Mike Reiter, the witness.

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calling them girls and underage. But as to any
female that's referenced, I believe -- that
we've referenced or that someone wants to
designate as confidential, I'm comfortable with
using the same process without necessarily
trying to categorize it one way or the other.
MR. KUVIN: Fair enough, we'll use the
same process here today that we've used in the
past. I just want to make sure of that,
correct?
MR. CRITTON: I think that's what I just
said.
MR. KUVIN: Fair enough.
MR. RANDOLPH: -- all of you agree that
there would be no waiver on the part of the
Chief in regard to any law relating to naming
these witnesses.
MR. KUVIN: I would absolutely agree with
that.
MR. HILL: Agree.
MR. CRITTON: I agree with that. Is he
still the Chief? You refer to him as the
Chief. Is he still the Chief?
MR. KUVIN: Well, we'll get to that.
MR. CRITTON: Oh, okay. Just wasn't sure.

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THEREUPON,
MICHAEL REITER,
having first duly sworn by me, was examined and testified
as follows:
THE WITNESS: I do.
MR. KUVIN: Good morning.
THE WITNESS: Good morning.
MR. KUVIN: Before I start asking you
questions, I just want to make sure I have
something on the record so that you understand
what we're going by in this case with respect
to confidentiality issues.
It's my understanding, Counsel, that we
treat this deposition as we have treated all
the other depositions in the case, by which
that I mean, Mr. -- Captain Chief Reiter is
free to testify about names of girls, the
underage girls in his testimony, and that a key
will be supplied as we have done in the past at
the conclusion of the deposition and attached
to the back of the deposition.
MR. CRITTON: My understanding is he can
certainly reference females. I don't know
whether they're underage or not, but I
certainly understand your stipulation by

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MR. RANDOLPH: He's not employed with the
Town of Palm Beach at this point.
MR. CRITTON: All right, thank you.
DIRECT EXAMINATION
BY MR. KUVIN:
Q Good morning.
A Good morning.
MR. RANDOLPH: May I also for the record,
before you go forward with the deposition,
place on the record, because there are parties
here that I believe did not receive prior to
today the motion for protective order and
motion to quash subpoenas filed on behalf of
the witnesses by us. And I believe that all of
you have received a copy of that by now, some
of you just having received it this morning, we
did not know when we had served this on Friday
all of the parties to whom to serve it so we
brought it today.
MR. KUVIN: Okay. I haven't received it
and I haven't read it except to the extent I
know I made copies of it this morning. So I
haven't read it yet so I certainly can't speak
to whatever's in it, but we'll read it.
MR. CRITTON: Skip, I also did not -- I

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don't think I got a copy on Friday afternoon.
If we could make a copy at the break too, I'd
like to get a copy so I know what it says.
MR. KUVIN: If you just give it to the
receptionist -MR. RANDOLPH: You were the two people
that we e-mailed it to, to you and to you, Bob.
MR. CRITTON: I'm a hundred percent
confident that you may have sent it to my
office, I just haven't seen it yet. But I saw
a reference to it so I'm not -- and I think
Joanne had mentioned that you were going to
file one so it doesn't come as a surprise, so I
appreciate it.
BY MR. KUVIN:
Q Okay. All right. Now that the lawyer
stuff's out of the way, could you give us your full
name, please?
A Michael Steven Reiter.
Q And are you still a commissioned police
officer?
A I have the licensure of the State of
Florida, I am not currently employed as a police
officer.
Q All right. But you still hold the

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A It's a licensed security company with the
State of Florida, and what I do is security and
crisis management and investigation.
Q Where does that business work?
A Primarily in the Town of Palm Beach and
areas nearby.
Q All the work contained, all the primary
work contained within the County of Palm Beach?
A I don't really see what details about my
business -- I have competitors, and if I speak of
the details I would have some concern that those
details would be unfavorable for the success of my
business.
Q Fair enough. You're the principal of that
business though?
A Yes.
Q When did that business begin?
A I actually filed the documents with the
state a couple of years ago but didn't begin
operating it until I left the police chief's
position until I retired, so that was really the
beginning of March of this year.
Q So you left as Chief of Police for the
Town of Palm Beach in March of 2009?
A I left -- February 28th was the last day,

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license, correct?
A That's correct.
Q I ask that because I don't want to ask
your home address if you still have the license.
With agreement of counsel, can we
agree that any contact made with former Chief Reiter
is made through your office?
MR. RANDOLPH: Yes.
BY MR. KUVIN:
Q And you understand what I mean by that,
when I say I don't want to make known your private
home address because you're still a licensed police
officer?
A I appreciate that and hope that that would
continue if I allow my license to expire as well.
Q Okay. All right. You're okay with us
contacting you through the lawyers that are here
today for any contact we need to make with you?
A Yes.
Q All right. Where do you currently work?
A I started a company after my retirement as
Chief, Michael Reiter and Associates. I'm the
president.
Q And Michael Reiter and Associates, what
does that business do?

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I retired.
Q How long had you been Chief of Police for
the Town of Palm Beach?
A Approximately eight years.
Q And before that where did you work?
A Before that, well I was a Palm Beach
police officer for twenty-eight years, so prior to
that I was employed by the University of Pittsburgh
Police Department.
Q What years are we talking about that you
were back at the University of Pittsburgh?
A I began with the town on January 26, 1981.
I worked for approximately two years prior to that
with the University of Pittsburgh Police Department.
Q And was that the first police officer
position that you held at University of Pittsburgh,
or did you hold any position prior to that as a
police officer?
A I worked for a year in the City of New
Kensington, Pennsylvania as a traffic officer, which
was kind of a hybrid type position with authority to
enforce traffic laws and so on. It was a one-year
grant position.
Q Okay. Any prior police work other than
that?

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A No.
Q Okay. Why don't you give us, if you
would, just the benefit of your background and
education starting with high school and any
post-secondary schooling that you've had?
A I graduated from high school in 1975. And
then I went to the Pennsylvania State University
where I received an Associate Degree in letters,
arts and sciences. And then I came to Florida and
received a Bachelor of Arts in criminal justice from
Florida Atlantic University. And then at the Palm
Beach Atlantic University a Master of Arts in human
resource development, the concentration in
organizational development. I was at Harvard
University, Kennedy School of Government in 2000 for
the senior executives and state and local government
program. I'm a graduate of the FBI National
Academy, which is in Quantico, Virginia. The
Southern Police Institute, which is a residential
management program for law enforcement at the
University of Louisville. I have numerous other
professional training courses in a variety of
different areas.
Q When you left the Town of Palm Beach as
Chief, I assume there was a personnel file that held

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crime, vice and narcotics unit as a detective for
approximately a couple of years. I was promoted to
sergeant and became a patrol sergeant, uniform
patrol sergeant, for a year and a half.
And then I was transferred to the
organized crime, vice and narcotics unit as its
supervisor. I did that for about three, or possibly
four years.
Then I was promoted to Captain, and
my first assignment as Captain was in the
investigations function of the department
responsible for all of the components and
investigation. I think I did that for approximately
a year or so and then I was promoted to Major. The
department had two Majors and acted as assistant
chiefs, and I was responsible for the law
enforcement component of the police department. Did
that for about seven years.
Then I became assistant Chief of
Police, which was a new position. I did that for
three years. And then I was appointed Chief of
Police and that was for about eight years.
Q And what was the year you were appointed
Chief?
A 2001.

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all of your training materials and background and
licenses and all of that qualification material?
A Yes.
Q Okay. Likely contained within your
personnel file, which is generally public record,
correct?
A Yes.
Q And you mentioned that you'd worked for
the Town of Palm Beach as a police officer for
twenty-eight years?
A That's correct.
Q Could you work us through up the ranks?
In other words, when you first started what your
position was, how long you may have held that
position and how you worked your way up the ranks to
ultimately become the Chief of Police?
A I started as a patrol officer, a uniform
patrol officer, I had that position for about a
year. And then I joined the tactical unit, of what
it was called back then, which was primarily
surveillance and investigations. I was in that
assignment for about two years.
And then I became a detective in the
general assignment detective bureau and I was there
for about a year. And then I went to the organized

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Q So we're looking at 2001 to 2009 roughly
as Chief of Police?
A Uh-huh.
Q And let me work back on the years with
that. This series of appointments and promotions
through the ranks at the police department also
would likely be outlined in your personnel file
there kept at the police department; would you agree
with that?
A Yes.
Q We're here today to talk about an
investigation that began -- well, let me ask you, do
you know as you sit here today when the
investigation began with respect to Jeffrey Epstein,
roughly the time frame that that investigation
ensued?
A I believe it was 2005.
Q Let me start out by showing you what we'll
mark as -- you got a whole thing of stickers? Why
don't you get them out because I'm going to need a
bunch. Why don't you take a look at it as well.
Perfect. Thank you very much.
All right. If I could just put a
quick sticker on that for you, I'll give it back to
you so you can finish reading.

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A I'd like to clarify what I said
previously. When you asked me the investigation, I
assumed you meant the one that resulted in the
criminal charges.
Q I figured -A And I interpreted that to mean when we had
a complaint that came forward, and I think that was
2005. And the document you've just given me is
dated prior to that and I didn't see this set of
facts that's documented here as being part of what I
previously -Q I appreciate that and that's why I gave
you the document because I wanted to clarify so that
we're on the same page.
MR. CRITTON: Move to strike as
unresponsive.
BY MR. KUVIN:
Q Let me ask you -- I've showed you what
we've marked as Exhibit 1. You've had a chance to
take a look at that, correct?
A Yes.
Q All right. Can you explain to us
generally, because we're going to go through a
couple of these forms today, what this form is and
what it's used for, or what it was used for back at

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used really is that. If it's just information and
it's intelligence and it could be eventually be part
of a criminal investigation, it would be documented
in an intelligence report. If it's information that
it was clear at the time when the writer prepared
the report, that it's part of a criminal
investigation or something that truly needs to be
documented, then it would be on the incident report.
Q Okay, fair enough. With respect to this
form generally, a blank one, who is it that
developed this particular form; do you remember?
A Well I can answer that and maybe remember
a -- I think I developed this form.
Q Okay.
A Or at least its predecessor. I skipped
somewhere along the way a three-year assignment when
I was responsible -- I was an administrative
sergeant. I was responsible for records and
planning and research and all those sorts of things.
I seem to recall during that time period that's when
we really fully computerized the police department.
I think I developed a predecessor to this form at
that time.
Q Okay, fair enough. Let's go through some
of the sections of this report. The date first of

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the time?
A It's titled Palm Beach Police Department
Intelligence Report. It documents information that
is of an intelligence nature that the department
sees it as important to remember but does not
necessarily start in a criminal investigation.
Q Okay. Is this generally the form that is
used by police officers and detectives when they get
a call for a potential incident?
MR. CRITTON: Form.
BY MR. KUVIN:
Q Let me ask it this way, bad question.
Is this the only form that was used
back at that time in order to report potential
incidents, or were there other forms that were used?
A No, there were other forms.
Q What was -- what is the deciding factor
when to use this particular form back then?
A Well the other form, which is an incident
report, that's something that gets counted as an
actual crime or an incident that's going to result
in an investigation. It's a sort of a higher level
documentation of something.
The difference between when an
intelligence report or an incident report would be

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all at the top right, is that the date the actual
report is taken, or is that the date that it's
filled out, or both?
MR. CRITTON: Form.
MR. KUVIN: Can you tell?
MR. CRITTON: Unless he has any personal
knowledge or filled out the form, please ask
him to read the form, or are you just talking
about the form in general? Form.
BY MR. KUVIN:
Q Okay. Let me ask some background
questions first since he has that objection.
As Chief of Police, were you
reviewing forms like this in your position at that
job, would you see these types of reports generally?
Not this one in particular but generally?
MR. CRITTON: Form.
THE WITNESS: If generally means would I
see most of them, no, as Chief.
BY MR. KUVIN:
Q You're aware of the form though itself,
correct?
A Yes.
Q And you were aware that officers would
fill these forms out working for your department?

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A Yes.
Q And these records, such as these reports,
like this intelligence report you have in front of
you today, are records that are regularly kept in
conducting business as a Chief of Police in the Town
of Palm Beach?
A That's correct.
Q Would you agree with me that this was a
regular business record for the Town of Palm Beach
Police Department?
MR. CRITTON: Form.
BY MR. KUVIN:
Q These types of documents?
A Yes.
Q And you trust in your officers to fill out
these types of incident reports on a regular basis?
MR. CRITTON: Form.
THE WITNESS: Yes.
BY MR. KUVIN:
Q And if your officers filled out these
reports incorrectly or improperly, ultimately
someone in the chain of command would talk to them
about that and try to correct any inaccuracies?
MR. CRITTON: Form.
THE WITNESS: If we became aware of --

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midnight, and then I don't think that the policies
of the department directly address what to do in
that case. But generally the date that the officer
became aware of the information and the date that it
would be written and the date recorded here would be
one and the same.
Q Okay, fair enough. And the date on this
one is November 28th of 2004?
A Yes.
Q Now there's a section there that says case
number and it's blank on this particular form.
There's also a section that says file number and
that is blank. Can you explain to me what those
sections would be used for and, if you know, why in
certain circumstances they would be blank?
MR. CRITTON: Form, speculation.
THE WITNESS: The case number would be
generally where if there was an incident report
also on this where that incident report number
would be recorded. The file number is kind of
an old system. What used to be the organized
crime, vice and narcotics unit is responsible
for intelligence in the department and it's now
called the special investigations unit, and
they have their own -- that unit had its only

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BY MR. KUVIN:
Q Sure.
A -- that they were incorrect, yes.
Q Okay. My point being is, is that while
you may never have seen this particular document,
I'm sure in your job as Chief of Police these
documents came across your desk on a periodic basis
so you know what this document -- not maybe this
one, but you know what these are, correct?
A Yes.
MR. CRITTON: Form.
BY MR. KUVIN:
Q And you're familiar with them?
A Yes.
Q Okay. All right. Now let's talk about
this document. In the top right-hand corner where
it says the date of 11/28/04, the form itself, is
that date that's put in that top right corner
supposed to be the date that the incident report is
taken?
A They would normally be the same date, but
it would normally be written the same date that the
information the police officer who completed the
form became aware of the information, unless it
happened near midnight and it was written after

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filing system by category of crime. And if
this report fell into one of those categories
like, for example, let's just say 3 would be
prostitution and, you know, 3-001 would be the
first or -- it was actually by the year.
2009001 would be the first prostitution
intelligence report that's filed in that
particular year. Those numbers, if they
applied, would be placed where it says file
number.
BY MR. KUVIN:
Q Can we assume that those, since those are
not filled out, that a case or file was not opened
on this particular report?
A I don't know about this particular report.
It was not unusual that when these reports would be
created by generally a police officer in the field
that part would be blank. And then if it was
appropriate to be included in the organized crime,
vice and narcotics unit or special investigations
unit, I can't remember what year we changed it,
which would apply a name for the time that this was
written, then the detective who would place it in
the file of that specialty unit would then record
the file number if it was appropriate to do that.

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Q The next section says confidential, and
there's a Y and an N, which I assume is yes or no.
Who is it that makes the call or determination
whether or not an incident or intelligence report is
to be kept confidential?
A I guess there are opportunities to do that
along the way. The author of the report certainly
has that opportunity, but others along the way,
supervisors and so on, can change that if they chose
to.
Q Okay. What I'm wondering though is, were
there any guidelines at the department back in 2004,
let's say late 2004, as to what report should or
should not be kept confidential, or was it left up
to the individual officers to make that call along
the line?
A Well there are guidelines. The guidelines
basically are, or were, of whether or not the
information would be exempt by virtue of the public
records law.
Q Okay.
A And the one most typical would be an
active criminal investigation or active criminal
intelligence information.
Q Sure. All right. We go down here and the

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Q All right, fair enough. I'm not going to
test you on it or anything, but after having
reviewed it, can you recall having seen this report
at or around the time of the primary investigation
which took place in roughly February of '05 through
December of '05?
MR. CRITTON: Form.
THE WITNESS: No.
BY MR. KUVIN:
Q Okay.
A No as to if I recall whether or not seeing
it. I could have, but I don't recall.
Q Okay. These types of reports -- well
actually let me go down it really quick here.
There's a section that has the information which is
the content of the report; in other words, what the
officer is reporting, correct?
A It says information, yes.
Q All right. And it says there in
information content, there are boxes, either
verified, unverified, explain, partially verified or
similar info filed. Do you see that?
A Yes.
Q What are those sections used for and how
is this that an officer is to decide which one to

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officer that filled out this particular report is
Officer Munyan. Do you know whether he still works
at the department?
A As far as I know he does.
Q And the subject of this investigation, we
can agree, was Jeffrey Epstein?
A That's what it says, yes.
Q And the source that was utilized for this
report was Alfredo Rodriguez?
MR. CRITTON: Let me just object to form.
Are you just asking him to read, I just want to
distinguish. If he has personal knowledge,
that's great, but if he's just reading the
form, I'd like that to be clear. So form.
BY MR. KUVIN:
Q According to your business record at the
department, the source of the investigation was
Alfredo Rodriguez?
MR. CRITTON: Form.
THE WITNESS: That's what it says here.
BY MR. KUVIN:
Q Okay. And with respect to this report in
particular, you've had a chance to read through it,
correct?
A I read it quickly.

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check there?
A Well that's sort of an evaluation of the
quality of the information.
Q Okay.
A But verified would be exactly what it
says, if they were able to verify the information.
Unverified would be it's just information, and I
don't know the person who wrote it, doesn't know the
reliability of the information. Explain, I don't
think I wrote that part of the form, and I suppose
if that were checked that would be to require, you
know, some additional explanation. Partially
verified being, you know, partially verified. I
don't know what else to -- they're really
self-explanatory.
Q Okay, fair enough. It then says evaluated
by supervisor with an initial there. Do you
recognize that initial?
A No.
Q Who is Officer Munyan's direct supervisor
in the chain of command, if you recall, back in
November of '04?
A I don't recall. Eighty police officers in
the department, probably twenty that came and left
during that time period. I don't know.

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Q Do you know whether there was any follow
up regarding this initial report?
A Well I recall being made aware of the
information. I recall that there was some follow
up, yes.
Q Having taken a look at this report, if
this were something that would have came across your
desk, if it ever came across your desk in November
of 2004, is this the type of report that you think
would require a follow up?
MR. CRITTON: Form.
BY MR. KUVIN:
Q Some type of further investigation or
follow up, or is it insufficient to require any type
of follow up in your opinion?
MR. CRITTON: Form.
THE WITNESS: If I'm understanding your
question to mean does the information included
here suggest that there should be some follow
up -BY MR. KUVIN:
Q Yes.
A -- in a general sense, yes.
Q Okay. Do we know as we sit here today, do
you know whether any ultimate follow up did occur

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BY MR. KUVIN:
Q Okay. Do you know what, if any, follow up
was done regarding Exhibit 1?
A Well I don't remember ever actually seeing
this document. I may have seen it in the later
years, but certainly not at the time that it was
written, I can't remember seeing it at the time it
was written. I remember it being characterized or
summarized for me by one of the supervisors, I don't
remember who that was, explained to me in general,
and what I remember is some general mention of the
circumstances here and some follow up to that.
Q Okay. All right. Let me show you, just
so you've got further information in front of you to
review, is what we'll mark as Exhibit 2. And I
don't want to characterize it, but if you could just
kind of tell me what is Exhibit 2?
As I mentioned to counsel, there
should be 87 pages to that.
A It's Palm Beach Police Department Incident
Report, number 05-00368.
Q And what is this incident report
pertaining to?
MR. CRITTON: Just so I'm clear, is that
the only copy you have?

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later on?
A Yes.
Q All right. And is that the investigation
ultimately that you were referencing at the
beginning which occurred, it looks like it began in
January just a few months later, of 2005?
MR. CRITTON: Form.
THE WITNESS: I'd like to read this again.
BY MR. KUVIN:
Q Absolutely.
A What was your question again?
Q Yes. At the beginning when I was asking
you when the investigation began, you initially
thought it might have been in early 2005. I then
showed you this to help refresh your recollection.
And my question is, is the primary investigation,
which you recalled starting in roughly the beginning
of 2005, a follow up to this initial report back in
November of 2004, or were they two independent
investigations or something else? That's what I'm
trying to understand.
MR. CRITTON: Form.
THE WITNESS: I think the facts that we're
all here for today, that investigation in my
view did not begin by this document.

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MR. KUVIN: I've got mine and his.
THE WITNESS: I've only looked at a few of
the pages but it looks to be the Palm Beach
Police Department's investigation concerning
the sexual contact that Mr. Epstein had with a
variety of underage, meaning juvenile females.
BY MR. KUVIN:
Q Okay. The same Mr. Epstein that is
attending your deposition here today at the end of
the table?
A Yes.
Q And what I'm trying to just understand for
a minute is, going back to Exhibit 1, you said
ultimately you may have been informed later on of
Exhibit 1. Was that given to you during the
investigation that was going on in Exhibit 2, that
someone came to you and refreshed your recollection
or showed you maybe for the first time Exhibit 1?
MR. CRITTON: Form.
THE WITNESS: I don't remember anyone
actually showing me Exhibit 1. It certainly
could have happened, I don't specifically
remember that. I do remember receiving a
verbal summary of this with this information
that's actually included in here.

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MR. CRITTON: Spencer, would you pass me
Exhibit 1?
MR. KUVIN: Sure.
MR. CRITTON: I'm sorry, Exhibit 2.
MR. KUVIN: Yeah.
BY MR. KUVIN:
Q With respect to what's outlined in Exhibit
1, were there any other summaries given to you or
explanations given to you by officers in the
department referencing potential prior similar
incidents to what ultimately became the focus of the
investigation shown in Exhibit 2 other than Exhibit
1?
A Yes.
Q How many other prior incidents were you
made aware of during the primary investigation shown
in Exhibit 2?
A I don't recall exactly how many.
Q More than just the one that we have here
in Exhibit 1?
A Yes.
Q Do you recall whether anyone showed you,
and I know you don't recall seeing Exhibit 1, but do
you recall whether anyone showed you any other
reports, intelligence reports, regarding Mr. Epstein

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understanding that, yes, there were very attractive
young women coming and going from Mr. Epstein's
residence.
Again, this is all prior to what I
consider the trigger point of the investigation,
which was some time, according to that report, in
2005, not 2004, this.
Q Correct.
A We did some level of further inquiry and
we were of the belief that they were all adults.
And we were also of the belief that there was a
possibility that there could be prostitution. But I
mean that's just not something that we heavily
pursued, prostitution in private residences, it's
common everywhere in America. We didn't believe
that they were underage at that point and so we had
no further interest in it.
Q How can we obtain any and all prior
intelligence reports that may have touched on that
topic that you just discussed? What is the easiest
and simplest way to obtain those records?
A I don't know for a fact that they exist,
but if they did exist then you're the lawyers, I'm
not, and whether or not -- I'm telling you the legal
mechanism that you would use to get these things,

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when the primary investigation was taking place as
shown in Exhibit 2?
A I have to see if I understand your
question correctly.
Q Yeah.
A Did I see any other intelligence reports?
Q That pre-dated the investigation which
began in January of 2005?
A Okay, I didn't understand that. I don't
remember. I do know that I was made aware in a
general sense of information similar to that which
is included in Exhibit 1.
Q Tell me what you were made aware of and
who made you aware of that?
A I don't remember exactly who, but some
member of the staff, as part of either them coming
to my office or a very brief daily staff meeting
that we always had, told me that we had received
reports of seeing young women, attractive young
women, coming and going from Mr. Epstein's
residence. There was some follow up to that. I
think we may have encountered one or two of them.
They may have done a little bit of surveillance or
talked to neighbors to ask whether or not they had
seen that. I think we were of the general

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subpoenas, public records law, demands -Q All I'm asking -A Again, I'm not the Police Chief so I'm not
speaking for the department.
Q Fair enough.
A Those would normally be available if there
was not an active criminal investigation or criminal
intelligence exemption or some statutory protection,
sexual battery victims and so on.
Q Sure. How were they kept back in 2002
through 2006 at the department, were they kept under
the individuals' names? So, for example, if we ask
for all intelligence reports for Jeffrey Epstein
dating back to 2002, is that how they're kept, or
are they kept under the residence address, or are
they kept under the source's name, or are they kept
under the potential victim's name? That's what I'm
asking.
A They're going to be searchable by every
parameter except the victim's name.
Q Gotcha.
A And it'd be available probably most easily
by the subject name.
Q Gotcha. Okay. That's what I was asking.
All right. Let's talk about -- can I

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get Exhibit 2 back, please.
Let's talk about what we marked
Exhibit 2. If we look at Exhibit 2, at the top of
the report it has a section where it says occur from
date, and it has January 27, 2005. What does that
date represent with respect to this particular
incident report?
A From purely my recollection I don't know.
I'm sure that there's some event documented here in
the report that is dated January 27th, 2005.
Q And the report date, that represents the
date that the initial report is prepared; is that
correct?
MR. CRITTON: Form.
BY MR. KUVIN:
Q What does that date represent?
A It would typically represent the date that
the report was prepared, or begun actually. Because
there are supplementary reports typically speaking
in general, and that could last for years or days or
any other time period. That would be when the first
report generally is begun.
Q And the suspect in this particular
incident report, or suspects, were whom?
MR. CRITTON: Let me just object to form

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Q So you were personally made aware of the
ongoing investigation, correct?
A Yes.
Q All right. When did they initially come
to you, your officers, whether it be the
investigating officer, a captain, major, whoever it
may have been in the chain of command, and let you
know that this investigation was ongoing for the
first time, if you recall?
A On the date that one of the victims and
her, I believe, father, either contacted first by
phone or came into the police department, I can't
recall exactly which, I think it was probably the
March 14th date, which I see as the report date, or
thereabouts, and made the complaint. I received a
phone call from someone, I don't remember who, that
evening or -- I don't believe it was a workday, I
think it was a weekend or it was at night during the
week, one of the two, and they told me what had been
alleged.
Q And what did you personally do at that
point when you were made aware of that?
A Really nothing. I told the -- whomever it
was that called me to tell me about the
investigation, the report, I told them to keep me

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again, personal knowledge versus are you just
asking him to read the report. I'd like that
to be clear. Because he's not the preparer of
the report. Form.
BY MR. KUVIN:
Q The suspects in this particular report are
who or whom?
A I'm looking at the report. The first one
that I see listed is Haley Robson, Sarah Kellen,
Jeffrey Epstein. I think that's probably it. The
remainder looks like victims, and then it probably
gets into witnesses.
Q Okay. At some point during your tenure as
Chief of Police, were you made aware of this
particular investigation and this particular
incident report?
A Yes.
Q Were you personally aware that Jeffrey
Epstein was being investigated by your department at
the time as a suspect as part of this incident?
A Yes.
Q And are you personally aware that you were
also -- your department at the time was also
investigating Sarah Kellen and Haley Robson?
A Yes.

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informed.
Q Okay. And who was conducting the
investigation? In other words, who was in charge of
that initial investigation?
A Well initially the reporting officer,
whoever took the information and met initially with
the victim and her parent or parents, I don't recall
exactly which, was in charge of it at that point.
But it was assigned early on to an investigator, who
was Detective Joe Recarey.
Q Okay. All right. And the initial
reporting officer appears to be -- page 11 -correct me if I'm wrong, but appears that it was
Michele Pagan?
A Yes.
Q Do you recall speaking with Officer Pagan
directly after she took the initial report?
A About this report?
Q About what she learned during her initial
interview?
A No.
Q Do you know when the first time was that
you learned Jeffrey Epstein was the subject of the
investigation, was that during the first call you
got?

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A I think so, because we had the address and
it was -- or we were able to figure out the
address -- we didn't have the address -- early on.
And it was very easy sort of to figure out who it
would be, particularly in light of the prior
information that we had.
Q In looking at this form incident report
that we've marked as Exhibit 2, there's a section,
is there not, for victim information?
A Yes.
Q Looks like pages 3 through 8. Am I
understanding that form correctly?
A Yes.
Q All right. And how many victims according
to the form were listed during the investigation?
A According to the form, seventeen.
Q Okay. And what is the standard practice
for the department; in other words, why would
someone be listed as a victim in a form like this
according to department rules and procedures?
A Are you asking me the manner that they
were listed in here, or why is any victim included
in the incident report?
Q Let me clarify. There are different
sections of the report that appear to be heading

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if a crime has been reported, I think that's -and the victim is present and we know that
victim's identity, that really is enough at the
early stage to get them put in a victim block.
BY MR. KUVIN:
Q Okay, fair enough.
Now with respect to the initial
investigation, you said that you advised the officer
to keep you informed of what was going on generally?
A Whomever originally informed me of this
after the victim and the parent came forward and
made the complaint, yes, I may -- I mean I may have
said something like hey, are we doing this, are we
doing that, which usually the officers of the
department are so good I don't have to ask them
that, but it's something I do anyways. And in a
case like this it could have been, you know, have we
contacted Victim Services and so on. I may have
said something like that, but I do remember saying
keep me informed because I realized that this was
something that I wanted to be informed of as it
progressed.
Q When is the next time that you can recall
being updated on what was going on? I'm trying to
get a chronology of the information you knew and

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such as suspect arrestee, section that says victim,
and then in the last part a section that says other
person information. Am I reading the form
correctly?
A Yes.
Q Okay. I'm wondering how is it that
department guidelines generally state that an
officer should put someone in the victim information
section versus in the other person information
section?
A And there are other categories by the way,
reporting person, complainant, witness and so on.
Q Correct.
A But a victim is categorized, classified as
a victim if we believe there's a possibility that
they're a victim of a crime.
Q Okay. So am I correct in stating that
based upon the investigation, in order to put
someone in the victim category there would have to
be sufficient probable cause in the investigating
officer's mind that there was a crime committed
against that person to place them in that section?
MR. CRITTON: Form.
THE WITNESS: No. Probable cause really
wouldn't be the standard of whether or not --

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when you knew it. That's where I'm going with my
questions.
A It was not long after the initial
notification, it would have been a day or two or
less. If it happened on a weekend, and we could
look this up, I would have at a minimum heard about
it in some more detail on a Monday. But it's a case
that early on I was informed of the progress almost
on a daily basis.
Q Okay. Would you agree with me that given
the subject of the investigation, as well as the
content and nature of the allegations that are being
alleged, that this was potentially in your mind a
high profile investigation?
MR. CRITTON: Form.
THE WITNESS: Could you repeat that?
BY MR. KUVIN:
Q Yes. I'm wondering if at the beginning of
this investigation you were concerned at all that
because of the nature of the allegations, as well as
the subject of the investigation, that it may be a
high profile type investigation?
And by high profile I'll define what
I mean. I mean something that would catch the
attention of press, media and potentially garner a

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higher profile than your standard investigation?
MR. CRITTON: Form.
THE WITNESS: I was concerned first
because of the seriousness of the allegation.
BY MR. KUVIN:
Q Okay.
A Was I aware, did I realize that this could
become a high profile investigation, yes.
Q Is that why you wanted to be kept updated
frequently?
A For both reasons, yes.
Q Fair enough. What is the next thing in
chronology that you learned with respect to the
investigation and how it's going, factual
information that you start to learn?
A I mean this is four years ago, I don't
have every single conversation relating to this case
committed to memory in great depth. Because for a
period of time I heard about it quite frequently.
So I mean I can't tell you factually, but I would
generally know more information about the case as
the department became informed.
The early on the information was very
brief, the first phone call. And then I received
another phone call after there was some in-depth

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detectives and people. And this is like
layers. I didn't generally talk to the
detective early on, he would talk to his
sergeant, would talk to his captain and then
end up talking to me, that more information
about what actually happened from the viewpoint
of the victim. Mr. Epstein himself, I knew a
little bit about him, but the department
certainly became better informed of by
reputation, at least news media for the most
part, of his life.
And then as time went on there were more
victims and more victims and all sorts of
different fact scenarios that were just
generally summarized for me. Once the report
was written I read it, and I just followed the
progress as the investigation proceeded.
BY MR. KUVIN:
Q Did you ever have a direct hand in
controlling the investigation, or did you leave that
up to the detectives?
A Well I generally have some involvement in
serious investigations. And what I mean by that as
involvement is, I become informed and I would
provide what I would consider guidance on how to

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interview of the victim, the first victim. And -Q What did you learn about that?
A I remember generally that she described a
variety of different things that to the detective
conducting the investigation seemed credible. And
I'd remembered some suggestion that she was not the
only -- likely not the only victim.
Q Okay.
A I don't remember the detail of the
conversation of the second time I was informed about
this, but generally though, that's the best I can
characterize it.
Q Fair enough. Let me do it this way, I'm
not looking for a verbatim, exact date and time
information. Can you tell us generally, summarize
for us, what the progression of information was that
you learned regarding the investigation? Walk us
through what you learned generally about the
investigation?
MR. CRITTON: Form.
THE WITNESS: Well once it had been
reported to us, then I was reminded of the
prior reports of young women visiting
Mr. Epstein's residence and possibly even for
money. I began to learn more through the

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proceed. Did I ever personally become involved in
the investigation and interviewing witnesses or any
of those things, no. Did I control the
investigation, I suppose that if you asked Detective
Recarey he would say that at some point he was
reporting directly to me. And that was as much as
important to keeping me informed as to my
involvement in helping develop the investigation,
giving advice to those who were actually performing
it. But that's pretty much how I handle anything
serious.
Q Okay. What I'm trying to find out is if
you can recall as you sit here today, having
directed any of the officers to take any particular
action? In other words, go out and, you know,
surveil this person, or go do a tap on this phone or
go do something in particular?
A I try not to be autocratic, and I'm sure
at some point in this I said well, we're going to do
a search warrant, right, you need to do a search
warrant, or why don't you go re-interview this
witness because what I read here is really
incomplete, or -- you know, that kind of thing. Do
I specifically remember all of that, no, I don't.
Q Well do you remember what hand you might

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have played with respect, and you mentioned the
search warrant, but with respect to that warrant?
In other words, did you have any hands-on direction
or control over the warrant and how it was going to
be filled out and what was going to be looked for?
A No.
Q Okay. Did you review the warrant prior to
its issuance?
A I don't believe so. You mean application
for the warrant?
Q Application for the warrant, yes.
A I don't think so.
Q As you became more and more informed on
the progress of the investigation, what actions, if
any, did you take that you can recall?
A I continued to be informed as it
developed. Actions. My involvement relating to the
actual investigation itself was pretty much limited
to staying informed and providing advice and in
probably some case direction to the investigators,
who were all very competent.
This isn't -- when you have a
well-functioning police department, the police chief
doesn't go out there and tell people to do things,
they know how to do things, and that's what they

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first conversation was about with State Attorney
Barry Krischer?
A I told him that we had an investigation
that was serious that involved a very noteworthy
person and that involved a number of underage
females, that it was of a sexual nature. I was
concerned that we had not reached all of the
victims, and we hadn't, I'm sure, at that point. I
told him that I felt like the suspect would probably
become aware of this investigation at some point and
that he should probably expect some contact from the
suspect Mr. Epstein's lawyers. And I told him that
I wanted to keep him very well informed on this and
that I hoped that he would do the same. And that we
would have to have more contact about this in making
sure that it was handled responsibly, intelligently
and appropriately as it moved forward.
Q Did you tell State Attorney Barry Krischer
at the time who the suspect of the investigation
was?
A Yes.
Q So he was aware at that time that it was
Jeffrey Epstein?
A Yes, and he didn't recognize the name.
Q Fair enough.

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did. More of keeping informed, and on some
occasions providing direction. Never personally
going out and actually doing any of this.
Q Can you recall your first contact with
anyone outside the department regarding this
investigation and, if so, who was that with?
A State Attorney Barry Krischer.
Q That was your first contact with anyone
outside the department, your department, regarding
the investigation?
A Well that is a huge broad question. I did
make clear that we needed to keep this information
very confidential for lots of reasons; rights of
victims and potential news media interest and so on.
But other than a Palm Beach Police Department
employee, the first person that I think that I can
remember talking about this would have been the
state attorney.
Q Okay. That conversation, would that have
taken place sometime late in 2005 or later, if you
recall?
MR. CRITTON: Form.
THE WITNESS: Would have been 2005, yes.
BY MR. KUVIN:
Q And can you recall generally what that

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You mentioned something that I want
to ask you about, and that's you thought that
ultimately Mr. Epstein would become aware of the
investigation. How is it that you thought he might
become aware of the investigation?
A Well the victims were very young juveniles
and I had been made aware that some of the parents
were enraged. I thought that there was a
possibility that the individual juveniles or their
family would contact Mr. Epstein. I thought that at
some point they would hire lawyers, and obviously at
some point they did, and I just -- I mean I'd been
there a really long time, I know how investigations
of this type -- well, investigations of noteworthy
individuals and so on go, they're extremely
difficult to contain. And I felt like this would
be -- so I wanted the state attorney to hear about
it from me first and make sure that we had some
relationship established that we would work this
together. And I knew that it would require some
cooperation from his office. Our detectives had
already talked to his assistants, but I don't think
his assistants had informed him of the investigation
at the point that I talked with him.
Q Okay. All right.

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And at what point did you learn that
Mr. Epstein, in fact, did become aware of the
investigation?
A I think the point that I actually knew
that it was, it was reported to me by one of the
detectives that one of the victims had been
contacted by a private investigator that the
department believed was employed by a lawyer of -employed by Mr. Epstein.
Q On that topic, at some point did you
become aware that Mr. Epstein was actually
investigating you?
MR. CRITTON: Form.
THE WITNESS: Yes.
BY MR. KUVIN:
Q Tell me about that?
A Well I heard through various individuals
that one of his lawyers, Mr. Dershowitz, had been
contacting private investigators in the area to
perform background investigations on me. I know
that there was a public records law demand filed by
several private investigators on the Town of Palm
Beach for my personnel records. And I actually ran
into one of the private investigators very early
on -- you asked me when I first became aware --

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A No.
Q First time ever?
MR. CRITTON: Form.
BY MR. KUVIN:
Q First time you can recall it going to this
extent?
A The only time I ever recall anyone ever
going to this extent.
Q How long were you aware there was
surveillance on you personally?
A Well, you know, I just took the approach
that I have nothing to hide, and I just lived my
life so I tried not to look around every corner. I
felt like it was around three months.
Q At any time during the investigation, did
you become aware that investigators were also
surveilling and investigating potential victims?
A That had been reported to us by victims.
And the lead investigator in the case also felt like
he was being surveilled, people were picking up his
trash and so on.
Q Is that Detective Recarey?
A Yes.
Q So there was a time that your officers
became aware it was being investigated on?

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Q Yeah.
A -- that basically told me that. I also -I mean I saw surveillance a number of times. I
didn't know precisely who had hired those persons,
but I mean I had surveillance for a fairly long
period of time.
Q There was surveillance you noticed on you?
A Yes.
Q Do you know why?
A No, no, I don't. It would be an
assumption. In general sense, you know, there's an
attack on the case and if that doesn't work there's
an attack on the investigators. I don't know. I
don't know. Shouldn't say that.
MR. CRITTON: Form, move to strike.
BY MR. KUVIN:
Q You were working as a police officer for
twenty-eight years and then as a chief -- well -A And two years prior to that actually.
Q Right. During your entire history as a
police officer, can you ever recall someone going to
that length? In other words, a suspect conducting
an investigation on you such as the lengths that
occurred in this case which include surveillance on
you?

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MR. CRITTON: Form.
THE WITNESS: One officer, one detective.
BY MR. KUVIN:
Q To the extent they were picking up his
trash?
A Yes.
Q Were you aware of that ever occurring in
your career to officers working under you?
A I didn't say it never occurred to this
degree.
Q Got you.
A I think if you're asking the question do I
know of any other law enforcement officers who know
as part of their job somebody investigated them and
picked up their trash, not that I can specifically
recall.
Q Okay.
A Other than the police department itself,
we've had private investigators take trash at the
police department itself, we've caught people doing
that.
Q Obviously at some point Mr. Epstein was
tipped off as to the investigation because of the
investigators that you became aware of. Did you
ultimately know how he became tipped off?

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MR. CRITTON: Form.
THE WITNESS: No.
BY MR. KUVIN:
Q During the investigation, were you made
aware of a prior incident involving a house manager
from Mr. Epstein, Juana Lessy (phonetic), who was
accused of burglarizing the home and stealing some
money?
A I was made aware of that, yes.
Q During the investigation, and by the
investigation I mean the investigation outlined in
Exhibit 2, during that investigation, did you become
aware that there was surveillance equipment
contained within Mr. Epstein's home?
A I remember hearing from the detectives
after the search warrant that there was some video
cameras, yes.
Q Did you at any time learn that there was
active surveillance video within the home because of
the fact that they had caught Mr. Leesey on film
many years prior on a burglary incident?
A Yes.
Q During the search of Mr. Epstein's home,
was there any surveillance, or were there any
surveillance tapes that were taken into custody,

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Q What ultimately became of all that
evidence; where is it today?
A All the evidence that the police
department had relative to this investigation was
turned over to the FBI as a result of the grand jury
subpoena in the federal investigation. I seem to
recall some piece of evidence that we thought should
have been evidence was a computer that ended up in
the hands of a private investigator that I think was
employed by one of the lawyers representing
Mr. Epstein. But all we had in our custody, that
was turned over to the U.S. Attorney.
Q Let me ask you about that because I was
going to get to that. But the computer that you
were made aware of that ended up in the hands of the
investigator, tell me a little more about that?
What did you learn and when did you learn it?
MR. CRITTON: Form.
THE WITNESS: I don't remember a lot more
than that. I do -- I don't remember the
circumstances, but it ended up in a private
person's hands and I had wondered why that was
the case. I don't recall the specifics of it
and I do remember there were some discussions
about getting access to it, and I remember I

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either tapes or videos or CD's? And any type of
media whatsoever, I want to be clear about that.
A I can't recall definitely, I can't. I'm
sure it's here included in the report that I have
not memorized. I can't say definitely. It's likely
but I'm not entirely sure.
Q Were you made aware -MR. CRITTON: Move to strike, speculative.
BY MR. KUVIN:
Q Were you aware that at the time
Mr. Epstein's computers were seized during the
search?
MR. CRITTON: Form.
THE WITNESS: Yes.
BY MR. KUVIN:
Q Were you also made aware that certain
photographs were seized from the home during the
search?
A Yes.
Q Did you at any point get a chance to
review any of the physical evidence that was in fact
seized from Mr. Epstein's home?
A I had the chance but I never did it.
Q You never actually looked at any of this?
A No.

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think asking the U.S. Attorney why aren't we
getting a search warrant for that. But I don't
remember anymore about it other than that. I
don't know whether or not it ever came into the
hands of the law enforcement at the Palm Beach
Police Department or the FBI.
BY MR. KUVIN:
Q Do you recall the name of the investigator
or investigating agency that ultimately that
computer you heard might have ended up in their
hands?
A No.
Q Did you write any e-mails or any written
communication to the U.S. Attorney's Office
regarding that computer? Was there any written
discussions about that?
A No.
Q Do you recall who you spoke with at the
U.S. Attorney's Office or FBI about that computer?
A I think it was Marie Villafana. She's the
U.S. Attorney.
Q Did the police department, the city, Town
of Palm Beach maintain any of the physical evidence
seized at Mr. Epstein's home after the grand jury
subpoena from the federal government?

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A No. The grand jury subpoena was all
encompassing.
Q So they took everything out of your
department?
A Yes. Every item of evidence, yes.
Q Were you continually kept up to date about
the contemporaneous federal investigation?
A No.
Q They kept you apart or separated from
that?
MR. CRITTON: Form.
THE WITNESS: I received partial
information. I think they were very purposeful
in not keeping the Palm Beach Police Department
informed. And generally when we wanted
information while we still had an active
investigation in the state case, we would have
to ask for it.
BY MR. KUVIN:
Q Okay. Why was that?
A I think you have to ask them.
Q I didn't know if you knew or not. In
other words, if you started this investigation on a
state level, you all collected all the evidence from
the home in a search warrant and you had an active

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to -- let me clarify this -- was not a joint
federal state investigation, this was their
investigation and they felt they needed to do
this, I don't know, very cleanly and separate
from us in order for their investigation to
have full credibility. So early on I was very
tolerant of not being informed about their
investigation.
BY MR. KUVIN:
Q With respect to their investigation, at
any time did you in fact become aware of victims
outside of Palm Beach County?
A Yes.
Q When did you become aware of that and what
did you learn?
A Well as their investigation would go on,
they would principally communicate with our
Detective Recarey and tell him about some of the
details, usually only to the extent necessary to get
the information that Joe Recarey had, because
they're developing their case and they needed us to
help with that a little bit. So -- and so when they
had fact A and needed fact B, they came and told us
A and we would be able to fill in the blank.
On some occasion I did talk with

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investigation going, I'm wondering if you know why
the feds essentially took over and cut you guys out
of the loop so to speak?
MR. CRITTON: Form.
THE WITNESS: I do know -- I think I know.
We felt that -- I wouldn't say cut us out of
the loop, that's probably an inaccurate
characterization, but at some point it was
clear that the state case had gone as far as it
should be and the FBI began an investigation.
And when it was clear that this would be more
fully investigated by the FBI, because there
were elements according to the -- and even the
state, they really had the case, they had the
ability to investigate it and they had venue
and jurisdiction and that was very clear. And
when they asked originally for the evidence, I
had -- I talked to the State Attorney and told
him that. And I told them that I would supply
under some legal order, although I wasn't
planning on resisting it, and served with a
grand jury subpoena.
The second part of your question, at some
point someone from the U.S. Attorney's Office,
probably Marie Villafana, told me that in order

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them, I talked with FBI Special Agent Nesbitt
Kirkendall, and she would tell me how the case was
developing generally, you know, in a very general
sense with nowhere near the level of specificity my
own detectives were able to keep me informed, and
that's how it went most of the time.
Q Specifically though, with respect to the
victims that might have been outside Palm Beach
County or the State of Florida, what did you learn
about them and when did you learn it?
A I don't think I learned their names until
months later.
I see he's holding up the five
minutes left.
Q You can answer that and then take a
bathroom break.
MR. CRITTON: Form to the last question.
BY MR. KUVIN:
THE WITNESS: Could you repeat?
BY MR. KUVIN:
Q Yes. I'm trying to find out what you
learned about potential victims outside of Palm
Beach County and the State of Florida and when you
learned it?
MR. CRITTON: Form.

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THE WITNESS: Primarily I learned that
they existed. Never really learned the details
other than they were varied. The fact
scenarios were very similar to the victims we
had here in Palm Beach.
When you say outside of Palm Beach County,
it could either -- you could mean that by
saying the elements of the crime occurred out
of Palm Beach County or there were victims that
the elements in the event of crimes but I mean
would apply to both situations.
BY MR. KUVIN:
Q Just before we take a quick break, did you
also learn that the elements of the crime occurred
to certain women outside of Palm Beach and the State
of Florida?
MR. CRITTON: Form.
THE WITNESS: Yes.
BY MR. KUVIN:
Q And that's what I'm talking about just to
clarify. Let's take a break. I'm going to come
back and touch on that subject a little more when we
come back.
(Brief Recess)

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the U.S. Attorney for some way to match that
up, here's our victims. I offered to give them
the list of our victims and to tell us whether
or not every one of them have to be considered
under the federal case and non-prosecution
agreement. And what they did was sent me a
letter which listed the federal victims with
instructions to destroy the letter in some
federal rules of procedure that I don't
remember any of it because frankly I destroyed
it. And from that letter I seem to recall
there were high thirties, early forties' number
of victims listed there. And the individuals
who came to us later and made a state complaint
were covered in the federal investigation so we
didn't need to proceed further.
BY MR. KUVIN:
Q Okay, let me see if I understand this.
The feds at some point sent you a
letter that listed all of their potential victims?
A Yes.
Q With instructions -A I'm sorry. They listed the victims that
were covered in their non-prosecution agreement,
that's what I remember the letter to say.

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THE VIDEOGRAPHER: We're back on the
record, 11:42. This marks the beginning of
tape 2.
BY MR. KUVIN:
Q We were talking about victims that
potentially were out of Palm Beach County or the
State of Florida. At any time, did you learn how
many potential victims may exist outside of the
State of Florida where the elements of the crime may
have occurred outside of the state?
MR. CRITTON: Form.
THE WITNESS: A precise number, no, an
approximate number, yes. At some point in the
federal investigation they shared with us that
there were approximately forty victims. At the
end of their investigation we had a situation
where we didn't really know who were victims in
the federal case, and that was important to us
to see if we had victims who came to us late in
the federal case to the Palm Beach Police
Department and they complained. So if they
were not part of the federal investigation,
then I think we would have had some
responsibility to investigate, even after the
state sentencing had taken place. So I asked

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Q Gotcha, okay. And that came with
instructions to destroy the letter after reviewing
it?
A Yes.
Q Pursuant to some federal legislation or
law?
A I think it was a rule or something, I
can't remember, yes.
Q Okay. And at some point you compared that
list with the potential victims that you had in the
state investigation?
A Yes.
Q Were there any additional girls in the
state investigation that were not covered by the
federal list? In other words, if there were thirty
some odd, almost forty on that list, were there any
additional that didn't match up to that?
A No.
Q They all matched up?
A Yes.
Q Do you still at the department -- well,
let me ask it this way, you're not there anymore.
But did you at the department, when you left, still
have a list of all potential victims?
A No.

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Q How did you keep that information when you
were there?
A It was a letter that I received from the
U.S. Attorney.
Q Hang on, back up, you misunderstood my
question. I'm talking about the state, your
investigation. In other words, what did you match
the forty some odd victims in the U.S. Attorney's
letter with in your list? I'm looking for your
list.
A The incident reports.
Q Okay. How many incident reports did you
all generate?
A I don't recall if the latter victim, or
victims, generated a new case number or if they're
included in this. It seems like it probably
generated a new case number but I can't say for
sure. But Detective Recarey would know.
Q Okay. All right. Would all of the
potential victims that were being investigated by
your department prior to let's say July of 2006,
have been listed in this incident report we've
marked as Exhibit 2? Were there any additional
incident reports?
MR. CRITTON: Form.

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we had no further involvement. So it wasn't
something that I would be completely informed about.
Q Okay. At any point did someone, anyone,
come to you and either formally or informally ask
you to back off the investigation, stop the
investigation, or alter your investigation in any
way?
A I had individuals suggest that the
department's approach to the investigation and my
referral of the investigation to the FBI was more
horse power than the investigation deserved. And I
had other individuals suggest that -- yeah, the term
back off probably fits, yes.
Q Who?
A I think that Barry Krischer would be
included in that description.
Q Who else?
A I had people in the community in Palm
Beach that either made comments directly to me or to
others who relayed them to me that I didn't need to
take the tact in the investigation that we did,
which is completely investigate it and then refer it
to the FBI after the state case was resolved.
Q Do you remember any of those people that
mentioned it either to you directly or through your

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THE WITNESS: For the time period that
that covers -BY MR. KUVIN:
Q Yeah. For the time period of January 27
of '05 through the last page of this Exhibit 2 is
July 12 of '06.
A I think there was only one report.
Q Okay.
A When you mention victims, and that's sort
of a subjective word, there were individuals that we
felt their activity had constituted a crime but they
were not cooperative.
Q Right.
A You know, they're not victims but they're
in here and the numbers change if you want to add
all them in.
Q Okay. And what I'm just trying to find
is, is in this particular report we've marked as
Exhibit 2, it has, if I recall, seventeen victims
listed and it goes through the date of July of '06.
Do you know how many girls approached the department
later on, total number?
A Definitely one and possibly more, I'm not
sure exactly. But once I realized that they had
been considered by the federal investigation, I knew

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department?
A Well it wouldn't be, I think, appropriate
for me to list individuals that I don't know
first-hand said that. I had many people relate
conversations of another on the cocktail party
circuit that suggested that we approach this in a
way that wasn't necessary. I had one individual who
actually came to see me a couple of times about
this.
Q Who was that?
A Jerry GoldSmith.
Q Okay. What did he say?
A He said that this wasn't necessary, this
was a case that really was very minor. The victims
had lifestyles that don't make them -- shouldn't
make them believable to the police department. And
he said that I shouldn't have referred it to the FBI
and Palm Beach solves its own problems, why did I do
that, why am I after Jeffrey Epstein. A couple of
occasions that was the general topic of the
discussion.
Q Did you know who Mr. Goldsmith was?
A Yes. I know them all.
Q Lives on the island?
A As far as I know, yes.

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Q Did you get the impression that he was
trying to get you to essentially either drop or
smooth over or quiet down the investigation of
Mr. Epstein in any way?
MR. CRITTON: Form.
THE WITNESS: Initially, yes.
BY MR. KUVIN:
Q And how did you respond to that when you
spoke to him?
A I told him that those kinds of suggestions
to me were improper and he should stop, that he had
taken a couple of steps down the road towards
something that could eventually constitute a crime.
We talked several times. Early on it didn't end
favorably.
You know, this is an individual which
I had to interact with in my official capacity and
in his official capacity as well. It was more
difficult and more emphatic of what I had just
described in our first conversation and less so in
our last about it.
Q And just so the record is clear,
Mr. Goldsmith is who?
A He's a resident of Palm Beach. He is
still the chairman of -- I think, last knowledge of

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Q Okay, fair enough. As a police chief, did
you think that rich people deserve different
treatment under the law?
MR. CRITTON: Form.
THE WITNESS: No. My responsibility was
to protect everyone that lives in Palm Beach
and preserve their constitutional rights and be
the police department for all. And I think
that under the law, particularly the criminal
laws, that all people have to, by nature of our
system, be treated exactly alike.
BY MR. KUVIN:
Q And you would agree with me that
Mr. Epstein should not obtain any favors just
because he may be a wealthy billionaire under the
law?
MR. CRITTON: Form, argumentative.
BY MR. KUVIN:
Q Would you agree with that?
A Nor should he be treated any worse.
Q Fair enough.
Other than Mr. Krischer, did anyone
have any discussions with you regarding
Mr. Epstein's plea deal that you can recall?
A I had discussions with the U.S. Attorney,
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mine, chairman of the police pension board. And he
was a candidate for mayor on the last election of
Palm Beach. And an acquaintance of mine for many
years. And, you know, he described himself as a
close friend of Mr. Epstein.
Q Is there anyone else that you can recall
coming to you directly and trying to alter or quiet
down the investigation in any way?
A I received comments from people from a
variety of different viewpoints that -- nowhere near
to the degree of those of Jerry Goldsmith, but -- in
some cases I had people tell me hey, he's a Palm
Beacher, why are you investigating a Palm Beacher.
And, you know, my responsibility is to protect and
investigate, or it was when I was chief, all the
citizens.
And a couple of those were sort of,
you know, somebody had a drink too many or something
at an event and I really didn't give that too much
credence. But for the most part I knew who, on the
cocktail party circuit, had said that I kind of
exceeded my bounds. But I know that all third hand
and fourth hand and I don't even know if it's
completely accurate, so I wouldn't feel comfortable
in relaying any of that to you.

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Assistant U.S. Attorneys.
Q Other than Ms. Villafana, who else did you
speak with there?
A Well I spoke with Alex Acosta, the U.S.
Attorney, and Nesbitt Kirkendall, the FBI agent.
Her supervisor, Junior Ortiz. Mr. Sloman, whose
first name escapes me, who was a special agent in
charge of Miami. And these are all people that I
interact with as part of my other responsibilities.
Q Sure.
A So I had conversations with them not as -we met for this reason, but we were together for
some other reason, and there were, you know, some
minor conversation concerning it. You know, there
are others in the U.S. Attorney's Office, there are
others.
Q Let me make it simpler. Was there anyone
outside of the U.S. Attorney's Office, the FBI or
the State Attorney's Office who ever discussed with
you directly Jeffrey Epstein's plea deal?
A Well of course as I interacted in the
community, people would read about it in the news
media and make comments to me and, you know, would
ask me questions. And that -- plenty of people.
Q Anyone with any authority to -- over you?

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In other words, was there anyone with authority over
your position as Chief of Police at the time they
had discussions with you about that plea deal?
A Well who has authority over my position as
Chief of Police, that's only one person, that's the
Town Manager. The Town Manager has hire, fire
responsibility, I am a direct report to him. And,
yes, I did have conversations with him because I
wanted to have him informed. Because this was on
the news media, there were things being written
about the investigation, about me personally, and I
wanted him to know about those things from me. So I
had -- his name is Peter Elwell, he was Town Manager
the entire time. He is still Town Manager and was
the entire time that I was the Chief, and throughout
this investigation I talked with him about it
several times.
Q And it's E-L-W-E-L-L?
A Yes.
Q Did he ever try to at any point guide
either your investigation or discussions regarding
plea deals for Mr. Epstein?
A No.
Q Were any suggestions ever made to you by
Mr. Elwell about what plea Mr. Epstein should or

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an unfavorable career move for me to ask the State
Attorney to remove himself from the case and to
refer it to the FBI and to advise the victims that I
was going to do that. I had plenty of people that
told me that that was a mistake.
Q Can you recall anyone in particular that
said that to you directly? And I'm not talking
about, you know, residents of the town that just may
be on a cocktail circuit, I'm talking about somebody
that you either knew directly or someone that worked
for the city or someone that said they worked for
Mr. Epstein?
MR. CRITTON: Form.
THE WITNESS: I never feared that, no. I
had friends of mine that've said wow, do you
realize what you just did was like a really big
thing, and people were going to look at you a
little differently now. I mean, yes, I had
that, but I never considered any of those
things a threat to my job. And if I did, it
wouldn't matter, people threaten my job on a
regular basis for a variety of different
things.
BY MR. KUVIN:
Q Did anyone come to you purporting to be

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should not get?
A No.
Q In other words -A We didn't have that kind of relationship.
He recognized that I was the law enforcement
professional and he didn't step into that world at
all, he was very supportive.
Q Okay. At any point was your job ever
threatened as a result of the investigation into
Mr. Epstein?
A No. Because again, one person has control
over my job and that's the Town Manager, and I knew
that he supported me and thought that I was a
competent Police Chief and gave me extremely
favorable evaluations and never, ever said anything
about this case, about how I should do anything.
Q Regardless of whether someone did or did
not have the actual authority over your job; in
other words, whether they had that ability to fire
you or not, do you recall receiving any threats to
your job with respect to the investigation? In
other words, someone that may not have had the
actual authority to fire you but nonetheless
threatened your job?
A No. I mean I had people that said it was

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from Mr. Epstein or representing Mr. Epstein
directly to talk to you about the plea deal?
A I suppose Jerry Goldsmith would fit that.
He basically introduced me at one point to
Mr. Epstein and I don't think he realized what he
had begun to do and he was trying to help out a
friend, and I think he truly thought that the case
was a tempest in a teacup.
Q Okay. At some point during the
investigation, did you become aware that requests
were made to interview Mr. Epstein? In other words,
did your department request an interview of
Mr. Epstein directly?
A Yes.
Q And what was the response to that request?
A Well we did it through the State
Attorney's Office because we knew that they had
contact with Mr. Epstein's attorneys and at that
time I think it was primarily Mr. Dershowitz. And
initially there was an interview set up, which I
thought that was great because, you know, I mean I
want to get all the facts before we really move
forward and accuse anybody of anything. And it was
cancelled, then it was rescheduled and it was
cancelled at least a couple of times.

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Q And did it ever actually take place?
A No.
Q Never got a chance to actually sit down
and speak with him?
A After the point of when we began the
investigation as part of the investigation?
Q Yes.
A No.
Q Okay. Did there come a time when you were
told that he was not going to sit for an interview?
A I think so, yes.
Q Do you recall -A Scheduled, rescheduled situation, you
know. At the end of that I think that we were told
it wasn't going to happen.
Q Okay. I'm going to go through a number of
people that represented or purported to represent
Mr. Epstein from time to time.
Let me just ask you real quickly, do
you recall having any direct conversations with
Mr. Dershowitz?
A Did I ever?
Q Yes.
A No.
Q Do you recall ever having any direct

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A Yes.
Q Do you recall having any conversations
during the investigation with her?
A I think so.
Q Tell me about that? What do you recall
generally?
A Well early on when we were conducting the
investigation, we needed investigative subpoenas and
other things from the State Attorney's Office. And
there were a couple of occasions when our detectives
felt as though our investigation and the things that
we would need from the State Attorney's Office would
benefit by my talking to them, and I did. I think I
talked to her at least once, I don't remember when,
and I don't remember what about. I know I talked
with her superior, a Lanna -Q Lanna Belohlavek?
A Yes, Belohlavek, at least once, and
probably more than one time.
Q At what time, if ever, did you learn that
Dahlia Weiss was going to be removing herself from
the investigation?
A I learned about it from Detective Recarey.
At what point, I think I learned about her
relatively soon after it happened. Because we were

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conversations with Jack Goldberger, the gentleman
sitting here?
A In my life, yes.
Q No, I just mean with respect to this
investigation?
A Probably only just in passing in the
hallway today. I don't think that we talked during
the investigation. I think that it's a -- I
remember he asked personally at the department if
there's a possibility, that a representative to the
department may have, but I don't remember.
Q Just talking about you -A Okay.
Q And the time frame I'm looking at here is
prior to, let's say today, where you may have seen
some of these gentlemen standing out in the lobby,
prior to today, can you recall having any
conversations with the Burman, Critton firm or
Mr. Critton here today who's Mr. Epstein's civil
attorneys?
A No.
Q Do you know a Mr. Attenbury?
A No.
Q Do you know a Dahlia Weiss, Assistant
State Attorney Dahlia Weiss?

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told -- our investigators were told that she was no
longer involved in the case.
Q And did you learn why?
A Well our detectives were either told or
figured it out on their own and passed on to me that
her husband, I believe, was a member of a law firm
that represented Mr. Epstein.
Q At any time did you become concerned that
she may have been sharing any information with
Mr. Epstein or his lawyers?
A I became concerned when I was made aware
of it, that I felt like it was improper and a
conflict of interest.
Q Did you contact anyone about that?
A I either had a discussion about it with
the FBI or the U.S. Attorney or it was a piece of
information that they relayed to me, one of the two.
I know that -- now would I
characterize that as a complaint, I felt it was
improper. I didn't personally make a complaint in
reference to that but I had some discussion with the
federal authorities about that being improper. I
don't know who initiated that.
Q Do you know whether the federal
authorities began looking into that connection at

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all; in other words, the impropriety of it or
investigate whether or not there were any
conversations going back and forth that should not
have occurred?
A I don't know if they did.
Q Do you know whether or not the ASA
Ms. Weiss was removed before or after you learned
about it?
A I learned about it before then.
Q Before she was removed?
A Well I learned about it before I became
aware that she was either removed or removed
herself.
Q What I'm trying to find out is, is that do
you know whether she removed herself independent of
it coming to light or whether or not she was
ultimately removed because of what you learned?
A I don't know.
Q Do you know who Mr. Reinhart is? Does
that name sound familiar at all?
A Is that Bruce Reinhart?
Q Yes, Bruce Reinhart, one of the U.S.
Attorneys on the criminal case.
MR. CRITTON: Form.
THE WITNESS: I recognize the name, yes.

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MR. CRITTON: Form.
BY MR. KUVIN:
Q Do you understand my question?
A No.
Q Let me rephrase it.
Dahlia Weiss, an attorney who was
working as an Assistant State Attorney on this case,
correct?
A Yes.
Q Her husband worked for Mr. Epstein's
criminal attorney Jack Goldberger, worked with him
as a partner. One of the U.S. Attorneys who was
involved in the investigation was hired by
Mr. Epstein as one of his attorneys. Were you aware
of any other connections between the investigative
teams and Mr. Epstein other than those two
individuals?
MR. CRITTON: Form.
THE WITNESS: I heard that one of the
Assistant U.S. Attorneys, and this is -- it
would be -- this is a rumor and I don't want to
report a rumor.
BY MR. KUVIN:
Q Well it's my job to follow up on that
rumor to see if it's true. Whether it's admissible

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BY MR. KUVIN:
Q Did you become aware at some point that he
was actually was hired by Mr. Epstein to represent
him after leaving the U.S. Attorney's Office?
MR. CRITTON: Form.
THE WITNESS: I think -- I know that I
recall knowing that a former U.S. Attorney or
several former U.S. Attorneys were retained by
Mr. Epstein, but I don't specifically recall he
being one of them.
BY MR. KUVIN:
Q Do you recall whether or not Mr. Reinhart
was involved in the investigation from the federal
level?
A I wouldn't know as far as the U.S.
Attorney's Office goes. I think I spoke to -- I did
not speak to him relative to this investigation.
There were several others but I don't believe he was
one that I talked with.
Q Did you get the impression at any point
that Mr. Epstein was trying to somehow control the
information that was being discovered about him,
either directly or who he was hiring or who was
involved in the investigation, or anything like
that?

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or not, I agree with you, but I'd like to understand
what the rumor is you heard so that I can
investigate it. What is it?
MR. CRITTON: Form.
THE WITNESS: That one of the Assistant
U.S. Attorneys, the managing Assistant U.S.
Attorney in this office, at least I was told,
is employed by a law firm that either has a
relationship or is assisting with this case
from Mr. Epstein's side. And, you know, if I
thought for a second I would remember his name
if that's important to you.
BY MR. KUVIN:
Q Okay. During the investigation at all,
did you generate any internal memoranda or e-mails
other than the formal reports? In other words, did
you e-mail anyone at the U.S Attorney's Office or at
the Assistant State Attorney's Office or generate
any additional memos to them?
A No.
Q Was there any e-mail communication
regarding this investigation that you can recall?
A People sent me e-mails, you know, because
Chief of the Police dot com was answered by my
assistant, and I had many e-mails from people that

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blamed me for the lack of the state prosecution or a
variety of different things, or you protect the Palm
Beachers or so on. And, you know, I never responded
to any them. I mean I had those at some point.
But, no, did I use that as a way to communicate -this is the question you asked me?
Q Yes.
A The U.S. Attorney or the State Attorney's
Office, no.
Q Those e-mails though, that you may have
received on your official e-mail address, are those
kept? And if they're kept, who keeps them and how
can we obtain them if we wanted to see them; in
other words, at the time you were there?
A There would be a retention period that I
would imagine is expired and they would be kept in
an electric format. And they're probably erased
once the state organization that, you know, they can
put out a guideline of how long you have to keep
those things and they routinely destroy them after
that. And I would think that we're beyond that time
period, that -Q Okay.
A I think that retention period's probably
only a year or two.

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that's the extent of probably two or three different
conversations.
Q When you learned that he was going to be
let out early on work release, what was your
response to that?
A My response to him?
Q When you learned that he was going to be
let out on work release, what was your response?
A I was surprised.
Q Why?
A Well the crimes that were eventually
charged and part of the plea and the short period of
incarceration and the fact that that was done in the
county jail rather than the state system, which
would have been typical, you know. Work release is
something that generally takes a while to earn your
way up to, at least as an observer, not the person
responsible for that. And I thought that it was a
little surprising giving the circumstances that he
would be given a work release.
MR. CRITTON: Let me just strike this,
speculation, his last answer based on what he
said.
BY MR. KUVIN:
Q Do you think that Mr. Epstein in your

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Q When you were there, who was in charge of
trying to obtain that information if a request came
in for it?
A The custodian of records in the police
department would accept those sorts of -Q At the time you were there?
A Well, Laura Oregero, O-R-E-G-E-R-O.
Q Do you know if she's still there?
A I believe she is.
Q At any point, did you have any
conversations with Rick Bradshaw or anyone in his
staff concerning the treatment that Mr. Epstein was
receiving in jail?
A Yes.
Q Tell me about those?
A I interacted with the sheriff sometimes on
a daily basis. We served on boards together and a
variety of different things. And as part of some
other meeting at one point he did mention to me hey,
you know, we're going to have to let Mr. Epstein out
on work release at some point. That was a
conversation.
I think another time I said something
like, asked him a question, you know, what kind of
inmate is Mr. Epstein, and he said model. I think

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opinion and in your experience in working as a
police officer and ultimately Chief of Police for as
many years as you did, do you think that Mr. Epstein
got preferential treatment because he was wealthy -MR. CRITTON: Form.
BY MR. KUVIN:
Q -- with respect to both his prosecution
and his ultimate conviction and sentence that he
served?
MR. CRITTON: Form.
THE WITNESS: The question is, do I think
that he got preferential treatment because he
is wealthy. I can't speculate why he was
treated the way that he was, that wasn't my
decision.
BY MR. KUVIN:
Q Do you think that he got preferential
treatment nonetheless?
MR. CRITTON: Form.
BY MR. KUVIN:
Q Based on your experience?
A Yes.
Q And I understand you don't want to
speculate why he got preferential treatment, but do
you have any ideas why?

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MR. CRITTON: Form.
THE WITNESS: That's not my role as Police
Chief.
BY MR. KUVIN:
Q How did you ultimately learn what was
going to happen with respect to the federal
investigation; who told you that for the first time?
A Well it changed so many different times.
The final outcome when it had been agreed upon,
Assistant U.S. Attorney Marie Villafana shared with
me in a general sense that there was a
non-prosecution agreement and told me what
Mr. Epstein would plea to in state court, and just
in a very general sense.
Q What were your thoughts about what
occurred with respect to the federal investigation?
MR. CRITTON: Form.
BY MR. KUVIN:
Q In other words, did you respond to her and
tell her what you were thinking?
MR. CRITTON: Form.
THE WITNESS: I had been telling her what
my thoughts were about the investigation and
the prosecution all along. I don't think when
she told me what was going to happen -- did I

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that you should not answer that question.
BY MR. KUVIN:
Q I certainly don't think once your
investigation is closed that there's any problem
with having the discussion if it's a closed
investigation, which it is now.
Well let me ask that. Is your
investigation closed with respect to Mr. Epstein?
A I'm retired. So as far as I know when I
left it was a closed investigation, yes.
Q Okay. So when you left, the investigation
with respect to Mr. Epstein was closed?
A Yes. I don't know if the federal
investigation is closed.
Q Fair enough.
You didn't though learn of any new
investigation with respect to the Town of Palm
Beach's duties after you left, did you?
A No.
Q So as far as you know, as you sit here
today, the Town of Palm Beach's investigation is
over as far as you know?
A Yes.
MR. KUVIN: Then at that point, once the
investigation's closed, I certainly don't see

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make a comment about it?
BY MR. KUVIN:
Q Yes.
A If that's what your question is, yes. All
along my concern was that he would be classified as
a sexual offender and all of the provisions that
travel along with that so there wouldn't be
opportunity, or be far less opportunity, for
additional victims to take place. And I think I
shared with her some sense of relief that that was a
part of the plea. Beyond that, there really wasn't
a need to say anything else.
Q Did you discuss with her the fact that the
feds were not going to prosecute; in other words,
the federal government weren't going to prosecute
the case?
A You know, I guess I have to sort of pose
this question that this is part of the, I suppose,
the work product of the U.S. Attorney's Office. Is
this the kind of thing that I should be talking
about? I mean is this privileged from the federal
end for me to talk about the conversations I had
with the United States Attorney?
MR. RANDOLPH: I think if you have any
discomfort at all in regard to whether it is,

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that there's any privilege with respect to
those communications that he may have had on a
closed investigation.
MR. RANDOLPH: He's not stating a concern
in regard to the closed investigation of the
town, he's stating his concern in regard to a
federal investigation and stated he does not
know whether there's any ongoing investigation
in that regard, I believe, and he has concerns
revealing that.
BY MR. KUVIN:
Q Well with respect to your communications
with the U.S. Attorney's Office regarding your now
closed investigation, do you recall discussing with
them the non-prosecution agreement, let's just start
there? Generally, did you discuss that with them?
A Yes, I discussed that with them. And it's
different iterations as it went along. They shared
some portion of the information. I still today have
not seen the non-prosecution agreement but they
shared some of the provisions with me.
Q Okay. Based upon what was shared with
you, did you at any point discuss your
dissatisfaction with that agreement in any regard?
A Yes.

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Q Why?
A Well I had been told by the U.S.
Attorney's Office that typically these kinds of
cases with one victim would end up in a ten-year
sentence. And they told me early on that they had,
I guess in earlier iterations of agreement, tried to
get some sort of a fund set up which I understand
there are provisions for in federal law to
compensate the victims. And I think I remember
asking that when they told me that the agreement had
been signed, and I think it was changed a time or
two and they told me that that was not a part of it.
Because I always felt that this case,
it was all about the victim, that's reason to do
this. And I did -- I think they told me that this
fund had not been a part of the final version and I
told them that I was disappointed in that. But they
didn't really give me the details of it, they gave
me an overall explanation and they said it was going
to be sealed.
And I understand it's been unsealed
but I haven't -- I haven't read it. Along the way I
gave general comment when they would inform me about
parts of it. Because they asked for my input, I
would give them general comment about the parts of

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any?
A No.
Q At some point you sent a letter to State
Attorney Barry Krischer. Let me show you what we'll
mark as Exhibit 3. Let me give you a chance to just
read through this letter again to help refresh your
recollection.
A I've read it.
Q At this point, in May of 2006, I'm
assuming based on what you told us before, that you
had had some conversations with Barry Krischer
directly at this point by phone, correct, prior to
this letter?
A I had conversations in person and by
phone.
Q Okay. But nonetheless in May, May 1,
2006, you felt the need to write this letter; is
that correct?
A Yes.
Q Can you tell us why?
A Well I felt the handling and just
continued to feel that the way the State Attorney's
Office handled this case was extremely unusual. I
felt that Mr. Krischer's -- I knew that Mr. Krischer
was making decisions about this case. I felt that

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it that were important to me. And the part that was
important to me is the classification as a sexual
offender.
Q Okay. Did you, at any time, learn why
they entered into a non-prosecution agreement as
opposed to prosecuting the forty some odd cases?
MR. CRITTON: Form.
THE WITNESS: No.
BY MR. KUVIN:
Q Never gave you an explanation on that?
A No.
Q You know the name Ken Starr?
A Yes.
Q Did you learn that name with respect to
this investigation at all?
A From the news media. And I think maybe
the U.S. Attorney's Office mentioned to me that he
either represents or did represent Mr. Epstein.
Q Do you know what discussions were had with
Ken Starr regarding the federal investigation at
all; did you ever become aware of that?
A No.
Q Do you know what influence Mr. Starr may
have exerted on the U.S. Attorney's Office and the
DC Office at all regarding this investigation, if

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his objectivity was lacking, and I felt that the
appropriate way after reading the statute that
governed the assignment of cases to other circuits,
I felt that his action met the standard. I used
some of the words from the statute in here. And I
attempted to call him and he wouldn't return my
phone calls.
The detective attempted to contact -his contact in the State Attorney's Office, Lanna
Belohlavek, however you pronounce that, I apologize
if I have it wrong, and she wouldn't return his
calls. So I wrote the letter in hope that he would
think about his situation and realize that his
objectivity was insufficient to prosecute the case
and ask the governor to appoint someone else. And I
felt like that was necessary for a fair prosecution
of our case that we submitted to him.
Q Could you tell us, explain to us, why you
felt that his objectivity may be lacking in regards
to this prosecution?
MR. CRITTON: Form.
BY MR. KUVIN:
Q In other words, what evidence did you see
here uncover that you felt made it potentially
non-objective?

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MR. CRITTON: Form.
THE WITNESS: Well, early on I had -- when
I first told him about the case and I realized
that it was a serious case, there were multiple
victims, that the suspect was very well known,
I told him about it. And we were -- it was in
person, I talked to him after a meeting that he
and I were both involved in. And I had known
him to be a victim advocate and to protect the
rights of children. Well I know that he even
wrote a portion of the statute that addresses
those issues. And when I told him about it
originally he said let's go for it, this is an
adult male in his fifties who's had sexual
contact with children of the ages of the
victims. He said this is somebody who we have
to stop. And whatever we need, he said, in the
State Attorney's Office, we have a unit that's
equipped to investigate and prosecute these
kinds of cases. I think he probably mentioned
Lanna's name to me and anything that you need
and, you know, this is basically a case that
needs to be prosecuted.
And I didn't have too many facts early on
when I talked with him, but I knew that there

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directly?
MR. CRITTON: Form.
THE WITNESS: He told me that he had
conversations with Mr. Dershowitz. I know Roy
Black. At least the news media reporter was
involved in this and I think that he said that
he had a conversation with him. I think Roy
Black had another case with that circuit around
the same time and maybe even other lawyers that
represented Mr. Epstein, and they were
obviously discussing the case. And he
basically told me that he looked at Facebook
pages of some of the victims and that he felt
like they were incredible.
And I have never felt like prosecutions,
evidence should be weighed outside of the
judicial process. I just don't -- we wouldn't
cover our ears and eyes when a person under
investigation's lawyer would bring forward
exculpatory evidence, but on the other hand
we're not the weigher of fact in these things.
We reach the standard of probable cause and
beyond, and that's when a judge, or in this
particular case a State Attorney, should make
those decisions.

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were multiple victims and to our detectives
they were believable. So when time went on and
Mr. Epstein became aware of the investigation
and his lawyers contacted the State Attorney's
Office, they told me that.
And from that point on, and I believe it
was Mr. Dershowitz initially, the tone and
tenor of the discussions of this case with
Mr. Krischer changed completely. One point he
suggested that we write him a notice to appear
which would be for a misdemeanor. He just
completely changed from not only our first
conversation about this and he didn't know the
name Jeffrey Epstein, till when he had been
informed on Mr. Epstein's reputation and his
wealth, and I just thought that very unusual.
I feel like I know him or knew him very
well, the State Attorney, and I just felt like
he could not objectively make decisions about
this case; that is why I wrote it.
BY MR. KUVIN:
Q Was there anything that you learned
through discussions with him that led you to believe
maybe his objectivity had been altered in some
regards; in other words, anything he told you

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And he had been meeting with them without
the presence of our investigators. I don't
mean he personally but at least -- probably he
personally but definitely members of his
office, and he hadn't been sharing that
information with us.
He hadn't, you know -- he characterized it
with me but he didn't show us the things, at
least not exhaustively, that had been given to
him by Mr. Epstein's attorneys. I just felt
like that was wrong. Those are the reasons.
BY MR. KUVIN:
Q Have we exhausted the reasons why you felt
that this case, at least you put in your letter,
was the handling of this case was highly unusual?
Was there anything else that you felt was highly
unusual regarding the investigation?
A Well the Dahlia Weiss being involved in
this case with her husband as a lawyer for -- I'm
not saying that anything happened there, but there's
certainly an appearance of impropriety. I felt like
that alone should have been reason enough. First of
all for her to be disqualified as soon as she became
aware that a law firm that -- not disqualified but
removed from the case as soon as she became aware

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that her husband's law firm had represented Mr.
Epstein. And maybe even done damage to the point
that because that happened it should be handled by
another circuit.
This was a case that I felt
absolutely needed the attention of the State
Attorney's Office, that needed to be prosecuted in
state court. It's not generally something that's
prosecuted in a federal court. And I knew that it
didn't really matter what the facts were in this
case, it was pretty clear to me that Mr. Krischer
did not want to prosecute this case.
Q Did he, in fact, make that clear to you at
some point verbally?
A Not in those exact words. But the
suggestion that multiple victims and some of the
crimes, felonies, that he should write a notice to
appear for a misdemeanor and the scheduling of a
grand jury on an issue like this is extremely rare.
The fact that he and I had an
excellent relationship. I was the speaker at his
swearing in ceremony. And that he wouldn't return
my phone calls, I mean it was clear to me by his
actions that he could not objectively look at this
case.

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record at 1:44. This is the beginning of tape
3.
BY MR. KUVIN:
Q Okay. When we left off we were talking
about Barry Krischer's office. And before I move on
from that subject I just have one other question.
Are you aware of any contact that was
made with Mr. Krischer's office from anyone in the
democratic party or the DNC at all?
MR. CRITTON: Form.
THE WITNESS: Relative to this case?
BY MR. KUVIN:
Q Yes, relative to the Epstein case?
A No.
Q Are all of the officers that were involved
in the investigation listed or contained within the
incident report that we've marked as Exhibit 2, and
were there any additional officers that were
involved that may not be listed in there?
A Typically and generally when you say
involved, I mean that could encompass all sorts of
different people. It might be -- I don't even know
that this was the case but it might ask the patrol
officer in the area to collect license tags from a
street or something like that. I mean if they

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Q At some point, did you feel, or did you
become aware, that maybe he had been threatened in
some regard, either regarding his job or personally
in any regard?
A No.
MR. CRITTON: Form.
BY MR. KUVIN:
Q You're aware that obviously his position
is an elected position?
A I am aware.
Q Did you know whether or not he had had any
discussions with anyone about his political career
if this case did not go a certain way; did you ever
become aware of that in any regard?
MR. CRITTON: Form.
THE WITNESS: No. He had already publicly
announced he wasn't running for re-election.
MR. KUVIN: All right. This is actually a
good stopping point for a quick lunch if you
want to take a quick one, I just have to eat.
I'm hopefully not far from concluding.
THE VIDEOGRAPHER: We're off the record at
12:35. This is the end of tape 2.
(Recess)
THE VIDEOGRAPHER: We're back on the

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aren't writing a report and they aren't doing
something that's probably important later on as a
witness, they might not appear in there. But the
detectives who conducted the investigation are
listed in there from what I recall the last time I
read it, and it's been a while, but as far as I
know.
Q At any point, did you have to remove for
any reason anyone in your department from the
investigation for any reason?
A No. It took place over a fairly long
period of time so people were transferred and so on,
but I didn't personally remove someone for any
reason.
Q And it may not have been you personally,
but just to make sure that it encompasses all
potential iterations of that question, was anyone
removed for any reason other than just someone
transferring out?
A Do you mean for -- I think you have to
explain that.
Q Were any of the investigating police
officers removed for any potential conflicts,
refusal to follow direction, any reason, other than
just a transfer out of the department for some

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reason?
A No.
Q At any point, did your department come to
any conclusions about how long this conduct outlined
in Exhibit Number 2 had been going on; in other
words, how far back?
A Well, no.
MR. CRITTON: Form.
THE WITNESS: All that we knew was the
incidents that had been reported to us or that
we learned about -- we'd learn about one victim
from another victim, but I don't think that we
could really know whether or not it occurred
for any time period prior to the first incident
that was reported to us.
BY MR. KUVIN:
Q Well once you started getting additional
girls coming forward or you learned of additional
girls, did you find out of incidents, find any
incidents that had occurred further back than the
initial incident reporting?
MR. CRITTON: Form.
BY MR. KUVIN:
Q Do you understand what I'm asking?
A Yes. There were instances of the very

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some of the cases. I don't know if it extended
into 2004, probably. How far I don't know.
BY MR. KUVIN:
Q Okay.
A Or before for that matter.
Q During the course of the investigation,
did you become aware or have any knowledge of
Mr. Epstein transporting any underage girls on his
airplanes?
A I recall one of the detectives writing a
report that reflected a victim saying that she had
travelled on an airplane, yes.
Q Do you recall who that victim was?
A No.
Q Did you learn that victim was allegedly
under the age of eighteen?
MR. CRITTON: Form.
BY MR. KUVIN:
Q In other words, was it a minor that he was
transporting or was it someone over the age of
eighteen?
A That's something that the FBI would have
investigated. Yeah, I think I remember -- I
remembered them, the FBI, telling us that they had
evidence from flight logs or something that a minor

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first victim that came forward with her parent.
There were incidents that occurred prior to that
time that were reported after the first victim
reported her case to us.
Q Right. And the first victim comes to you
in your department on March 14 of 2005 through a
phone call initially, according to the report, about
an incident that allegedly occurred to her going
back, and it appears on page 2 of the incident
report, to February 9 of 2005.
My question is, as the additional
potential victims came forward, how far back did you
learn of incidents, potential incidents occurring?
A I don't recall. It's probably -- I didn't
learn that directly. It's probably included in the
report, but I don't recall.
Q Would you say you learned of incidents at
least as far back as 2004?
MR. CRITTON: Form.
THE WITNESS: Well, the only reason that I
remember anything about this at some point
there was a calculation of statute of
limitations. And while the investigation was
going on we came close to, you know, bumping up
against that expiring, and eventually it did on

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that was one of the victims, or maybe even more than
one, I don't remember, that was transported on an
aircraft of Mr. Epstein.
Q Did you ever see any of that evidence
though?
A No.
Q Did you all, when you turned over all the
information you had to the FBI, did you all keep
copies of anything?
A I don't remember. I do remember there was
discussion about that but I don't remember the
outcome. Copies as in things that would be easily
copied, you mean photographed or photocopied or so
on?
Q Yeah. I mean like -A Yeah. I think we did, the department did
on some things, because we were still conducting an
investigation, pieces of paper that we thought might
be important moving forward. Might not have
realized the significance at the point that we
turned it over. I didn't keep any of that and I
don't think I ever saw any of that except maybe
later on when it appeared in a news media. I'm not
the right person to ask that question.
Q If any copies of evidence were kept, who

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would have been the person at the department back
then that would have been in control of that
information, would it have been Ms. Laura Oregero?
A Oregero, probably technically, but it
would have probably been in the physical control of
the special investigation's unit, Detective Recarey.
We wouldn't have treated it like a document like a
report and put it into our normal system.
Q And what I'm curious about is information
that would have been easily copied; for example,
phone logs, phone message pads, printouts from the
computer, laser copies of any photographs or
pictures that may have been on the walls, anything
like that that you can recall keeping?
A I don't know. At the point that we passed
all this over, we knew that our investigation was
winding down.
Q Okay. You definitely turned over the
computers though that you did have?
A I don't know in specificity, I never saw a
list of items. But I know that when I received the
grand jury subpoena from the U.S. Attorney, I passed
it on to our evidence custodian and said they want
everything, give them everything.
Q At any point, did you ever become aware of

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St. Thomas, New Mexico, Manhattan. Whether or
not the discussion was specific to where these
acts may have taken place amongst them, I don't
remember that.
BY MR. KUVIN:
Q I noticed in the investigation in Exhibit
2 that some of the interviews were taped. Did you
all keep those tapes or did you give those over to
the FBI as part of the grand jury subpoena?
A Well I know that I instructed, when I
instructed our evidence custodian to give them
everything, I intended -- I meant -- I mean I didn't
personally go there and inspect but I was told that
everything we had, which would have included that,
was given to the FBI.
Q Do you know if you all kept any copies of
any of the tapes or interviews?
A I don't know.
Q Do you know if you all kept any
transcriptions of those interviews?
A I don't think -- I don't remember ever
having them transcribed. I know at one point the
State Attorney's Office wanted to know the content
of the interviews. And I can't remember whether or
not we made copies and gave them tapes or what

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a gentleman by the name of Bill Richardson, former
governor?
A Only from news media.
Q That name never came up with respect to
this case that you can recall?
A Not that I know.
Q Did you learn of any information regarding
Mr. Epstein engaging in any acts with minors, any
illegal, potential illegal acts with minors, either
in New York or in New Mexico at his homes there?
MR. CRITTON: Form.
THE WITNESS: I know that either the FBI
or the U.S. Attorney either told me or told the
detective who told me that they were
investigating allegations of that, of illegal
acts with minors outside of Florida. Don't
remember exactly where or whether or not they
ever told us that they were able to confirm
that.
BY MR. KUVIN:
Q Did you ever hear any information in
particular about acts that may have occurred in
St. Thomas at his home there?
MR. CRITTON: Form.
THE WITNESS: I recall mention of

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happened there, but in mass they were not
transcribed by us.
Q Did you ever come to learn that at any
point during the investigation that Mr. Epstein had
a massage schedule that was contained on one of his
computers?
MR. CRITTON: Form.
THE WITNESS: No.
BY MR. KUVIN:
Q Never learned anything about that?
A I don't remember that. And my role is not
to know the nuances of the investigation.
Q Just asking what you may know. If you
don't know then I don't know is sufficient.
With respect to the search warrant
that was issued by your department, did you ever
come to learn any information that might have led
you to believe that Mr. Epstein had been tipped off
with respect to that search warrant prior to the
warrant being executed?
A I know that the detectives who executed it
believed that that was a possibility.
Q Do you know how they -- do you know why
they might have believed that, what evidence they
may have had?

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MR. CRITTON: Form.
THE WITNESS: Well they told me it was by
the condition of the house, by the condition of
the place to be searched, they thought that
someone had probably cleaned it up a bit. But
it was -- really that's a question you should
ask them.
BY MR. KUVIN:
Q Okay. Did you advise the State Attorney's
Office ahead of time that a search warrant was going
to be executed?
A Well we didn't have to, because the system
is that the application to the judge first has to be
approved by the State Attorney's Office, and they
did, so they were aware of it and party to it.
Q So the process, and excuse me because I
don't know criminal procedure at all, the process by
which the application would go is that you all, your
department, somebody in the department would fill
out the application. It would then go to the State
Attorney's Office; is that correct?
A Yes. And then usually it would go to the
on-call judge, which I don't remember who signed the
search warrant. And often, I don't know what
happened in this case, but often it would be the

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Q Did you ever see any -- well let me ask
this. Did you ever interview or talk to directly
any of the potential victims?
A No. The only thing I did is that might be
responsive to your question was write their parents
a letter. I don't remember whether I wrote them and
their parents or just their parents. Was the only
communication.
Q At any time, did your department ever
investigate whether or not Mr. Epstein might
actually have some type of psychosexual disorder?
In other words, was there any investigation by your
department as to his psyche?
MR. CRITTON: Form.
THE WITNESS: No.
BY MR. KUVIN:
Q And I ask that because sometimes in cases
as a defense to a case there's a psychology
component with respect to criminal defendants.
You're aware of that, right, sometimes?
A Yes. And that's not typically the role of
law enforcement. No, we didn't.
Q You never retained a psychologist or had
anybody -A A profiler or anything, no.

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Assistant State Attorney and the detective that go
see the judge together, particularly in a case like
this.
Q Do you know whether or not Dahlia Weiss
was involved in that process?
A I don't know.
Q Did you ever have a chance to review any
of the physical evidence in the case that might link
Mr. Epstein to crimes against underage minors?
MR. CRITTON: Form.
THE WITNESS: No.
BY MR. KUVIN:
Q In other words, did you look at any of
the, and I apologize for the terms but, you know,
some of the things that were confiscated involving
sexual toys, massage oils, different things like
that; did you ever review any of the evidence like
that in the case?
A No.
MR. CRITTON: Form.
BY MR. KUVIN:
Q Did you ever see any videos that may have
been kept on his computers, or photographs in the
house or photos on the computers?
A No.

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Q Okay. Did you find anything in your
investigation with respect to -- find out anything
with respect to Mr. Epstein's psychosexual potential
disorders or psychological disorders? In other
words, did the State Attorney's Office share
anything with you; U.S. Attorney's, FBI?
MR. CRITTON: Form.
THE WITNESS: Well I think the State
Attorney in our conversations at some point
said the guy probably has a problem, that's the
extent of it. And I don't think that's
probably a psychological -- beyond that the
answer would be no.
BY MR. KUVIN:
Q Fair enough. I'm just wondering whether
any professional had ever assisted the State
Attorney's Office or U.S. Attorney's Office or FBI
that you're aware of?
A Not that I'm aware of.
Q You're aware of the name Sarah Kellen, a
probable cause warrant was issued for her?
A An application for a capias or arrest
warrant was transmitted to the State Attorney's
Office by our department for her, yes.
Q What information did you learn with

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respect to her as part of the investigation? In
other words, what part did she play as far as you
learned?
A Well I learned nothing first hand. The
detectives told me that she had acted in some
capacity to secure the victims for massages for
Mr. Epstein.
Q What about Ghislaine Maxwell, are you
aware of that name?
A I am aware of that name.
Q How did you become aware of that name and
what did you learn about her?
A I knew from news media reports that
Mr. Epstein and she were friends. I think the name
popped up a couple of times in the investigation,
but many names did but I don't ever remember. And
it could be the case because I don't have the entire
case committed to memory, I don't really remember
any connection to specific acts of the crime
involving her.
Q Okay. And what about Nadia Marcinkova,
does that name sound similar, and if so, what did
you learn about her?
A Well we believed that she was an actual
participant in some of the cases, I remember that.

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somebody telling me in the outside of the
investigation that it had, but I don't remember it
from the case.
Q Did you ever discuss his name with the FBI
at all in connection to a separate investigation
regarding allegations of rape with respect to Mr.
Copperfield?
A No.
Q All right. With respect to the victims
that were investigated by your department, can you
explain whether or not they all had a similar story
to tell with respect to how the incidents had
occurred at Mr. Epstein's home?
First of all, were their stories
similar, and if so, how were they familiar?
MR. CRITTON: Form.
THE WITNESS: Well they were similar in
that they heard about Mr. Epstein, most of
them, if not all of them that were considered
by the Palm Beach Police Department, through
another person, either another victim or
another person who had gone there to get a
massage, massages. Was sort of invited to come
to the home for some sort of work. I think I
remember one person it was suggested that she

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Q When you say participant, can you explain
further what you mean?
A I recall her name being brought up with
having some -- and I think that it's in the probable
cause affidavit request for the capias -- of having
some sexual contact with some of the victims, or at
least one of the victims.
Q Okay. What about Adriana Mucinska?
A Don't recognize the name.
Q Leslie Gross (phonetic)?
A I think I may have heard the name in
connection to this case, but I'm not sure.
Q No specific information that you can
recall about her though?
A No.
Q With respect to your job, did this
investigation have anything to do with you leaving
your post as Police Chief?
A No. If anything it kept me there a little
longer.
Q You're aware of illusionist magician David
Copperfield. Did that name ever come up during the
investigation, either phone logs or message pads
that you can recall?
A Not that I can recall. I remember

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answer the telephone. Others were told you
give a guy a massage, there's nothing strange
about it. And when they got there there was
typically some increasing level of contact
between Mr. Epstein and the victim. And that
really is the part -- those are the parts that
are common on all of the ones as far as I can
best recall from those we considered as
victims. And they were paid something.
BY MR. KUVIN:
Q As far as those girls that you all
considered as victims during the investigation, you
agree with me that they all were asked to come to
the home and either perform a massage or some sort
of work for Mr. Epstein?
MR. CRITTON: Form, speculation.
BY MR. KUVIN:
Q As far as you know?
MR. CRITTON: Same objection. Said he
didn't know anything.
THE WITNESS: Again, that is true, I
learned all of this third hand. But can I say
all of them absolutely, no, I can't. That's my
general recollection from most of the victims
that we investigated their allegations.

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BY MR. KUVIN:
Q Let's not use the word all because I don't
want you to be uncomfortable with that term all.
Would you agree with me that most of
the victims were asked to come to the home and give
massages based on what you learned during the
investigation?
MR. CRITTON: Same objection, speculation.
BY MR. KUVIN:
Q You can answer.
A That was the general set of circumstances
that were reported to us.
Q And most of them were asked to come and
give that massage and ultimately were paid money as
a result?
MR. CRITTON: Form.
THE WITNESS: Yes.
BY MR. KUVIN:
Q Most, once again?
A Well they reported to us that they were
paid money, yes.
Q And do you recall whether most of them
were paid somewhere in the neighborhood between 200
to $400 for their services?
A That's my rough recollection, yes.

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MR. CRITTON: Form.
THE WITNESS: Most. Remember, we were
only interested in victims those being under
age eighteen. Others who were over age
eighteen came to our attention, so I can't tell
you whether more than half of all the
individuals who came to our attention were
under age eighteen.
BY MR. KUVIN:
Q Okay. And that most of the girls were
asked to come upstairs and give a massage to
Mr. Epstein when he was either nude or just had a
towel over his private parts?
MR. CRITTON: Form.
THE WITNESS: Yes.
BY MR. KUVIN:
Q And that most of these girls reported to
your department that he pleasured himself during
those massages?
MR. CRITTON: Form.
BY MR. KUVIN:
Q Sexually gratified himself during the
massages?
A Yes.
Q And that most of these girls -- did most

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Q Do you recall whether or not during the
investigation that most of them were taken in
through a side door entrance, a kitchen door, and
met in the kitchen area?
MR. CRITTON: Form.
THE WITNESS: I don't recall how they
entered.
BY MR. KUVIN:
Q Do you recall whether most of them were
asked to come upstairs to a special room that was
being used for massages?
MR. CRITTON: Form.
THE WITNESS: Yes, I do recall that from
the report.
BY MR. KUVIN:
Q Do you recall whether or not during your
investigation that most of them were met at the home
by Sarah Kellen?
MR. CRITTON: Form.
THE WITNESS: Her name was frequently
mentioned by the victims as the one that met
them, yes.
BY MR. KUVIN:
Q And that most of these girls were between
the ages of fourteen and seventeen?

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of these girls report during the investigation that
they were asked to either get fully undressed or at
least partially unclothed?
MR. CRITTON: Form.
THE WITNESS: Yes.
BY MR. KUVIN:
Q And that most of these girls -- did most
of these girls report to your department that at
some point Mr. Epstein would try to touch them in
some manner?
MR. CRITTON: Form.
THE WITNESS: I can't say for sure if that
was more than half, but some did.
BY MR. KUVIN:
Q And some of these girls reported that
Mr. Epstein would actually digitally penetrate them
in their vaginas during the massage?
A That's correct.
Q And some of those girls that were involved
in that incident were -- the ones that you learned
of through the investigation were under the age of
eighteen?
MR. CRITTON: Form.
THE WITNESS: That's correct.

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BY MR. KUVIN:
Q And that some of these girls actually were
asked to have sex with Mr. Epstein?
MR. CRITTON: Form.
THE WITNESS: That's correct.
BY MR. KUVIN:
Q At least one of them; is that correct?
MR. CRITTON: Form.
THE WITNESS: Yes.
BY MR. KUVIN:
Q And one you learned of that actually had
sex with Mr. Epstein was under age eighteen?
A Yes.
MR. CRITTON: Form.
BY MR. KUVIN:
Q Did you also learn that some of these
girls that were asked to give massages to
Mr. Epstein he actually used vibrators on during the
massage?
MR. CRITTON: Form.
THE WITNESS: I learned that once again
from the detectives in the report, yes.
BY MR. KUVIN:
Q Mr. Elwell, I'm sorry, who is he again?
A He's the Town Manager.

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BY MR. KUVIN:
Q Okay. I meant to mark these before but -at some point you learned the location of
Mr. Epstein's home, correct?
A Yes.
Q And that location was 358 El Brillo Way on
Palm Beach Island?
A If that's what the report says. I know it
was on El Brillo, but I don't recall the exact
address.
Q You know the island generally?
A Yes.
Q I'm sure you've driven around it many
times?
A For twenty-eight plus years.
Q Figured. Let me show you three separate
images, each one getting a little closer, and ask
you if you can identify this as Mr. Epstein's home
on El Brillo Way. First one's a wide shot and then
it gets closer.
MR. CRITTON: Are you marking this as an
exhibit?
MR. KUVIN: Oh, yeah, 4.
THE WITNESS: I can't say for sure that
that's his home. I've driven by it a couple of

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Q Did Mr. Elwell ever discuss with you that
people came to him and lobbied him to try and give
Mr. Epstein favorable treatment; in other words,
that he was actually fielding complaints or people
were coming to him about it?
A We had a number of conversations. Early
on, when this broke in the news media, a number of
people sort of stepped away from me. Some of those
people shared with Peter Elwell the concern that
maybe that we had pursued this at a level that
wasn't necessary. And that was some people's talk,
both, yes.
Q Do you feel today, as you sit here today
after everything that went on looking back on it,
that you pursued this in a manner that was
unnecessary in any way?
MR. CRITTON: Form.
THE WITNESS: No.
BY MR. KUVIN:
Q As you sit here today, do you feel that
you or your department did anything improper with
respect to the investigation?
MR. CRITTON: Form.
THE WITNESS: No.

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times, seen it in the news media, but from an
aerial photograph -BY MR. KUVIN:
Q It's on the water facing west; you were
aware of that?
A That would be El Brillo.
Q It's at the end of the road?
A It's at the end. That would fit.
Q Did you ever go out to the home and see
whether or not -- well, did you ever go out to the
home at any point -A No.
Q -- during the investigation process at
all?
A Not ever. I could have been there many,
many years ago on a call when I was a young police
officer, but nothing to do with this case.
Q Okay, fair enough.
Do you -- let's see, I think this one
is 5 -- recognize this photo as the exterior of
Mr. Epstein's home? Does this help refresh your
recollection at all?
A This is a picture that was in the news
media.
Q Do you have any independent knowledge

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regarding that being the exterior of Mr. Epstein's
home, if you know?
A I think it is.
Q Okay. I don't want you to guess. If you
know, you know, if you don't, you don't.
A I don't know absolutely definitively, no.
Q Did you become aware during the course of
the investigation that Mr. Epstein was actually
conducting some type of construction on his home?
Do you recall that?
A Yes, I think I remember the detectives
mentioning that. Not at the beginning of the
investigation but once it was under way at some
point.
Q At some point, do you recall learning what
type of construction was going on; in other words,
whether it was exterior construction or construction
to the inside of the home?
A I can see in the photographs that the
driveway is covered. I think I remember from some
of the neighbors who are acquaintances of mine
mentioning that there was all sorts of activity,
that it was a larger scale rather than a smaller
scale construction.
Q Do you know whether or not the

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the fourth line down?
A It's very hard to make out, but I see
there are some numbers. It looks like 12/30,
probably '86 or '80 something, yes.
Q And the date of this report would have
been November 28 of 2004, correct, we already went
through that?
A That's what it said.
Q That would make her approximately -- would
make her seventeen years old, would it not?
A If those numbers are accurate, yes.
Q Why is her name blacked out, if you know?
A Well she was a juvenile at the time that
the report -- only by a month apparently at the time
the report was taken.
Q Would you agree with me that the
investigating officer obtained information in this
interview that there was some type of potential
sexual contact going on between this underage
juvenile and Mr. Epstein?
MR. CRITTON: Form.
BY MR. KUVIN:
Q If you look at the last three lines in the
report?
MR. CRITTON: Form.

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construction on Mr. Epstein's home started after the
investigation began or he learned of the
investigation?
A I don't know.
Q Do you know whether or not he altered the
interior of his home in order to somehow alter the
investigation in some manner or change the look of
the interior of his home to change the investigation
in any way?
MR. CRITTON: Form.
THE WITNESS: No.
BY MR. KUVIN:
Q No knowledge one way or the other about
that?
A No.
Q During the investigation, did you learn
that Dollar Rent a Car was being used in order to
rent vehicles for some of the girls?
MR. CRITTON: Form.
THE WITNESS: I don't remember that.
BY MR. KUVIN:
Q I forgot to ask this before, but in
looking at Exhibit 1, it appears that the girl in
this particular incident -- hang on, let me find it
here. Date of birth 12/30/86. Do you see that on

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THE WITNESS: Only from my reading it
right now, yes.
BY MR. KUVIN:
Q Do you know what actions, if any, were
taken by Officer Munyan to further investigate this
report?
MR. CRITTON: Form, asked and answered a
couple of times earlier.
THE WITNESS: No. The State Attorney's
Office had an even lesser level of concern for
sixteen and seventeen year olds, had a greater
level of concern for fifteen and younger. In
fact was not inclined to prosecute, even from
the very beginning, any instances that had a
victim who were sixteen or seventeen years old.
I don't know if that played in this decision to
black this out. I didn't do the redaction, I
wouldn't normally do the redaction.
BY MR. KUVIN:
Q Okay. I'm going to ask you about Exhibit
2 for a moment, if you grab that incident report.
See if any of this helps refresh your recollection
regarding stuff you may have learned. If we turn to
page 62 of the report and we go to paragraph five,
starts with a small office, do you see that?

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A Yes.
Q It appears that a phone message book with
recent messages was taken into custody or seized as
evidence. Do you know if you all made copies of
that?
A No.
Q No, you don't know, or no, you didn't?
A I don't know.
Q Do you ever recall seeing that phone
message book?
A No, I don't.
Q If you look at the bottom of this page,
second paragraph up from the bottom starting with
regarding seized evidence, do you see that
paragraph?
A Yes.
Q Says all items were photographed in place
and then collected by CSEU personnel. What happened
to those photographs?
A That would be typical when you execute a
search warrant. When the Palm Beach Police
Department executed a search warrant they would
photograph anything they were going to take before
they would take it. The photographs themselves
generally aren't evidence and I would imagine that

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records?
A No.
Q Do you know whether or not any copies were
made of phone records were kept before anything was
turned over to the FBI?
A I don't even know if we received them.
Normally we would subpoena them, but I don't know
that in fact we did.
Q Okay. At any time during the
investigation, did you become aware that
investigators for Mr. Epstein may have been
harassing potential victims?
MR. CRITTON: Form.
THE WITNESS: I know that from the
detectives that that was reported from victims
to the detectives.
BY MR. KUVIN:
Q What type of harassment did you hear
about?
A I recall that some of the victims had
reported to us that they had been what they thought
was under surveillance. There was private
investigators or individuals who would come to the
door and try to talk to them. The contents of the
discussions I don't remember. I do know that it was

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the department probably has those.
Q Okay. So the department probably has
those photographs?
A I would imagine.
Q And with respect to those photographs,
were they taken on digital cameras; in other words,
did you have that technology at the time or were you
still using a 35 millimeter or something else?
A They would have had an option.
Q Do you know whether a video was taken
during the execution of the warrant, was that
standard practice?
A Is it standard practice?
Q Was it?
A Not really. And I don't know. I'm sure
it's included in here.
Q Okay. On page 66 of the report, turn to
that page, third paragraph down starting with the
sentence while at the police station. Do you see
that paragraph?
A Yes.
Q Second sentence it says I began an
analysis of Sarah Kellen's cellular telephone, the
telephone number is (917) 855-3363. Do you remember
whether your department obtained those phone

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something enough of us -- to make us enough
concerned that we talked to the State Attorney's
Office about it. Because I remember some of it
happened outside of this circuit, victims had gone
elsewhere in the state and so on, and we had
evaluated whether any of it had risen to witness
tampering or something like that. And we -- and we
didn't take any action on it, we didn't file for
warrants or anything like that, but there was
discussion about it. I don't remember the content
of it.
Q All right. And you kind of got to where I
was going with it. Did you all sit down at any time
and write out any information or put down
information to determine whether or not Mr. Epstein
actually -- his conduct had actually risen to the
level of witness tampering?
A We didn't file a request for a capias or
an arrest warrant, if that's what you're asking.
Q Did you all sit down to determine whether
or not it had risen to that level, have a meeting or
discussion about that?
A I didn't personally, but I know that the
detectives talked with the State Attorney's Office
about it and I think probably the FBI.

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Q If we look at the bottom of page 67,
second paragraph down -- sorry, second paragraph
from the bottom, excuse me, it says here letter to
Mr. Dershowitz sent advised he was looking into the
allegation that one of the private investigators
used by the private attorneys of Epstein, attempted
to impersonate or state that they were police
officers from Palm Beach. Do you recall hearing
about that?
A I didn't recall, not till I read this.
Q Okay. Apparently there was a package sent
to both ASA Lanna Belohlavek and ASA Dahlia Weiss at
the State Attorney's Office. Do you see that?
A I see that sentence, yes.
Q Did you see that package that was sent?
A I don't remember that I did. I wouldn't
normally.
Q If we turn to page 73, top of the page it
has the name of a Dr. Perry Bard. Do you see that
in the first paragraph?
A I do.
Q Did you ever come to learn who Dr. Perry
Bard was other than what might be stated in here?
A I read this at one time so I was informed
of it, but I had not recalled the name until I read

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A No.
Q If you turn to page 79, it appears that on
the date of February 16, 2006, there's a meeting
that takes place between the investigator Joseph
Recarey and two women, Joanna Harrison and a
Victoria Bean. Do you see that?
MR. CRITTON: Are we at 79?
MR. KUVIN: Yeah.
THE WITNESS: Yes.
BY MR. KUVIN:
Q Okay. Did you learn any additional
information regarding those two women other than
what might be in here, in the report?
A No, not personally.
Q This may go along with what you discussed
at the beginning with respect to not really
prosecuting what technically would be a criminal act
for prostitution in a home. But it appears from
this information here that these two girls were paid
for sexual contact with Mr. Epstein, at least
according to what Detective Recarey investigated.
Were there any additional
investigations ongoing regarding allegations of
prostitution at the home?
MR. CRITTON: Form.

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it again here.
Q No additional information regarding
Dr. Bard?
A No.
Q And with respect to the next paragraph it
mentions a woman by the name of Johanna Sjoberg,
spelled S-J-O-B-E-R-G. Do you see that?
A I see it, yes.
Q Do you recall anything in particular with
respect to Ms. Sjoberg?
A No.
Q If we turn to page 74 for a moment, there
are, at the bottom of the page, last paragraph, four
separate telephone numbers listed for a Cingular
wireless, one of which is listed to a Janusz,
J-A-N-U-S-Z, Banasiak. Do you know who Janusz
Banasiak is?
A No. Only from what it says here.
Q No additional information though?
A No.
Q Christina Venero at the bottom of the
page, do you see that name?
A I see it.
Q Any additional information that you're
aware of regarding her?

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THE WITNESS: The only way I can answer
that question is I don't consider
fifteen-year-olds, sixteen-year-olds who are
paid money to engage in sexual contact
prostitution, by the legal definition of the
law, for purposes of prosecuting them. I
really don't know what you're getting at beyond
that. I mean that's -- I don't know how else
to answer that.
BY MR. KUVIN:
Q Maybe I phrased it wrong. But these
girls, Ms. Bean and Ms. Harrison, were apparently
over the age of eighteen. These were girls that
were over the age of majority that were apparently
paid for sexual contact with Mr. Epstein.
Were there any ongoing investigations
regarding solicitation for prostitution against
Mr. Epstein regarding girls over the age of
eighteen?
A No. These kinds of situations are not
prosecutable. The State Attorney's Office some
years earlier even suggested that we no longer do
sting operations for prostitution because they
didn't want to prosecute them. This is a case where
you have willing participants after the fact and no

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physical evidence.
No, the resources of the department
are not dedicated for these kind of semi-victimless
crimes in private residences unless it presents some
other problem.
Q Okay. If we turn to page 81, bottom of
the page dated April 10 of 2006. Second to last
paragraph it references -MR. CRITTON: I'm sorry, Spencer, what
page?
MR. KUVIN: 81.
BY MR. KUVIN:
Q Additional subpoenas from the State
Attorney's Office requesting information from Dollar
Rent a Car and Jet Aviation. Do you see that?
A Yes.
Q Do you recall seeing any of the records
that were produced in response to this subpoena to
Dollar Rent a Car or Jet Aviation?
A No.
Q Turn to page 84 if you would. Top of page
84 there's discussion -- and this goes back to the
initial note as begun on April 14, 2006 and actually
begins on page 82 -- regarding grand jury subpoenas
and discussions with the State Attorney's Office.

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offer an opinion on behalf of the department of
whether we think any deal is appropriate, that I
would want to reserve that for myself. So that's
what happened here.
Q Okay. All right.
Do you recall having direct
conversation with Barry Krischer about this
particular deal that's discussed here on pages 83
and 84?
In other words, it looks here on page
83 to be a deal where the offer is one count of
aggravated assault with intent to commit a felony,
five years probation with adjudication withheld,
which was conveyed to Mr. Epstein's attorneys at the
time, Guy Fronstin and Mr. Dershowitz.
A I always told Barry Krischer when we had
conversations about how this would resolve itself
that my biggest concern, really my main concern was
that Mr. Epstein be classified as a sexual offender
to reduce the likelihood that this would continue in
the future. I never formed an opinion or
communicated it to him about how many years of this
or how many years of that, so on, other than to tell
him that I felt like a Notice to Appear was not the
appropriate way to resolve this.

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If we go to page 84 though, it talks
about the quote, unquote, deal being offered to
Mr. Epstein. And if you look at paragraph one here,
in the middle of the paragraph it says however, I
expressed that was only my opinion and that the
final approval would come from the Chief of Police.
She explained to have Chief Reiter call Barry
Krischer about the deal. Do you see that?
A I do.
Q Did Officer Recarey talk to you about the
deal?
A There were so many potential deals, deals
being the plea agreement, that had been suggested, I
don't know which one they're talking about here.
Q Bottom of page 83, if you read the last
paragraph it'll explain it, might help refresh your
recollection.
A Well after reading this it refreshed my
recollection on one of the different proposed
agreements, which -Q Okay.
A -- I guess some of which they asked for
our input. And what this reflects is that in this
particular case with all of its unusual twists and
turns, I told Detective Recarey that he should not

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Q Okay. All right. Bottom of page 84
there's a documented call with Officer Recarey,
Detective Recarey. Says here on May 3rd, 2006 at
approximately 2:54 p.m., I, meaning Detective
Recarey, received a telephone call from ASA Dahlia
Weiss on my cellular telephone. ASA Weiss advised
she has been taken off the Jeffrey Epstein case
because her husband is employed with Attorney Jack
Goldberger. Do you see that?
A Yes.
MR. CRITTON: Is there a date there,
Spencer, of reference?
MR. KUVIN: Yes, May 3rd, 2006.
MR. CRITTON: Thank you.
BY MR. KUVIN:
Q Is that the first time that -- or shortly
after that call that you became aware of the
relationship between ASA Weiss and Mr. Goldberger's
office?
A Like I said earlier, I became aware of the
relationship prior to learning of her being taken
off the case, so I would have known about the
relationship before this day.
Q It appears, and I don't want you to guess,
so all I want to know is whether you had a

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conversation with Detective Recarey about this,
whether he said anything directly to you that she
was removed as opposed to removing herself
voluntarily from the case?
MR. CRITTON: Form. You're asking him to
speculate.
MR. KUVIN: No, I'm not, I'm asking for
any conversation he had with Detective Recarey.
THE WITNESS: I don't remember.
BY MR. KUVIN:
Q Okay. Page 85, again going down to the
date of May 15, 2006, there's a reference to a
contractor by the name of David Norr, N-O-R-R, and
apparently he was surveilled for a short period of
time.
A Let me find that.
Q Sure. Middle of the page.
A Okay.
Q Do you recall whether your department
obtained any records regarding the renovations that
were going on at Mr. Epstein's home; blue prints,
construction diagrams, anything like that, documents
from the contractor?
A No.
Q No, you didn't, or no --

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with Mr. Indyke?
A No.
Q There appear to be a number of
corporations. El Zorro Ranch Corporation, New York
Strategy Group, Ghislaine, G-H-I-S-L-A-I-N-E,
Corporation, J. Epstein and Company and the
Financial Strategy Group. Do you see those?
A I do.
Q Do you recall anything, seeing any
documents or information regarding those companies?
A I've read this report before. And if it's
in the report I read it previously, but I don't have
anything independent of the report, nor do I recall
any more than what you've shown me here.
Q I'm just looking to see whether or not you
saw any corporate printouts or corporate documents
or anything like that that might have been obtained
online or through other sources?
A I did not get involved in this
investigation at that level.
Q Okay. Last entry here of July 12, 2006,
it says here Belohlavek -- and spelled for the
benefit of the court reporter, we've used it before,
but just for her sake it's B-E-L-O-H-L-A-V-E-K -stated State Attorney Barry Krischer made the

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A No, I don't recall. It would have been
easily available to us from the building department.
Q Right, building and zoning?
A I have no idea if we did.
Q Turn to page 86. Top of the page on May
22nd, 2006, I received several phone calls
throughout the day from Mr., and then it's blacked
out, who stated he had been followed aggressively by
a private investigator. Who was that?
A I don't know.
Q It appears if you go further down that the
vehicle that was following this person was traced by
Florida tag I35-XGA to a Mr. Zachary Bechard of
Candor Investigations. Do you see that?
A Yes.
Q Did you come to learn anything about that
particular investigative agency? Independent of
what might be in the report.
A No, not that I can recall.
Q Page 87, last page. Middle of the page
references Epstein's corporation attorney, a
gentleman by the name of Darren Indyke, I-N-D-Y-K-E.
Do you see that?
A Not yet. Okay, yes.
Q Do you recall having any conversations

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determination to go to the Grand Jury to hear the
case.
Did you, or do you recall discussing
directly with him why he was taking this to a Grand
Jury as opposed to just charging Mr. Epstein, his
office doing it themselves?
A No.
Q You agree with me that that would be out
of the ordinary based on the charges that were
brought?
MR. CRITTON: Form.
THE WITNESS: My experience, yes.
BY MR. KUVIN:
Q Do you agree with me that you learned that
it was Mr. Krischer that made that decision himself?
MR. CRITTON: Form.
THE WITNESS: That's my understanding.
BY MR. KUVIN:
Q Did you ever get any explanation from
anyone, not just him, but anyone, as to why they did
that?
MR. CRITTON: Form.
THE WITNESS: Sometime after the fact, the
Grand Jury, maybe even possibly long after the
fact, he told me that it was a political -- not

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a political, but it was a noteworthy
investigation, a noteworthy prosecution. And
in these kind of controversial situations, an
independent body of the Grand Jury, it was
appropriate to have them exam him. He called
other grand juries for things, I can't say
similar, but a homicide that had racial
overtones and so on, and he made reference to
that, that that was his choice to deal with
these kinds of things. That could have been as
recent as, you know, within the last year and a
half or so.
BY MR. KUVIN:
Q Do you recall your department being
involved in any other high profile type of
investigations; for example, the investigation that
involved a radio personality that lives in Palm
Beach and the investigation of a potential boater
fraud as a result of another author or radio
personality on Palm Beach, or was this the only high
profile investigation you can recall working on in
your history in the city, or the town?
A Involved in the department and personally
been involved in many high profile investigations.
Q Many being more than ten? I'm just trying

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perspectives but not necessarily the news media
coverage.
BY MR. KUVIN:
Q Was it handled any differently than you
handled other high profile cases that you may have
handled in the past?
MR. CRITTON: Form.
BY MR. KUVIN:
Q From your perspective?
A I don't think it was handled any
differently by the Palm Beach Police Department than
from any of the other high profile cases.
Q Okay. I appreciate it. That's all the
questions I have at this point. I'm going to turn
it over to the other plaintiff attorneys who may
have a few for you.
MR. HILL: I don't have any. Thank you,
sir.
THE WITNESS: You're welcome.
MR. GARCIA: I just have a couple here.
CROSS-EXAMINATION.
BY MR. GARCIA:
Q Chief, my name is Sid Garcia, I represent
one of the plaintiffs in the case. I think we met
before in another case, another deposition years

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to get an idea -A The standard rules don't really help me.
We used to joke about how very small things in Palm
Beach would become noteworthy in the news media,
that they would be meaningless everywhere else.
Q Right.
A If you mean national political interest,
at that level profile, yes, at least ten, probably
more than ten.
Q In your experience in dealing with even
those high profile investigations, was this one
different?
MR. CRITTON: Form.
THE WITNESS: It wasn't different in the
amount of, you know, at the level of profile of
had we been involved in that before where it
gets international news media coverage and all
of the things that come with that. It was
different in the respect that probably what
should have remained a state case had to become
a federal case, which they ended it and it all
ended in an agreed plea in the state case. It
was different for me in that I asked the State
Attorney to remove himself from the case, you
know. It was different from many different

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ago.
Just want to ask you a few questions
beginning with the -- asking basically your opinion
as to why Mr. Krischer did not pursue the case with
the diligence that you thought he should have
pursued it with?
MR. CRITTON: Form.
THE WITNESS: I'm not sure I understand
the question.
BY MR. GARCIA:
Q In other words, you talked about that you
sent a letter to Mr. Krischer asking him to
disqualify his office from the case. Why do you
believe that he did not pursue the case with the
zeal that you thought he should pursue it with?
A I don't know.
MR. CRITTON: Form.
BY MR. GARCIA:
Q What is your opinion of why he didn't
pursue it that way?
MR. CRITTON: Form.
THE WITNESS: That's not my role. I
haven't formed an opinion on that, I don't know
why.

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BY MR. GARCIA:
Q Did you think that -- were you aware or
did you become aware at some point that Mr. Epstein
was a contributor to the democratic party?
A Yes.
Q Are you aware that Mr. Krischer has ties
to the democratic party?
MR. CRITTON: Form.
THE WITNESS: Yes.
BY MR. GARCIA:
Q Did you suspect at any point in time that
there was a connection between Mr. Epstein's
political connections with the democratic party and
Mr. Krischer's refusal or neglect to prosecute in
this case with the zeal he should have pursued it
with?
MR. CRITTON: Form.
THE WITNESS: I didn't allow myself to
explore that.
BY MR. GARCIA:
Q Did you have any discussions with Mr.
Krischer about that issue, whether or not
Mr. Epstein was receiving favorable treatment from
the State Attorney's Office because of Mr. Epstein's
political connections?

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criminal charges against Mr. Epstein, correct?
MR. CRITTON: Form.
THE WITNESS: Yes.
BY MR. GARCIA:
Q This is not a situation where there was
maybe a boyfriend/girlfriend situation, an age
difference and the victim was not cooperating in the
investigation; is that correct?
MR. CRITTON: Form.
THE WITNESS: That's correct.
BY MR. GARCIA:
Q Did you challenge him on that issue?
A Yes.
Q And what was his response?
A He continued to reiterate that the case,
that it was his ethical obligation. And he had told
me this before about other cases that we had
discussed, Palm Beach Police Department cases and
other cases, that he has an ethical responsibility
to feel -- to be reasonably certain that the case is
winnable before he prosecutes it. And he said that
because of all of those reasons and others involving
some of the reputation and Facebook pages and so on
of certain victims, that he couldn't feel that he
could be successful in the prosecution.

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MR. CRITTON: Form.
THE WITNESS: I asked him why he was
treating the case in the way that he did.
BY MR. GARCIA:
Q And what was his response?
A His response was that the victims weren't
credible in his mind. I don't know -- I don't mean
all the victims weren't credible but some of the
victims weren't credible. He didn't believe that -sixteen and seventeen-year-old victims, he told me,
were -- he said it was the policy of the State
Attorney's Office not to charge molestation type
cases or even a sex type battery case when it was
consensual. His answer to that question was about
the merits of the case.
Q So he told you it was the policy of the
State Attorney's Office not to charge victims of
lewd and lascivious who were sixteen and seventeen
years old?
A Well when it was a consensual -- I know
it's kind of a misnomer because they can't legally
consent to it, but he said when it was practically a
consensual situation it was their general policy not
to prosecute those kinds of cases, yes.
Q But these victims were willing to press

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Q Did he show you any of the Facebook pages
that he had considered?
A He did not.
Q You said when he presented this case to
the Grand Jury he gave you some explanation as to
why he presented it that way. Did your detectives
and investigators, were they subpoenaed to appear
before the Grand Jury?
A At least one detective was.
Q You know who that was?
A I have to ask my lawyer the question of
whether or not I can answer that because Grand Jury
material, I know, always remains sealed. I don't
know if I do something improper by identifying that
person alone without -- I don't know what they said,
I wasn't in the Grand Jury.
Q I think the testimony would remain
privileged or confidential, but the Grand Jury did
return an indictment; is that correct?
A That's my understanding, yes.
Q So I'm not asking you to -- you don't have
access to the testimony I'm assuming?
A That's correct.
Q I'm just asking you for the identity of
the person who was subpoenaed to appear before the

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Grand Jury, if anyone was, from your department?
A Well I don't know if that is appropriate
for me to answer. Grand Juries are sacred, I don't
know if revealing that would violate something. So
really if unless -Q Do you want to consult with -A -- my lawyer knows otherwise then, you
know, I really would rather not answer that. I
didn't appear before the Grand Jury, you know. I
mean, I don't know if you have that information.
This is a nuance probably.
MR. RANDOLPH: I think he's going to stand
with his answer.
MR. GARCIA: So are you instructing him
not to answer?
MR. RANDOLPH: No.
MR. GARCIA: Okay. Well does anyone take
the position that the identity of the person
subpoenaed to appear before the Grand Jury is
privileged? I think it's something that unless
there's a specific provision in the law that
I'm not aware of, I think the identity of a
witness before the Grand Jury can be testified
to. I'm not asking for the content of
testimony, which he should not have shared with

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Goldsmith?
A It has to be a majority vote of the town
council and he's been reappointed. I don't know if
he still serves in that capacity. I know he did
when I left the department.
Q And at the time that he, for lack of a
better word, lobbied for Mr. Epstein, was he a
member of this retirement police board?
A Yes.
Q How many conversations did Mr. Goldsmith
have with you about Mr. Epstein on this issue?
A I can remember two in my office and I
think one during sort of a chance encounter
somewhere outside of my office.
Q And you said he introduced Mr. Goldstein
to you? I mean Mr. Goldsmith introduced Mr. Epstein
to you on one occasion; is that correct?
A Yeah, I believe so.
Q Did he bring him to your office or was it
outside the office?
A I remember a time that Mr. Epstein came to
my office prior to all this.
Q Prior to all what?
A All of -- everything that we've talked
about here today.

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you in any event, but I just want to know the
person who actually had a subpoena served on
him to appear before the Grand Jury.
THE WITNESS: Other subpoenas in the case
file, criminal case file?
BY MR. GARCIA:
Q I don't know the answer.
A If they're not, I mean you're all the
lawyers, but I would feel much more comfortable
either having that researched by my lawyer or being
instructed by a judge whether to answer that. I
would not want to take the chance of doing something
wrong in violation of law by answering that.
Q All right. Well I guess we'll certify the
question.
You were talking about Jerry
Goldsmith. Did he ever hold any official position
with the Town of Palm Beach?
A He did. And as far as I know is still the
chairman of the police retirement board, which is an
appointed position by the town council.
Q Are you a participant in the retirement
plan?
A Yes, I am.
Q And do you know who appointed Mr.

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Q Oh, prior to even the beginning of the
investigation?
A Yes, as just a resident. And I really had
an open door policy and lots of people did that.
And I don't remember whether or not he was
physically there with him or whether or not it was
something he facilitated, he being Jerry Goldsmith.
Q What did Mr. Epstein want to speak to you
about?
A I don't remember the detail of it and I
don't remember whether or not it was at his request
or my request. He had made donations to the police
department in the past. I think that some substance
of that conversation related to that.
Q I'm sorry, who had made donations?
A He being Mr. Epstein.
Q And do you know in what amounts?
A Precisely, no. But Palm Beach being a
philanthropic community, there was a formal fund set
up that allowed residents, or anyone for that
matter, to buy things that didn't appear in the
budget and it was always very specific. And I do
remember that he donated, he being Mr. Epstein,
donated a long period prior to this investigation
some technical equipment that the department

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couldn't fund any other way. The exact number or
even the approximate number I don't remember. He
made a larger donation at a later time, you know,
before the investigation took place, and we didn't
expend the money because we were researching the
equipment, and that was a firearms training
simulator. And once the investigation -- I became
aware of the investigation, I sort of froze the
money, and then once the case had become public I
had sent him the money back.
Q And do you know what the amount of the
larger donation was?
A It was in the $100,000 range.
Q And do you recall the date of the
donation?
A No, I don't. Those records I'm sure are
available.
Q What was the earliest date that anyone
came to you with a complaint about Mr. Epstein's
activities in terms of the young women visiting his
home?
A Well no one ever came to me about that
directly, but to the department. I suppose this,
this would be Exhibit Number 1. Or just prior to
that there was some sort of report to us that was

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I've ever seen that before.
Q When did you return the money, the second
donation of $100,000 to Mr. Epstein?
A I don't recall the exact date, but it was
once I was completely confident that he was aware of
the investigation. Because I didn't want to return
it prior to that because then I think it might have
been a tip off to him, it would have been a tip off
to him that something was amiss.
Q Did your staff at the Palm Beach Police
Department attempt to interview any of Mr. Epstein's
employees at any time? And I'm talking about like
maybe the cook, the butler, whoever he had on staff
at the house?
A I think we tried to interview everyone.
Q Do you recall when the first attempts to
interview were made?
A No, I don't.
Q Would you say it was 2004 or 2005?
A I think it was around the point that it
either -- it was after or around the point that it
became public that we were confident that he knew
that we were investigating.
MR. GARCIA: I think the videographer's
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kind of like there are attractive young women coming
and going, different ones all of the time. And
there was some level of inquiry on that and we
were -- it was reported to me that we were confident
that they were all adults.
Q And Exhibit Number 1, what is the date of
that document?
A 11/28/04.
Q And you said that it was either on that
date or just before that date that someone made the
department aware of these activities at his home
involving young women?
A Yes.
Q And are you able to testify to a certainty
that the donation, the initial donation of technical
equipment or the subsequent donation of about
$100,000, was before or prior to November 28th,
2004?
A I know it was with complete certainty
prior to March 14th, 2005. I believe it was
probably prior to 11/28/2004, but the details of
this I am not sure I have ever seen prior to this.
I think it was reported to me in summary format,
but -- so I wouldn't have made an immediate
connection to the timing because I don't know if

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if we can change tapes.
THE VIDEOGRAPHER: We're off the record at
3 o'clock and this is the end of tape 3.
(Off the record)
THE VIDEOGRAPHER: We're back on the
record at 3:04. This is the beginning of tape
4.
BY MR. GARCIA:
Q Did you ever inform the U.S. Attorney's
Office or the FBI about these donations that Mr.
Epstein had made sometime around the -- we don't
know quite when but sometime it sounds like 2004
perhaps?
MR. CRITTON: Form.
THE WITNESS: Yes, on the same day that
the Grand Jury indictment was on, a Friday. I
learned of Mr. Epstein's arrest on Monday
morning. That day the FBI called me and asked
me to come over along with the detective to
provide them information in the case, and in
that initial meeting I informed them of this in
detail.
BY MR. GARCIA:
Q I'm sorry if I asked this already, but the
original equipment that he donated to the

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department, was that ever returned to Mr. Epstein?
MR. CRITTON: Form.
THE WITNESS: No. That was video editing
equipment.
BY MR. GARCIA:
Q And do you know the value of that
equipment?
A No, I don't. It was certainly less than
the subsequent donation.
Q And when you learned of the subsequent
donation, why did you hang on to it rather than
using it for -- to purchase equipment or for some
other purpose?
A This was emerging technology and we were
still researching which of the vendor's equipment
that we were interested in purchasing. I think we
were going to put out a request for proposals on
that. And we were learning more, as it was changing
and improving, about what kind of equipment to
actually buy, the details of which brand equipment
to buy.
Q And who would have the records of when
this donation or these two donations actually came
in?
A Custodian of records would be the

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generally.
Q Do you recall writing a thank you letter
in this particular case?
A For which one, for the -Q For the monetary donation?
A I don't actually recall it but it would
have been extremely unusual for me not to, so I'm
sure that I did.
Q Where are these funds deposited, the
monetary donations that are made to the police
department?
A There is a donation's account that's
part -- a line item on the town's budget as an
expenditure line item that matches that.
Q Is it fair to say that the $100,000
donation was returned by the Town of Palm Beach
after the indictment?
A Well the exact date is available because I
wrote Mr. Epstein a letter when I had a check issued
and sent to him. I'm thinking that it might be
before the indictment. I think it was the point
that it was out there in the public, that everybody
knew, but I might be wrong. I see he's shaking his
head no, he might remember better. But it was
returned no later than the day of his arrest.

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appropriate place where all the financial things
like that are very carefully documented. I'm
guessing that the donation of the video equipment
might even have been prior to when I became Police
Chief, it was that much earlier.
Q And you became Police Chief when?
A 2001.
Q What about the $100,000 donation, was that
before or after you became Police Chief?
A That was while I was Police Chief.
Q And can you narrow down a year for me in
terms of when it may have happened?
A All of this is available in exact numbers,
I just don't have the documents.
Q What sort of receipt is issued to someone
who donates equipment or money to the Town of Palm
Beach?
A A thank you letter, which if they choose
to use it as a tax deduction I guess they use that.
Q And would that come from the town -excuse me, police -A Come from the Police Chief.
Q Police Chief, okay.
A Or whatever department the donation was
made to it would come from the department head

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Q And did you explain in your letter why you
were returning the funds to him?
A No. I remember being very brief.
Q Getting back to Mr. Goldsmith, I may have
misunderstood what you said, but I thought you said
something along the lines that you had to make clear
to him that what he was doing, what he,
Mr. Goldsmith was doing, could potentially be a
crime. Did I understand that correctly?
A Yeah. I said it was improper and that he
needed to stop.
Q Did you use the words what you might be
doing might be a crime?
A I conveyed that message even if I didn't
use those exact words. Not that what he was doing
was a crime. If it was a crime I would have to
decide to arrest him, but -- and I don't think he
ever thought that prior to me pointing out to him
that he had to stop and that it was improper and
that it was, you know, serious, I don't think he
ever thought that he was doing anything improper or
illegal.
Q And did he say that he had any personal
knowledge of what these events that Mr. Epstein was
being investigated for were and that it wasn't

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really that big a deal?
A No.
Q Did he seem to have an understanding of
what Mr. Epstein was being investigated for?
MR. CRITTON: Form.
THE WITNESS: I know that I told him that
this was very serious, involved young girls,
that it was a felony some of the instances.
Did he realize that prior to me telling him
that, I don't know, but I know that he realized
that when I told him that.
BY MR. GARCIA:
Q And when do you think the conversations in
terms of the range of dates that you had with Mr.
Goldsmith were?
A I don't have the exact dates, but the very
first conversation was before things were public. I
had the impression that he had some contact with Mr.
Epstein to know that we were investigating him. I
didn't know how else he would know that.
Q And if it was a -- I don't know if you
would call it a secret investigation, maybe a
confidential investigation, did you ask him how he
knew of the investigation?
A I don't recall if I did. All

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if I said illegal or what charges might apply here
or anything of those things, I don't know. I don't
think -- I did because I don't think he fully
realized what I thought he had begun to do. I feel
like he thought that he was just sort of defending a
friend and making a commentary to a friend, which is
I'm sure how he viewed me, that he thought we were
unnecessarily zealous in seeing this got prosecuted.
Q Did you ever find out that Mr. Goldsmith
went to higher authorities than yourself within the
Town of Palm Beach to make the same pitch in favor
of Mr. Epstein?
MR. CRITTON: Form.
THE WITNESS: I heard from many different
people that he said the same thing to them
about our investigation.
BY MR. GARCIA:
Q Including Mr. Elwell?
A No.
Q Who did you hear -A I don't remember specifically Peter Elwell
telling me that Jerry Goldsmith talked to me about
that.
Q Did he go to any town council members?
A I know that he went to one town council

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investigations are secret just by their nature.
Q But in any event, no one from your
department at that point in time would have been
authorized to discuss the investigation outside of
the agency itself or perhaps maybe with a witness;
is that correct?
A Or law enforcement, the State Attorney's
Office, that's correct.
Q And the first conversation that you say
you had with Mr. Goldsmith before things became
public, are you speaking of the indictment or are
you speaking about media coverage of the
investigation? What do you mean by before things
became public?
A When I say public I mean that was the
point that the news media began reporting on it.
And I don't remember exactly when that was, if that
was before the announcing of the arrest or if it was
right at the arrest when he turned himself in.
Q When you spoke to Mr. Goldsmith, did you
use words like obstruction of justice or witness
tampering?
A I don't remember exactly what I told him,
but I let him know he had to stop, he had to stop
and it was beyond just improper. I don't remember

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person, yes.
Q Who was that?
A You know, some of these things are told me
in confidence as a friend. I don't feel appropriate
in relaying that information here. I don't see what
that has to do with the case.
Q Well, I mean I can't explain to you how I
might use that information, but I can tell you it's
not subject to a privilege even if a person told you
in confidence unless there was some sort of
attorney/client privilege involved, which I'm sure
there wasn't. So unfortunately I am going to ask
that you convey that answer.
MR. KUVIN: Do you want to consult?
MR. RANDOLPH: Yeah. Let's take a minute.
THE VIDEOGRAPHER: We're off the record at
3:15.
(Off the record)
THE VIDEOGRAPHER: We are back on the
record at 3:19.
BY MR. GARCIA:
Q Okay, sir, you've had an opportunity to
consult with your counsel. And my question, I
believe, was who was the town council member who
informed you that Jerry Goldsmith had approached him

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or her attempting to speak on behalf of Mr. Epstein
concerning your investigation?
A Gail Coniglio.
Q Gail, G-A-I-L?
A Yes.
Q How do you spell the last name?
A C-O-N-I-G-L-I-O.
Q Is this before or after you had impressed
upon Mr. Goldsmith that what he was doing was
improper that Mrs. Coniglio approached you?
A I don't remember.
Q Did you ever consider filing any
obstruction of justice charges against Mr. Goldsmith
after you learned that he was conferring with town
council members on behalf of Mr. Epstein during a
pending police investigation?
A I don't think that he was attempting to
influence me through them because I was not
influenceable. I don't report to them and it really
wouldn't matter, I report to the Town Manager.
Even if he told me to do A, if I felt
B was right and it ended my career, if it was
important enough I would do B. But I never felt
that kind of pressure. I never felt like he did any
of these things knowing that he risked violation of

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Q And, I'm sorry, did you say that
Ms. Coniglio spoke to you about this or did you
initiate a conversation with her about this?
A I had contact with her on a regular basis
and, you know, as a town council member, and she
called me and sort of began it by why is Jerry
Goldsmith so upset with you. And I think I said
well, I've heard that -- in general terms this is
what I said, that he has been speaking unfavorably
about me. I know that he is a close friend of
Mr. Epstein and he told me that. And she sort of
said oh, well that explains it. Well, you know, he
thinks that you went too far with this and that
you're out of control and pursuing investigations
against Palm Beach residents and didn't really know
my place. That was the general content of the
conversation.
Q And did you perceive Ms. Coniglio as
exerting some sort of subtle pressure on you to
maybe back off a little bit in this investigation?
A Not at all in any way.
Q Does the Town of Palm Beach have an IT
person who is in charge of your computerized records
and e-mails and things of that nature?
A Yes.

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a statute. I felt like he -- I just felt like he
could talk to a friend about a friend. I mean I
thought about it a little bit but, no, it wasn't the
kind of thing that I ever considered filing charges.
Q Did Gail Coniglio ever tell you, or did
you ever ask Ms. Coniglio what Mr. Goldsmith had
said to her on behalf of Mr. Epstein?
A It was -- yes, she told me it was more of
a commentary about she described Jerry Goldsmith's
sort of commentary about how he didn't feel I acted
appropriately and he thought it was my way of
showing that I had some power over the wealthy
residents of Palm Beach, which was ridiculous.
It was, you know, a variety of
different things that I heard on the cocktail party
circuit of, you know, people's idea, some of them
planted by lawyers that represented Mr. Epstein and
comments to the New York newspapers. And I heard a
lot of that throughout this entire thing.
And it was more along those lines of
that Gail Coniglio related Jerry Goldsmith's
comments about, I was kind of an employee and didn't
really know my place here and that I had been more
zealous about seeing that this got prosecuted than I
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Q Who would that be?
A Spencer Wilson.
Q And what is his job title or position?
A Manager or director or something, of
information systems.
Q Is that just for the police department or
for all the town?
A No, for the whole town.
Q And you said something about you felt the
retention policy for e-mails was one to two years?
A I'm guessing, I don't know. I'm guessing.
Q I mean any e-mail you would have received
or sent out would be subject to the public records
law, right?
A Business related e-mails, that's my
understanding, yes.
Q You said you received a letter from the
U.S. Attorney's Office that you were asked to
destroy?
A That's correct.
Q Did you destroy the letter?
A Yes, I did.
Q Did you consult with counsel prior to
destroying the letter?
A I consulted with the U.S. Attorney and

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asked whether or not in light of the public records
law and so on that I had an obligation to keep it
and so on. And they said no, we're asking you to
destroy that as part of something, some statute or
rule or something that was included in there, and it
was appropriate to destroy it as part of -- I don't
know whether they use this terminology, but work
product, attorney/client relationship, so on and so
on.
Q Did your agency handle the doctor shopping
investigation with Rush Limbaugh?
A No.
Q Did your detectives or officers interview
Sarah Kellen at any time or attempt to interview
her?
A I think we attempted. I don't know
whether we were successful or not.
Q And I think you said you submitted, I
don't know if it was an arrest warrant or some sort
of paper, to the State Attorney's Office to have
Sarah Kellen charged criminally?
A I think I remember the original
application for a capias or a rough sworn or
something like that included three people. I seem
to remember it was Mr. Epstein, Nadia Marcinkova, I

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first questions of him today.
THE WITNESS: Yeah. It was the same
explanation as before, the Facebook pages and
ages of some of the victims and so on.
BY MR. GARCIA:
Q Did Mr. Krischer talk to you about a
lawsuit that he had been a defendant in involving
allegations of sexual harassment?
A No.
Q Were you aware of that lawsuit?
A Yes, from the news media.
Q I have nothing further. Thank you.
A You're welcome.
*****
(End of Volume I, continued on Volume II)

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apologize if I'm mispronouncing that. And, you
know, I'm not sure whether it was Sarah Kellen or
Haley Robson that was that third person, I'm not
entirely sure. I'm sure you have copies in the
public records.
Q And in that document that you forwarded to
the State Attorney's Office, were charges
recommended specifically in terms of what they
should be?
A Yes.
Q And what were the charges if you recall?
A I don't recall.
Q And as a result of filing those papers
with the State Attorney's Office, were criminal
charges filed, or was this where Mr. Krischer
declined to file the charges that you folks
recommended?
A He declined to file those charges.
Q And is that when the relationship between
you and Mr. Krischer started breaking down?
A Yes.
Q Did he give you any explanation as to why
he declined to follow your agency's recommended
charges?
MR. CRITTON: Form. That was one of your

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CERTIFICATE OF OATH

THE STATE OF FLORIDA,)
COUNTY OF PALM BEACH.)
I, the undersigned authority, certify that MICHAEL
REITER personally appeared before me and was duly sworn on
the 23rd day of November, 2009.
WITNESS my hand and official seal this 30th day of
November, 2009.

______________________________
VANESSA G. ARCHER

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REPORTER'S CERTIFICATE
THE STATE OF FLORIDA,)
COUNTY OF PALM BEACH.)
I, VANESSA G. ARCHER, Court Reporter, certify that
I was authorized to and did stenographically report the
foregoing deposition; that a review of the transcript was
requested; and that the transcript, Pages 1 through 185, is
a true and complete record of the testimony given by the
witness.
I further certify that I am not a relative,
employee, attorney, or counsel of any of the parties, nor am
I a relative or employee of any of the parties' attorney or
counsel connected with the action, nor am I financially
interested in the action.
The certification does not apply to any
reproduction of the same by any means unless under the
direct control and/or direction of the reporter.
Dated this 30th day of November, 2009.
_________________________________
VANESSA G. ARCHER, COURT REPORTER

ERRATA SHEET
B.B. vs. Jeffrey Epstein
Case No: 502008CA37319 XXXX MB AB
11/23/09
DO NOT WRITE ON TRANSCRIPT - - ENTER CHANGES HERE:
Page: ___________ Line: _____________
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Should read: _______________________________________________
Reason for Change: _________________________________________
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Reason for Change: _________________________________________
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Should read: _______________________________________________
Reason for Change: _________________________________________
Under penalties of perjury, I declare that I have
read my foregoing transcript and, together with any changes
made above, the facts stated herein are true.

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__________________ ____________________________________
DATE
(Witness Name)

47 (Pages 185 to 186)
Pleasanton, Greenhill, Meek and Associates
561-833-7811