Page 499 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: JANE DOE NO. 2, _Plaintiff, ~vs? VOLUME IV OF IV JEFFREY EPSTEIN, Defendant. Related cases: 08?80232, 08?08380, 08?80381, 08?80994 08?80993, 08?808Il, 08?80893, 09w80469 09?80591, 09?80656, 09?80802, 09?81092 DEPOSITION OF DETECTIVE JOSEPH RECAREY Tuesday, April 27, 2010 10:03 5:23 p.m. 505 South Flagler Drive Suite 1100 West Palm Beach, Florida 33401 Reported By: Jeana Ricciuti, RPR, FPR, CLR Notary Public, State of Florida Prose Court Reporting (561) 832m7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428?9381) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Page 500 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE AB Plaintiff, ?vs? VOLUME IV OF IV JEFFREY EPSTEIN AND SARAH KELLEN, Defendants. DEPOSITION OF DETECTIVE JOSEPH RECAREY Friday, March 19,,2010 10:03 5:23 p.m. 505 South Flagler Drive Suite 1100 West Palm Beach, Florida 33401 Reported By: Jeana Ricoiuti, RPR, FPR, CLR Notary Public, State of Florida Prose Court Reporting ,7 - . r' - - (561) 832?7506 Electronically signed by Jeana Ricciuti (601-289?428-9381) Electronically signed by Jeana Ricciuti (601?280-428-9381) 29f Page 501 2 UNITED STATES DISTRICT COURT, SOUTHERN DISTRICT OF FLORIDA CASE NO. 10?80309 5 JANE DOE NO. 103, 6 Plaintiff, 7 -Vs? VOLUME IV OF IV 8 JEFFREY EPSTEIN, 9 Defendant. 10 11 12 DEPOSITION OF DETECTIVE JOSEPH RECAREY 13 14 Tuesday, April 27, 2010 15 10:03 5:23lp.m. 16 505 South Flagler Drive Suite 1100 17 West Palm Beach, Florida 33401 18 19 20 21 22 Reported By: Jeana Ricciuti, RPR, FPR, CLR 23 Notary Public, State of Florida Prose Court Reporting 24 25 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 (561) 832u7500 Electronically signed by Jeana Ricciuti (601-2804283381) Electronically signed by Jeana Ricciuti (601-280-428-9381) bdcd?l876-c729?432d-8ch-b1 939656129f APPEARANCES: On behalf of Jane Does 1 through 8: JESSICA ARBOUR, ESQUIRE MERMELSTEIN HOROWITZ, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 Phone: 305.931.2200 On behalf of the Plaintiff, Jane Doe No. II: and ISIDRO MANUEL GARCIA, ESQUIRE GARCIA, ELKINS BOEHRINGER 224 Datura Avenue, Suite 900 West Palm Beach, Florida 33401 Phone: 561.832.8033 TARA A. FINNTGAN, ESQUIRE TARA A. FINNIGAN, P.A. 224 Datura Street Suite 900 West Palm Beach, Florida 33401 Phone: 561.835.8115 On behalf of the Defendant, Jeffrey Epstein: and (561) 832w7500 MICHAEL PIKE, ESQUIRE BURMAN, CRITTON, LUTTIER COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Palm Beach, Florida 33401 Phone: 561.842.2820 MILTON G. WEINBERG, ESQUIRE LAW OFFICE OF MILTON G. WEINBERG 20 Park Plaza Suite 1000, Boston, Massachusetts 02116 Phone: 617.227.3700 PROSE COURT REPORTING AGENCY, INC. Electronicafly signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280?428-9381) Page 502 (561) 832?7506 bdcd1 876-c729?432d-86f0-b19ae6561 29f 7 Also (561) 832?7500 1 Appearances 2 On behalf of the Witness: JOANNE M. ESQUIRE JONES, FOSTER, JOHNSON STUBBS, P.A. 505 South Flagler Drive, Suite 1100 West Palm Beach, Florida 33401 Phone: 561.659.3000 Present: Jeffrey Epstein PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 5035 (561) 832-7506 bdcd1 WITNESS: CROSS CROSS REDIRECT DETECTIVE JOE RECAREY BY MR. WEINBERG 505 BY MS. ARBOUR BY MR. GARCIA I I DESCRIPTION DEPOSITION EX. 29? MESSAGE BOOKS DEPOSITION EX. 3O HANDWRITTEN NOTE ON JEFFREY E. PAD DEPOSITION EX. 31 HANDWRITTEN MESSAGE (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) Electronically signed by Jeana Ricciuti (601-280?428-9381) Electronically signed lay Jeana Ricciuti (601-280-428-9381) 832*7506 Page 504 RECROSS 636 636 PAGE 592 617" 622 bdcd?l 10 ll W12 __14 (561) 832~7500 Page 505 I MR. WEINBERG: Q. Good afternoon, sir. A. Good afternoon. Q. To finish up the subject that we were talking about right before the recess, do you ever recall discussions with the State Attorney's office about an offer that was extended to Mr: Epstein to plead guilty and receive a five?year period of probation for an aggravated assault charge? A. Yes. Q. And that was a subject of discussion between you and members of the State Attorney's office? A. With Assistant State Attorney Lanna Belohlavek. I don?t know if that's her last name, how it's pronounced, but close enough. Q. If we call her Lanna, I think we both know who we're discussing. A. Yeah. Q. And those discussions occurred within or around the winter of 2005, A. I believe so. Q. And was that a sentence and a charge option that was extended to Mr. Epstein through his then PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronically signed by Jeana Ricciuti (601-280-428-9381?) Electronically signed by Jeana Ricciuti (601-280-428-9381) 291 'was made? (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Page 506 counsel? MS. ARBOUR: Form. THE WITNESS: I believe so, yes. BY MR. WEINBERG: Q. And that was an offer that was extended by the State Attorney following discussions with the Palm Beach Police Department, correct? A. That was when we had just heard about it. We were unaware that the offer was made. Q. And how did you become aware that the offer A. I had made numerous telephone calls to the State Attorney's office to inquire where we were, and did not receive any return phone calls. I went over to the State Attorney's office personally on an unrelated incident to drop off some filing packets, and that's when I went by and I saw Lanna was in her office. Q. Lanna was an experienced State attorney, correct? MS. ARBOUR: Form. THE WITNESS: I know she had been there for some time. BY MR. WEINBERG: Q. And you knew she had been a prosecutor for sex offense cases for some time, correct? (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 507 crimes against children. 2 Qt And she, on other occasions, advocated 3 rprosecution of people on felony charges, correct? 4 A. I hadn't had many dealings with her so I don't 5 know? You know, I knew of her. She was actually at the 6 office, State.Attorney's office, when_I was employed 7 there many years ago. 8 Q. And that was how many years ago? 9' A. I've been with Palm Beach almost 19 years. 10 So we?re talking about at least 20 years ago? 11 A Yeah. 12 Q. And she had been there, to your knowledge, 13 continuously fromithe time that you knew she was there 14 20 years ago? 15 A- Yeah. 16 7 Q. And you knew her specialty to be charging 17 people that were for offenses that dealt with 18 violations of underaged people, correct? 19 MS. ARBOUR: Form. 20 THE WITNESS: I believe so. I believe so. 21 Like I said, I didn't have many dealings with her. 22 BY MR. WEINBERGthe office that day? 24 A. And that was the time that I just had learned 25 of the offer that was made to previous counsel. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Page 508 Q. And did you take a position on that offer? A. Personally, I told her I didn't agree with it, but I couldn't speak for the department. It actually had to come from people with a higher pay grade than mine, so I just relayed the information back to Chief Reiter. Q. And what, if anything, did Chief Reiter do? MS. ARBOUR: Form. THE WITNESS: I believe he tried to make contact with State Attorney Barry Krischer. BY MR. WEINBERG: Q. Did he make contact with State Attorney Krischer, to your knowledge? A. I'm not 100 percent certain if he did or didn't. I know there was some time where none of our calls were being returned from the State Attorney's office. Q. Jane Doe 103 was one of the witnesses who was at the center of the State investigation, correct? A. One of them, yes. Q. And you knew that Jane Doe 103 had a MySpace page that was one of the MySpace profiles that was provided to the State Attorney by Mr. Epstein's then counsel, Professor Dershowitz, correct? A. Yes, I knew that there were pages sent of the 2123:2333: 1-13 TiEi?EiiE": E. i i (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) _25 MySpaces, but I wasn't sure of whom_at that particular time. They provided us copies thereafter, but right there, immediately, I wasn't aware of whom had pages. Q. You eventually received them_and reviewed them, correct? A. thhuh. Q. And you that Jane Doe 103 least one arrest, A. Yes. Q. And you in early October, Page 509 i understood that from_even before then, had a background that involved at correct? understood that when she was arrested she in fact informed the arresting (561) 832?7500 officers that she had information regarding Mr. Epstein, correct? A. I believe soyour probable cause affidavit at page ll, at the bottom of 10, it starts, "On September 11, 2005, Jane Doe 103 was arrested by the Palm Beach Police Department for misdemeanor possession of marijuana. During the arrest, Jane Doe 103 told the arresting officer that she had information about sexual activity taking place at the residence of Mr. Epstein." A. Yes. Q. Jane Doe 103 essentially was asking the arresting officer to assist in her cooperating; is that PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428?9381) Electronically signed by deana Ricciuti (601?280-428-9381) (561) 832?7500 Page 510 correct? MS. ARBOUR: Form. THE WITNESS: I know that when there's misdemeanor arrests in the Town of Palm Beach, a lot of officers pretty much try to gain any intelligence they can from any of the people that they encounter. Some of the information actually leads to other cases, clearance of minor cases, thefts, bike thefts. BY MR. WEINBERG: Q. And in this case, it led to you going to see Jane Doe 103, first calling her on October 10th and then visiting her in Jacksonville on October 11th, correct? A. Yes. Q. .And you also, in your investigation, learned that Jane Doe 103 had lost her job at Victoria Secret for stealing, did you not? A. No . Q. You never received any information regarding 5 Jane Doe 103's employment history with Victoria Secret? A. She was actually employed there when I went up to see her. That's where I met with her. Q. Did you ever learn at any time that she had a problem that led to her losing her employment? A. No. 2.223;? PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 511 1 Q. So you knew she had been arrested for 2 marijuana? 3 A. Uh?huh. 4 Q. You knew she had a MySpace page where there 5 was information that was that showed her to use 6 drugs, correct? 7 A. Uh-huh. 8 MR. PIKE: Yes or no? 9 THE WITNESS: Yes. 10 BY MR. WEINBERG: 11 Q. You knew that the role of the State Attorney, 12 the prosecutor that would have to present this case to 13 the jury, was to weigh evidence, correct? Not only the 14 evidence you provided but also any evidence that was 15 provided by those representing the target of criminal 16 investigation? 17 A. Yes. 18 Q. And you knew that as a result of that weighing 19 process, Lanna, an experienced State Attorney, told you 20 that she believed at least that Jane Doe 103 was a 21 consenting participant and not a victim of criminal 22 offenses by Mr. Epstein, correct? 23 MR. GARCIA: Object to the form. 24 THE WITNESS: I don't consenting victim, 25 you mean? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428w9381) 291 Page 512 1 BY MR. WEINBERG: 2 Q. She told you that there were no victims here 3 when 4 A. Originally, that was her statement, yes. 5 Q. Right. And if there were no victims here, 6 then she's really saying to you that, after reviewing 7 all of the evidence that she received, not only from you 8 but from the defense, she didn't consider Jane Doe 103 9 to be a victim? 10 MS. ARBOUR: Form. 11 THE WITNESS: I believe that's what she 12 stated. 13 BY MR. WEINBERG: 14 Q. And given her knowledge of what occurred on E1 715 Brillo Way, she didn't see any victims in this case. 16 MS. ARBOUR: Form. 17 THE WITNESS: I believe that's what she 18 stated. 19 BY MR. WEINBERG: 20 Q. Whether or not she physically did possess the 21 message pads or whether she had access to information, 22 the message pads that you revieWed were in the hundreds, 23 if not thousands, correct? I 24 A. Uh?huh. 25 Q. And that these pads reflected incoming calls (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 Eiectronicaily signed by Jeana Ricciuti (601 ?280-428-9381) Eiectronicaily signed by Jeana Ricciuti (601 -280?428?9381) (561 Page 513 to Mr. Epstein's phone that was in Mr. Epstein's residence on El Brillo, correct? A. Correct. Q. And they reflected messages that came from people that left their phone numbers? A. Yes. Q. And it reflected messages that included, for instance, from L.M. on July 9, 2004?, is available on Tuesday. Was that a message that was concluded in? these mesSage pads? MS. ARBOUR: Form. THE WITNESS: Yes, there was some like that, yes. BY MR. WEINBERG: Q. And that is characteristic of lots of the messages that were being received by whoever was taking down a message at the Epstein residence, correct? MS. ARBOUR: Form. THE WITNESS: Uh?huh, yes, correct. BY MR. WEINBERG: Q. And the way it worked, if I'm right, is that somebody would answer the phone and, for instance, the 3 message would say on July 19, '04, Mr. Epstein: Phone call from L.M., leaving a reply mobile phone number or cellular number, and leave a very short message, in this PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 832w7500 Electronicaily signed by Jeana Ricciuti (601-280-428?9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 514 1 case, "Is it okay to take a taxi". 2 MS. ARBOUR: Form. 3 BY MR. WEINBERG: 4 - Q. Is that right? 5 MS. ARBOUR: Same objection. 6 THE WITNESS: Yes. 7 BY MR. WEINBERG: 8 Q. So whoever was at the Epstein home receiving 9 the call would essentially write this down onia message 10 pad that had at least two different layers? 11 MS. ARBOUR: 'Form. 712 THE WITNESS: Yes. 13 BY MR. WEINBERG: 14 Q. And that when you seized the message pad from 15 the trash pulls, there was only one layer, which was.the 16 original that had been thrown out or crumpled out, 17 correct? 18 A. Yes. 19 Q. And when you went on October 20th and 20 conducted a search and seizure, you would seize the pads 21 that included all of the copies of the original 22 messages, correct? 23 A. Yes. 24 Q. And they were in various handwriting, were 25 they not? (561) 832*7506 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronicaily signed by Jeana Ricciuti (601?280-428?9331) Electronicaily signed by Jeana Ricciuti (601-280-428-9381) Page 515 A- Yes. i 2 Q. And they provided you with leads to witnesses, 3 did they not? A A. Yes. 5 Q. And provided you with names and numbers? 6 7 A. Yes. 77 Q. And gave you information that there was lots 8_ of people who, at least according to these telephone, 9 incoming telephone calls, were inviting themselves to 10 Mr. Epstein's home 7 11 MS. ARBOUR: Form. 12 BY MR. WEINBERG: 13 Q- either directly or through their friends, i 14 correct? . 15 MS. ARBOUR: Form. 16 MR. GARCIA: Object to form. 17 THE WITNESS: There were several messages that 18 I recall was written to Mr. Epstein indicating 19 girls' names and times that they were available. 20 BY MR. WEINBERG: 21 Q. Like, for instance here, she wants to confirm 22 a 11:00 tomorrow, message for JAE from a woman's name. 23 That would be typical messages on these pads that you 24 reviewed? 25 MS..ARBOUR: Form. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601 48042841381) Electronically signed by Jeana Ricciuti (601?2804288381) (561) 832-7500 PROBE COURT REPORTING AGENCY, INC. Page 516 THE WITNESS: That would be some, yes. BY MR. WEINBERG: Q. And many of them appeared to?be incoming calls from different girls which said, I'm in town, can I come over, can I schedule a meeting? MS . ARBOUR: Formi I THE Some were like that. BY MR. WEINBERG: Q. And some appeared to be responses to a phone call made by someone at the El Brillo home asking, are you available, and thereewould be a phone call back saying, I'm available tomorrow afternoon or Wednesday morning or Thursday afternoon. A. Correct. Q. And by and large, these messages did not include any negotiation over dollars? In other words, there was not on a message pad that any of these incoming girls were saying, I will come over if Jeffrey gives me $500 or $300; there was no evidence of that kind of incoming phone call, correct? MS. ARBOUR: Form. THE WITNESS: Not that I can recall, no. BY MR. WEINBERG: Q. And likewise, there was no indication on these message pads that any of the people calling (561) 832?7506 Electronicain signed by Jeana Ricciuti (601 -280-428-9381) Electronically signed by Jeana Ricciuti (601 ?280-428-9381) Page 517 1 Mr. Epstein?s home were, in essence, particularizing 2 what they were going to do or what they intended to do 3 .or what they might do once they got there, correct? - 4 MS. ARBOUR: Form. 5 THE Can you repeat that question? 6 BY MR. WEINBERG: 7 Q. Sure. There's nothing on these message pads 8 that indicates, I?ll come over and give a topless 9 massage to Mr. Epstein? -310 A. No. 11 Q. These are essentially contact and scheduling _12 calls? 13 MS. ARBQUR: Forms 4714 THE WITNESS: Yes. BY 16 Q. And often reflect the fact that the callers 3 17 are not connecting on the first call, so they're going 18 back and forth and trying to arrange times for a 19 particular woman to come over to Mr. Epstein's home, 20 correct? 21 MS. ARBOUR: Form. 22 THE WITNESS: Yeah. 23 BY MR. WEINBERG: 24 Q. And some of these calls come from a whole 25 grouping of persons that you learned were over the age (56l) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601 ?280-428-9381) Electronically signed by Jeana Ricciuti (601-280?428-9381) 29f Page 518 1 of 18; is that right? 2 A. What groupings? 3 Q. Well, let's say, did you ever interview a 4 woman named - 5 A. Yes. 6 Q. And you knew that her date of birth was in 7 June of 1986 and that she was over 18 when you 8 interviewed her 9 A. Yes. 10 Q. and represented herself to be over 18 when - 11 she saw Mr. Epstein? 12 MS. ARBOUR: Form. 13 THE WITNESS: Yes. 14 BY MR. WEINBERG: 15 Q. And, likewise, V.B. was another person who 16 said yes, she had been to Mri Epstein's house at a time 17 when she was over 18? 18 A. Correct. 19 Q. And then was in her 20s when you 20 interviewed her? 21 A. Yes. 22 Q. And there was a K.P., who after the publicity 23 came out, called in and said she was 25 at the time she 24 met with Mr. Epstein? 25 A. Yes. . (561) 832?7506 t: (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Eiectronically signed by Jeana Ricciuti (601-?280-428?9381) Electronically signed by Jeana Ricciuti (601?280-423?9381) Page 519l? 1 Q. And L.A., who you interviewed, who told you 2 that yes, she went to Mr. Epstein's home on many 3 occasions, and she was over 18? 4 A. Yes. 5 And a C.V. 6 AJ She was a licensed masseuse. 7 Licensed masseuse who was over 18. 85 A Yes. 9 Q. And some of the people interviewed had turned i 10 18 during the period that they were seeing Mr. Epstein 11 and so told you, correct? In other words, that they had 12 started seeing Mr. Epstein when they were 17, and then 13 they became 18 and continued to see him-when they were 14 18 and, in tact, you interviewed them when they were 18? 15 MS. ARBOUR: Form. i 16 THE WITNESS: Some, yes. 17 BY MR. 18 Q. And they, too, are included in these book of . 19 message pads? In other words, this was not limited, the 20 incoming calls were not limited to girls that were 17 or 21 16, and included girls that were 18, 19, 20, 25 and even 22 older, correct? 23 MS. ARBOUR: Form. 24 THE WITNESS: Correct. 25 BY MR. WEINBERG: Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciutl (601-280-428-9381) Page 520_? Q. Now, when you drafted the search warrant affidavit and you agreed with me that you understood when you drafted it, as an experienced detective of almost two decades, that the judge would be relying on the content of what you presented to him, correct? A. Yes. MS. ARBOUR: Form, asked and answered. BY MR. WEINBERG: Q. That the judge did not have some external bases to test the representations, either for completeness or for accuracy? MS. ARBOUR: Form. THE WITNESS: Correct. BY MR. WEINBERG: Q. And you made representations in the search warrant affidavit that were repeated in the probable cause affidavit, did you not, that were attributed to A. Yes. Q. And directing myself to the probable cause affidavit, because that's the one that is unsealed and an exhibit in this case, you essentially said to, on the probable cause affidavit, that H.R. said that Jeffrey Epstein wanted young girls A. Yes. (56l) 832~7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana 'Ricciuti (601 -280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-938'1) 1 ?mm ?an mulliiz?.invim?ilii? ?ail-tun? 29f l8_ (561) 832?7500 Page 521 Q. correct? Do you recall that during your tape recorded interview with H.R., she told you that Jeffrey Epstein preferred to receive massages from girlS'between 18 and? 20 years old? A. I recall her stating, "The younger, the better," but I don't recall that he prefers girls between 18 and 20. Q. Will you agree with me that if the tape recording of interview with you reports that as a statement made by her, that the tape recording would be the most accurate source of what she told you back in early October 2005? I MS. ARBOUR: Form. MR. GARCIA: Do you have the tape?recording to play, because my understanding is that's under FBI control. MR. WEINBERG: I'm asking questions about whether or not it included MR. GARCIA: Without playing the tape recording, I think it's an unfair question. I'll ask it. MR. WEINBERG: You can object. THE WITNESS: If the recording indicated? BY MR. WEINBERG: Q. That H.R. told you in early October of 2005, PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 Eiectronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) 29f (561) 832-7500 Page 522 now almost five years ago, that she had said to you that Jeffrey Epstein preferred girls between 18 and 20. A. I would have documented that in the incident report, Q. Would it be an important modification of the statement attributed to her that Jeffrey Epstein wants young girls, correct? MS. ARBOUR: Form. THE WITNESS: Had she said it, but again, I don't BY MR. WEINBERG: Q. I understand. Had she said it, it certainly would have been considered important enough to include in the various affidavits that you drafted that relied in part on what H.R. told you. MS. ARBOUR: Form, the tape speaks for itself. BY MR. WEINBERG: Q. Correct? A. Correct. Q. The message pads include messages like, was wondering if she would get work tonight, she couldn't work yesterday because of some family event. That's the messages, those contents, you would have view of the message pads, correct? MS. ARBOUR: Form. It speaks for themselves. PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 ElectronicaHy signed by Jeana Ri??ciuti (601-280-428-9331) Electronicaily signed by Jeana Ricciuti (601?280-428-9331) (561) 832-7500 Page 523 THE WITNESS: Uh?huh. BY MR- WEINBERG: Q. Did you ever interview a woman named A. I attempted it, and I don't think she ever returned my calls. Q. Did you ever go to her house? A. Let me think. I may have. I mean, I can't recall if I went to her house or not, but I know I I telephoned her and I never got any call back from her. Q. Did you, during this investigation, ever, yourself, go to MySpace pages to conduct any background investigation on the various women that you were proffering to the State Attorney as reliable witnesses? MR. GARCIA: Objection, asked and answered. i MS. ARBOUR: Joined. THE WITNESS: Again, I looked at them when they were turned over, but no, I didn't. BY MR. WEINBERG: Q. I'd ask you to look at page 65 of the incident report, paragraph 4, and see if that refreshes your recollection. A. Yes, I did. Q. And do you recall just how you accessed MySpace? Did you run through a list of all your witnesses and saw whether or not certain of them had "7 . a PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Eiectronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Page 524 MySpace pages? A. Correct. Q. And you concluded that it's all redacted here, but it looks like 10 or 12 of your witnesses had MySpace pages. A. Correct. Q. And did you download the information from these MySpace pages into some evidentiary format? A. I believe either I printed them.or I might have viewed them and just made reference of it, that they had a MySpace page. Q. Did you ever study the contents of the MySpace page? A. The ones that were viewable, I looked at. The ones that weren't, eventually they all became private. Q. And the ones that were viewable, did you identify certain of your witnesses as including in their MySpace page evidence that they were involved in the use of drugs? A. I recall pictures of like a marijuana leaf, comments made of being high when the photo was taken and some alcohol use. I remember that as well. Q. And did you include those observations in your incident report that ultimately would have gone to the State Attorney to assist the State Attorney in assessing (561) 832?7506 Electronically signed by Jeana Ricciuti (601 480428-9381) Electronically signed by Jeana Ricciuti (601 ~280-428-9381) Page 525 1 the credibility of the people that you were proffering ?2 to them as witnesses? 3 A. Did I include those in with the State 4 Attorney? I believe they had them by then. That was 5 the winter of '05, '06. 6 Q. But this was an independent review of MySpace 7 that was not related to what Professor Dershowitz gave 8? the State Attorney; this was something you were 9- -reporting that you did on your own, correct? 10 A. I may have done it on my own to view it myself 11 after learning from the State Attorney's office. I'm "12 not I can't recall if I did it totally on my own?or 13 when I first heard of the MySpace pages, I researched it i 14 myself to view it myself. 15 Q. Did you do anything other than look at MySpace 16 pages to try to assess the credibility of any of your 17 witnesses based on what you could learn about them from. 18 other people? In other words, you were essentially 19 proffering to the State Attorney certain statements that 20 had been made to you regarding what occurred on El 21 Brillo Way, correct? 22 A. Uh?huh. 23 Q. And you were relying on those statements and 24 their detail as a basis for asking the State Attorney to 25 bring a criminal prosecution against a residence of Palm (561) 832?7500 PROSE COURTI REPORTING AGENCY, INC. (56 832-7506 Electronica?y signed by Jeana Ricciuti Electronicaliy signed by Jeana Ricciuti'(601 -280-428~9381) bdcd1876-c72e?432d-8cf0?b1 9a96561291 (561) 16 832-7500 PROSE COURT REPORTING AGENCY, INC. Page 526 Beach, Mr. Epstein? A. 'Yes. Q. And the question is: You went on MySpace, you looked at certain pages that reflected at least some of your witnesses who were not only using drugs but bragging about using drugs publically and publishing pictures or references to themselves as drug users, correct? A. On the MySpace page, right. Q. Right. Did you do anything else, as an experieneed investigator, to try to determine by through the investigation into the background of any of the witnesses? A. I believe I checked them under the local systems to see if they had been arrested. 1 did like a criminal background check on them and the sworn taped statement that we took as well. Q. October 20th you went to Mr. Epstein's home with a group of others; is that correct? A. Uh?huh. MR. PIKE: Yes? THE WITNESS: Yes. BY MR. WEINBERG: Q. And you went there with a search warrant A. Correct. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronicaiiy signed by Jeana Ricciuti (601 -280-428-9381) 29f (561 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) Page 527 Q. correct? And in the search warrant, you requested the authority to seize all computers, all equipment, any discs, any DVDs, any media, correct? A. Uh?huh. MS. ARBOUR: Form, asked and answered. THE WITNESS: Correct. BY MR. WEINBERG: Q. And you seized whatever you found there, correct? A. Yes. Q. And you, yourself, looked through what you could look through and asked your forensic people to look through what you couldn't look through; is that correct? A. That is correct. Q. And as a result of the search and seizure, there was no picture of Jane Doe 103 that was seized, correct? A. That's correct. Q. And there was no camera that was found in the massage room, no covert camera found in the second floor massage room of the Epstein home, correct? MS. ARBOUR: Form. THE WITNESS: No, we did not find a camera that day, no. Electronically signed by Jeana Ricciuti (501-280-428-9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) 832?7506 bdcd?i 876~c72e432d~80f0-b19aeG56129f (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Page 528 BY MR. WEINBERG: Q. The only camera you found was the camera that you knew about from your 2003 investigation, the one that was in the clock aimed at Mr. Epstein's desk and the second camera that was in the garage, correct? A. We found, yes, the second camera in the garage. Q. Did you ever, on any other day, find any camera other than the cameras you, yourself, installed in 2003 and the camera that Mr. Epstein pointed out to you in 2003 from the first floor area? A. No, we didn't see we didn?t find any other cameras. Q. And you had only been to his house, twice; is that correct? Once A. The day of the search warrant and the day that I assisted by putting-the cameras. Q. You never went back in and entered his home after October 20, 2005, did you? A. No. Q. Do you know of any audio or wire electronic interceptions that were directed against Mr. Epstein or his residence at any time by anyone? A. No. Q. There were certainly none that was connected (561) 832*7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601?280?428-9381) (561) 83 Page 529 to your State investigation? A. ,Nor Q. So nobody under your command was outside his house.at any time-trying to intercept telephone communications of any kind? 3 MS. ARBOUR: Form, asked and answered. BY MR. WEINBERG: Q. Is that right? A. Not to my knowledge, no. Q. And not to your knowledge, did anybody try to intercept electronic communications, ewmails, any other form of communication emanating from either his residence or any Internet service provider? MS. ARBOUR: Form, asked and answered. NO. MR. WEINBERG: Q. Do you recall that during the course of your investigation, before you ended.up drafting your May 1st affidavit, there was a decision made to conduct a grand jury? A. Yes, a couple of times. Q. Whether it was March or April, a subpoena was served on.Jane Doe 103 by yourself in Tallahassee, correct? MS. ARBOUR: Form, asked and answered. PROSE COURT REPORTING AGENCY, ENC. (561) 832-7506 2?7500 Electronicaliy signed by Jeana Ricciuti (601-280-428-9381) Electronicaiiy signed by Jeana Ricciuti (601-230-428-9381) Page 530 1 THE WITNESS: Yes. 2 BY MR. WEINBERG: 3 Q. At any time prior to that, did Jane Doe 103 4 ever call you and say that she was concerned about an 5 investigator? 6 A. Yes. 7 Q. And did she call do you recall when she i 8 called you? Before or after the service of the 9 - subpoena, if you remember? i 10 A. It was before. i 11 Q. And did she call you at night or in the day 12 time? 13 A. I believe she called me in the evening time 14 and left me a voice mail, and-I returned her call in the 15 morning. 16 Q. And when she left you a voice mail, where 17 would she have called, into the office, 18 A. Into the Police Department. 19 Q. Did she have your cell phone number? 20 A. I had provided the victims with a cell phone 21 number, yes. 22 Q. Was that a cell phone number that you carried? 23 A thhuhseveral cell phones you carried? 25 A Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 531 1 Q. Was it.a cell phone that was paid for by the 2 Palm_Beach Police Department? 3 A. I believe I was paying.for that-one. 4 Q. Was there a second cell phone 5 A. Herers the thing: The Town was offering us a 6 stipend onto a cell phone. I had, prior to that, a few 7 months left on another cell phone to the end of 8 contract.- So for.a time period there I carried two 9 phones until the contract expired, and at which time I 10 shut off that service and then just used the 11 Q. The phone left was the one that the Town was 12 offering you a stipend? 13 A. Yes. 14 Q. And by "the Town," do you mean the Palm Beach 15 Police Department? 16 A. Palm.Beach Police Department. 17 Q. And this was the number that you began to give 18 out to different witnesses we 19 A. That is correct. 20 Q. not only in this case but in other cases? 21 A. Correct. 22 Q. Is that a do you get copies of the cell 23 records that are connected to that phone or do they go 24 directly to the Palm Beach Police Department? 25 A. No, I receive the bill, but it's not an (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601 -280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 532 1 itemized bill. It's just a regular billshred it. 3 Q. You pay it, you shred it and then you get 4 reimbursed by the Town mm 5 A. The Town offers a flat sum_before a flat sum, a sum. And with which service provider is that? 10 00 10 10 And can you give us the number of the cell 11 phone that Jane Doe 103 that you would have given to 12 Jane Doe 103 or other witnesses during this time period? 13 A. Hold on one second. __14 MS. We're going to object. If you 15 don't want to raise this issue in terms of the cell 16 phone records on the motion to compel that's 17 pending, we can address it with the court. 18 MR. PIKE: It's noted. I 19 MS. We raised a number of statutory 20 objection to producing information regarding his 21 cell phone. 22 BY MR. WEINBERG: 23 Q. How about emmails? You mentioned 24 jrecarey@palmbeachpd [sic]. 25 A. That's correct. (561) 832?7506 (561) 832~7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601-280-428-9381)? Electronically signed by Jeana Ricciuti (601~280-42849381) Page 533 1 Q. Is that an account that you paid tor or that 2 the Palm Beach Police pays for it? 3 A. The Palm Beach Police pays for it. 4 Q. Are the copies of your e?mail on the server of 5 the Palm Beach Police Department? 6 A. Yes. 7 MR. PIKE: Can we go off the record for a 8 second? 9 MS. Yes. 10 (Discussion held off thesrecord.) 11 BY MR. WEINBERG: 12 Q. So the e?mail is jrecarey@palmbeachpd [sic]. 13 Do you have a separate e?mail account, a personal e?mail 14 account as contrasted to a public esmail account? 15 A. I do, but that's I use that for my family i 16 and nothing work?related. 17 Q. So it's your representation that none of the 18 witnesses in this case ever e-mailed to you to your 19 personal e?mail? 20 A. Never. 21 Q. And no communications from your personal 22 e?mail to Chief ReiterNope. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832m7506 ?Electronicaiiy signed by Jeana Ricciuti (601 -280-428-9381) Electronicaliy signed by Jeana Ricciuti (601 -280-423-9381) (561) 832?7500 Page 534 Q. To any State Attorney? A.r Nope. Q. To anyone associated with the investigation of Jeffrey Epstein? A. Nope. Q. Same question for your cell phones: I assume you have a cell phone other than the cell phone that you receive through the Palm Beach PD stipend. A. No. This is the only phone I use. Q. And that's the phone that's subject to the separate inquiry. How about reimbursing expenses? When you have expenses in connection with, for instance, the Epstein investigation, would there be a record of those expenses? MS .. ARBOUR: Form. THE WITNESS: We are given investigative funds to utilize an investigation, and sometimes BY MR. WEINBERG: Q. Who would give you the funds? A. sometimes the funds is issued by the Detective Bureau sergeant. Q. Would they give you a flat amount and leave to your discretion the utilization of that amount? A. No. The maximum 1 think they give you is PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana-Ricciuti (691-28?0-428-938?1) Electronically signed by Jeana Ricciutl (601-280-428-9381) 29f Page 535 1 $200, and that's to be utilized if you're going out of 2 County to pay for gas or if you run into a situation 3 with a flat tire, to get a tire replaced or repaired,- 4 that kind of thing, providing you get a receipt 5 Q. What about, you do things on video 6 surveillance and you have to continue to buy new 7 equipment to film the 24 hours a day of comings and is 8 goings of a residence; would there be records of those 9 purchases? 10 A. For equipment? A 11 Q. Yes. 12 A. I'm sure there would be. I don't recall any 13 purchases. 14 Q. How about travel, did you do any travel in 15 connection with the Epstein investigation? 16 A. Up to Jacksonville, Tallahassee, all within 17 State. You know, we didn't leave. 18 Q. You didn?t have to travel to New York or to 19 any other location? 20 A. No. 21 Q. Did you ever contact any law enforcement 22 officers in any other jurisdiction with the exception of 23 this meeting with Special Agent Ortiz and other agents 24 of the 2 5 MS. ARBOUR: Form. (561) 832?7506 (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601?280-428-9381) Electronically signed by Jeana Ricciuti (601-2804283381) 29f A Page 536 1 THE WITNESS: I think, during the 2 investigation, I telephoned New Mexico to see if 3 there was any incidences involving the ranch that 4 Mr. Epstein owns. 5 BY MR. WEINBERG: 67 Q. And what did you learn? 7 A. It was a huge ranch, but they didn't have 8 anything documented. 9 I believe I also called the NYPD to see if #10 they had any incidences involving Mr. Epstein up in New 7-11 York. 12 What did you learn? 13 A. They had nothing on file after numerous phone -14 calls up there, once someone returned your call. I 15 believe that was it. 16 Q. When you went to Tallahassee to serve the 17 grand jury subpoena to Jane Doe 103, that was a subpoena 18 that required her attendance, was it not? 19 A. Yesgiven date to come to West Palm 21 Beach and to appear in front of a grand jury being 22 conducted by the State Attorney? 23 A. Yes. 24 Q. Did you and her have any conversations 25 regarding that subpoena and her compliance obligations? A . 17:11, Wag-ray - We - - .. (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280~428~9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) bdcd1876-c72e-432d-8cf0-b1 9365561291 Page 537 1 A. I?m trying to recall what we discussed. I 2 7 served her with a subpoena and instructed her to call 3 the phone number that was on there to make arrangements. 4 Q. How long were you with her in Tallahassee on 5 this occasion? 6_ A. I'd say about 40 minutes, 50 minutes. 7 Q. And did you decide that you were to be the 8 person to serve the subpoena as contrasted to any of the 9 different people working under or with you? 10 A. Yes, I am_the one who served the other search 11 warrant subpoenas. 12 Q. So you served all of the subpoenas? 13 A. Uh?huh. 14 Q. And was that the only reason to go to 15 Tallahassee that day? 16 A. I spoke to her also regarding some phone calls 17 that she had received which she felt was threatening in 18 nature. 19 i Q. And what were the results of those 20 conversations? 21 A. She had received a phone call from -, 22 indicating to her that those that are with Mr. Epstein 23 will be compensated and those that go against him - 24 basically would be dealt with. 25 Q. We're talking about March or April of 2006, PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 (561) 832?7500 Electronically signedbyu'eana Ricciuti (601?2804288384) Electronically signed by Jeana Ricciuti (601 Page 538 1 correct? 2 A. I believe so. I documented it in the incident 3 report.- 4 Q. But, in fact, nobody got taken care of; nobody 5 ever got harmed in this case, did they? 6 MS. ARBQUR: Form. 7 THE WITNESS: Not that I'n.aware of, no. 8 BY MR. WEINBERG: 9 Q. And there's no evidence that you're aware of 10 that any persons were paid large sums of money not to 11 cooperate with you, correct? 12 MS. ARBOUR: Form. 13 THE WITNESS: Not that I'm_aware of. 14 BY MR. WEINBERGT 15 Q. So this is simply Jane Doe 103 telling you 16 what -;said,e and that was said to you on this 17 occasion where she received a grand jury subpoena, 18 right? 19 A. Yes. 20 Q. Did you ever interview 21 A. I know that Jane Doe 103 didn't want to pursue 22" the matter any further. I know I forwarded that 23 information to Lanna Belohlavek, and I also subpoenaed 24 cell phone records, which indicated phone calls 25 to Jane Doe 103 when she indicated she did get the (561) 832?7506 (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601-280?428?9381) Eiectronically signed by Jeana Ricciuti (601 -280-428-9381) Page 1 threatening-calls. 2 Q. But did you ever did - ever get asked 3 whether or not that was a statement that she had made to 4 Jane?Doe 103? 5 A. No, I didn't, again, because Jane Doe 103 did 6 not want to pursue the matter. 7 Q. So at no time was - did - testify i; 8 or provide you with any corroboration from Jane Doe 9 103's allegations that - had conveyed some sort of 710 threat to her, correct? 11 A. Again, I didn't speak to - 12 Q. Nor did anyone else in the Palm Beach Police 13 Department, to your knowledge? 7 14 A. No, except for that one time I tried to 15" interview her at her boyfriend's job. 16 Q. Nor did any State Attorney, to the best of 17 your knowledge? 18 A. No, not that I'm aware of- 19 Q. Now, this was the last time you saw Jane Doe 20 103? 21 A. I believe there was there were two grand 22 jury subpoenas. Yes, this would have been the last time 2 23 I met with her. i 24 Q. Did you reserve her for the second, the summer 25 grand jury? (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428~9381) they could serve the subpoenas. Q. time? A. Q. regarding that the second grand jury conflicted with her school schedule? A. Q. subpoena? A. A. A There was interview her. The second time I went up to see her, it was in Tallahassee. That one time that I went up there to serve her, we discussed the - issue, but I Page 540 The second time, I provided the State where And to your knowledge, was she served a second I have no knowledge. Do you recall any conversations with her That is correct, yes. But that was in response to her receiving a Yes. I went to Tallahassee, correct: So you went to Tallahassee a second time? Yes. To serve her with a second subpoena? I think the trip I'm confusing the trips. a trip that I went up to Jacksonville to didn't go back the third time. (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Somebody else served her, to your knowledge? It would have been the State Attorney's And as a result of her being served a second (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-423?9381) Electronically signed by Jeana Ricciuti (601?280-423we381) bdcd1876-c72e-432d~8cf0-b1 9a96561 291 Page 1 time, did she have a conversation with you regarding the 2* second subpoenafs conflicting with her finals schedule? 3 A. Corrects 4 Q. And she made a phone call to you to complain 5 about the service? 6 A. Correct. 7 Q. 'And what was the conversation between Jane Doe 8 103 and you on that occasion? 9 A. It was finals week and she could not leave and 10 not take her final to come down for the grand jury. I 11 recommended that she contact the State Attorney's office 12 and make recommendations through the State Attorney's . 13 office. 5 14 Q. And did you have any followup with her to see 15 if she had been formally excused from the grand jury by 16 the State Attorney? 17 At, No, I did not. 18 Q. Did you learn that she didn't show up at the 19 grand jury? 20 A. Yes. 21 Q. Did you learn that she had not been excused by 22 the State Attorney? 23 A. I doth think she officially came out and told 24 me that she was not excused. 25 Q. But you do know that she failed to appear? Electronically signed by Jeana Ricciuti (601 -280-428-9381) Eiectronically signed by Jeana Ricciuti (601-280-428-9381) Page 542 1 A. Yes. I was there. 2 Q. In response to a subpoena, correct?' 9 3 A. Yes. I was there. 5 4 Q. And did you know whether or not she had had 5 any conversations with anyone other than you about her 6 belief that her finals needed to be attended to rather 7 than a grand jury subpoena? 8 A. That she 9 Q. In other words, did you ever speak to the 10 State Attorney that she had gotten a pass on appearing 11 in front of the grand jury because of her school 12 schedule? 13 A. Oh, I have no idea. 14 Q. All you do know is that the State Attorney was 15 waiting for her and she didn't come? 16 A. I don?t know if she was waiting for her, 17 18 Q. Didn't they expect her to appear and testify 19 in response to the subpoena and she failed to appear 20 that day? 21 A. Again, I don't know the conversations that she 22 had with the State Attorney's office. I do know that 23 she relayed that information to me. I told her to relay 24 that information to the State Attorney's office. I 25 was (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Page 543 Q. Did you empathize with her conflict? A. Absolutely. Q. And did you in any way tell her that, I understand that your finals are important and you should tell the State Attorney that you can't come? A. I explained to her that she needed to contact the State Attorney's office and make arrangements through the State Attorney's office. Q. You encouraged her to get excused from the grand jury subpoena? MS. ARBOUR: Form. THE WITNESS: I recommended that she contact the State Attorney'Stoffice and let her know what was going on as far as her finals. BY MR. WEINBERG: Q. And whether she did or didn't, you have no knowledge? A. No, but I was present during the entire grand jury, so I knew she wasn't Q. That she didn't come? A. (Non?verbal response). Q. And you don't recall any conversation where Lanna or any State Attorney informed_you that she had authorized Jane Doe 103 not to comply with the grand jury subpoena? Electronically signed by Jeana Ricciuti (601 -280-428-9381) Electronically sig ned- by Jeana Ricciuti (601 -280-428~9381) 29f (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 544 A. No, I don't recall any of those conversations. Q. Toll records, you examined some toll records in this case, did you not, telephone toll records? A. Do you mean itemized records? Q. Yes. A. Yes. Q. And, for instance, you told us there was a record between Jane Doe 103 and - Q. And there were records between H.R. and Sarah Kellen, correct? A. Correct. Q. And it's fair to say that those toll records establish connections between two phones, correct? A. That is correct. Q. They don't tell you who was on either end, do A. No. Q. They don't tell you the content of the call, correct? A. No. Q. They tell you how long the call was and phone numbers connected, but not the content of the call, correct? A. No, not the content. Date and time. Electronically signed by Jeana Ricciuti (601 -280-428-9381?) Electronically signed by Jeana Ricciuti (6011280-428?9381) Page 545 1 Q. Anywhere in your investigation, were you ever 2 a participant in or hear any phone calls between any of 3 the witnesses in this case? 4 A. In other words 5 Q. Let me ask it another way. Did you ever, in 6 any way, receive a tape recording of any telephone call 7 engaged in by Sarah Kellen? 8? A. No. 9 Q. And certainly never received or heard a tape 10 recording of Jeffrey Epstein, correctanyone else who was associated with the El 13 Brillo residence, correct? 14 A. No. 15 Q. The only evidence you have of what transpired 16 during any call is the message pad and what somebody 17 told you happened during a call, correct? 18 MS. ARBOUR: Form. 19 THE WITNESS: And the toll records. 20 BY MR. WEINBERG: 21 Q. And the toll records. Okay. 22 Now, after the grand jury returned a charge 23 against Mr. Epstein, you conducted a followup 24 investigation, did you not? 25 A. The followup investigation was initiated by, PROSE COURT REPORTING AGENCY, INC. (561) (561) 832?7500 832-7506 Electronically signed by Jeana Ricciuti (601 ?280-428?9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) bdcd1876-c72e-432d-8cf0-b1 93e6561 29f (561) 832?7500 Page 546 now, Sergeant Dawson, but back then it was Detective Dawson. Were YOU a participant in that Second investigation A. Yes. Q. that has a separate case number, an 7'06 number instead of an '05 number? A. Correct. Q. And that investigation lasted until when? A. Not very long. It lasted up to when the Feds 'came in and basically took over. Q. Again, I think you said the last time when the FBT?comes in, it becomes a one~way street? A. That is correct. Q. And that's been your 20?year experience as a State law enforcement officer? A. Correct. Q. And yet, this case, ironically, the Feds were invited in by you and Chief Reiter, correct? MS. ARBOUR: Form. THE WITNESS: Correct. BY MR. WEINBERG: Q. And this is the first time you've invited the Feds into a State investigation? A. I've been a participant in other PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) bdcd1876-C726432d-80f0-b1 9a9656129f Page 547 1 investigations where the Feds have come in and worked 2 with us, and I've assisted them in 3 Q. Sure. But this is the first case where you've 4 conducted an over?one?year State investigation of an 5 offense that occurred at a residence in Palm Beach and 6 that the chief of police of your department brought this 7 case to the Federal government; is that correct? 8 MS. ARBOUR: Form. _9 THE WITNESS: Like I said, we've worked with 10 the FBI. Is that what you're trying to get at, in 11 the past? 12 BY MR. WEINBERG: 13 Q. Bringing the case to the FBI, this is what's 14 unusual in this case is the chief of police not i 15 . accepting the charged decisions made by the State 2 16 Attorney, brought this investigation over to the United 2 17 1 States Attorney's officeu That's a first for you, isn't 18? it? i 19 MS. ARBOUR: Form. 20 THE WITNESS: There were many firsts in this 21 case. 22 BY MR. WEINBERG: 23 Q. This was one of them? 24 MS. ARBOUR: Form, asked and answered. -25 THE WITNESS: There was 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 (561) Electronically signed by Jeana Ricciuti (601 ~280-4-28-9381) Electronically signed by Jea na Ricciuti (601 2230-4213-9381) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Page 548?; MS. Is there a question pending? MR. WEINBERG: Yes. BY MR. WEINBERG: Q. One of the firsts in this case was that this was the first time that your chief of police brought the case to the Federal government after a year of State investigation, correct? MS. ARBOUR: Form, asked and answered. THE WITNESS: I believe so. BY MR. WEINBERG: Q. Now, Mr. Epstein stays at El Brillo, and he's there on a periodic basis, at least until this case ended up in the Criminal Justice System, correct? He would come there at times and be absent at times, correct? A. Yes. MS. ARBOUR: Form. BY MR. WE INBERG: I Q. And the investigation began in March; is that right? A. Yes. Q. And there was an allegation made by -, and resulted from a phone call by her parents, correct? MS. ARBOUR: Form, asked and answered. THE WITNESS: Yes. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601?280?428-9381) Page 549 1 BY MR. WEINBERG: 2 And then there were trash pulls that, in some 3 respects, were believed to included objects that you 4 thought were reflective of anal sex, correct? 5 MS. ARBOUR: Form, asked and answered. 6 Yes. 7 BY MR. WEINBERG: 8 Q. Yet, there was no attempts to arrest 9 Mr. Epstein in April of 2005, were they? 10 A. Again, that was when Detective Pagan had that 11 case. 12 Q. I?m_not being critical of you. 13 A. No, I?m just saying I don't know. I don't l4 know back then what she did. 15 Q. Well, you have access to her case file, do you 16 not? 17 A. Right. 18 Q. And you, in fact, on September 22nd, asked 19 that the case file be provided to you so that you, as an 20 experienced investigator, could learn from the history 21 of this case, correct? 22 MS. ARBOUR: Form, and asked and answered. 23 THE WITNESS: Correct. 24 BY MR. WEINBERG: 25 Q. And you knew for six months following the - (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronicaiiy signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) bdcd1876-c729?432d-8cf0-b?1 9ae656129f (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 550 allegation, there was no attempts to charge Mr. Epstein or arrest Mr. Epstein in March, April, May, June, July, August and into September of 2005, correct? A. Correct. Q. And then you picked up this case in late September of 2005, correct? A. Correct. MS. ARBOUR: Form, asked and answered. BY MR. WEINBERG: Q. And you interviewed H.R. in the first week of October 2005, correct? ARBOUR: Form, asked and answered. THE WITNESS: Correct. BY MR. WEINBERG: Q. And H.R. gave you certain corroborating information that confirmed the information that -had i given you about their joint visit in early '05 to Mr. Epstein's home? A. Correct. Q. Correct? That led to a request for a search warrant rather than a request for an arrest warrant, correct? A. Correct. Q. And surveillance continued on Mr. Epstein's home on occasion when you knew he was in town? Electronically signed by Jeana Ricciuti (601-280-428*9381) Electronicaily signed by Jeana Ricciuti (601-280-428-9381) 9a9656129f Page 551 1 A. Yes. i 2 Q. And trash pulls continued, correct? 3 A. Correct. 2 4? Q. And your investigation disclosed that the 7 ?5 young women going to his home were more than just - 6" and H.R., correct? 7 A. Correct. 8 Q. And yet there was no arrest warrant in October 9 or November or December brought against Mr. Epstein, 10 correct? 11 A. Correct. . 12 Q. And no attempt to initiate a criminal charge 13 -against him through the end of the year 2005? ';14 A. Correct. 15 Q. In the beginning of 2006, you continued to 1.6 conduct interviews of women, including -, correct? 17 MS. ARBOUR: Form, asked and answered. - 18 THE WITNESS: Yes. 19 BY MR. WEINBERG: I 20 Q. You continued to do garbage pulls, correct? 21 As In '06, I don't know if we continued to do 22 trash pulls. 23 Q. You continued to do surveillances, on 24 occasion, of Mr. Epstein's home? 25 A. On occasion, I believe. i (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601 -280?428-9381) Page 552 1 Q. Studied the results of the seizures of 2 October 20th to try to augment your investigation? 3 MS. ARBOUR: Form. i 4 THE WITNESS: We went through the evidence 5 collected, if that's what you're trying to get at, i 6 yes. 7 BY MR. WEINBERG: 8 Q. And yet the first time you executed a probable 9 cause affidavit was May I, 2006, correct? lO MS. ARBOUR: Form, asked and answered. ll THE WITNESS: Correct. 12 BY MR. WEINBERG: 13 Q. And the first time Mr. Epstein was charged was 14 late in the summer or during the summer or 2006 by the 15 turn of an indictment for solicitation by the grand l6 jury, correct? 17 A. Correct. 18 Q. Now, have you ever spoken to any reporters 19 from outside the Palm Beach area 20 MS. ARBOUR: Form, asked and answered. 21 BY MR. WEINBERG: 22 Q. regarding Mr. Epstein? 23 MS. ARBOUR: Same objection. 24 THE WITNESS: No. I know we received a lot of 25 phone calls. We received a lot of phone calls from PROSE COURT REPORTING AGENCY, INC. (561) 832?7500 (561) 832*7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428?9381) Page 553 1 different reporters. 2 BY MR. WEINBERG: 3 Q. Do you know whether or not Mr. Reiter was in 4 touch former Chief Reiter was in touch with various 5 reporters? 6 A. I don?t believe so. 7 Q. Did he talk to you about having been 8 interviewed by Mr. Connolly from Vanity Fair? 9 A. Not that I'm aware of. 10 Q. Did he talk to you about being interviewed by 11 anyone from the New York Daily News? 12 A. No; 13 New York Post? 14 A. -No. 15 Q. "New York Times? 16 A. (Non?verbal response)1 17 Q. Any other magazine? 18 A. No, sir. 19 Q. Any local reporters from the media here? 20 A. Not that I?m aware of. 21 Q. TV broadcasters looking for news about i 22 Mr. Epstein? I 23 A. Not that I'm aware of. 24 Q. Would it surprise you if there was e~mai1 25 traffic between Chief Reiter and some of the local (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280?428-9381) Electronically signed by Jeana Ricciuti (601-280-428?9381) bdcd1876-c72e?432d-8cf0?b1 Sae6561 291 Page 554;; 1 reporters and media broadcasters? 2 MS. ARBOUR: Form. 3 THE WITNESS: I wasn't privy on who he I 4 mean, obviously, he's 5' BY MR. WEINBERG: He's the chief. he's the chief, you know. You're the detective. 00 K) E) Exactly. 10 Q. Let me run through a couple of additional i 11 investigators and see whether you actually have ever had 12 conversations with them, and if you have, then follow it i 13 up with whether those conversations addressed any part I 14 of this communication. I 15 Richard Fandrey? 16 No. 17 Kenneth Jenne? 18 No. 19 Patrick Roberts? 20 No. 21 Christina Kitterman? 22 Uh?uh. . 23 Michael FistenAnd again, do you have any knowledge that PROSE COURT REPORTING AGENCY, INC. (561) 832?7500 (561) 832?7506 Electronically signed by Jeana Ricciuti (601 480-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) (561 832?7500 Page 555 i several of these investigators went to Mr. Epstein's property and entered it at or around 10:00 to 10:30 on March 17, 2010, dressed in black and leaving in a vehicle registered to an investigator named Richard Fandrey? MS. ARBOUR: Form. THE WITNESS: No, sir. BY MR. WEINBERG: Q. Do you have any knowledge that there was surveillance of an entry onto Mr. Epstein's property by private investigators connected to this case on any' occasion? A. No, sir. I was under the assumption that Wackenhut was still protecting the property. Q. After Mr. Epstein entered his piea and began his service of his sentence, did you receive any followup requests for you to conduct investigations of him? A. Again, I received a phone call from Mr. Edwards pertaining to a victim_that was not in the original report. I referred him over to the FBI. Q. Did anyone in the FBI ask you to conduct any followup investigation of Mr. Epstein? A. No. Q. And that includes the time he was in jail? Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) PROSE COURT REPORTING AGENCY, INC. (561) 832m7506 'control? (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. Page 556 i (Non?verbal response). The time he was on work release, no request? 5 5 None. Q. The time he was on probation, community A. No. Q. So you've never received an FBI request to, in any way, investigate Mr. Epstein? A. No. Q. Surveille Mr. Epstein? A. No. Q. Report to them any of your knowledge of Mr. Epstein's ongoing conduct? A. No. Q. Same question for the US Attorney's office: Have they ever initiated a call to you at any time after Mr? Epstein went to jail asking you to do anything in connection to their ongoing investigation of Mr. Epstein? A. Absolutely not. Q. And what about Probation? Has Probation ever asked you to initiate any surveillance or investigation of Mr. Epstein? A. No. Aside from that one day that I saw him walking on the along South Ocean Boulevard, that was (561) 832?7506 Electronicallyisigned by*Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601 ?280-428-9381 )7 Page 557 1 it. That was the only and I didn't even contact 2 Probation. I believe Captain Prick (phonetic) is the 3 one who contacted Probation and something Sloan 4 (phonetic). 5 Q. Are you aware of any putting yourself aside 6 and putting this one incident aside, are you aware of 7 the Palm_Beach Police Department having any ongoingzrole 8 in the investigation of Jeffrey Epstein? 9 A. As far as today? 10 Q. Yes, as of today. 11 A. No. 12 Q. How about at any time over the past year, 13 starting with the time he was out on work release and i 14 thereafter on community control 15 A. There did no 16 Q. house arrest? 17 Al investigation, not that I'm aware of. 18 Q. Is the one occasion the only time that you or 197 anyone working with you spoke to Probation about 20 Mr. Epstein's ongoing activities? 21 A. That was the only time I think 22 Q. That you were involved? 23 A. Yes. 24 Q. And is it the only time that you are aware 25 that anyone else has had communications to and from the (56-1) 832""7'500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by J'eana Ricciuti (601-280-428?9381) Eiectronicaliy signed by JZeana Ricciuti (601-2804283381) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Page 558 Probation Department? A. As far as I'm concerned, yeah. As far as I know. Q. On that occasion, he was how far from.his home when you saw him? A. From El Brillo to Clark and the ocean, I'd say about a mile, mile and a half. Q. And Clark is north of El Brillo? A. Yes, north of Royal Palm Way. Q. And in other words, coming this way from Mr. Epstein's house, from south to north? A. Yes. Q. A. res. Q. And Mr. Epstein's office.is north of his house, correct? A. Northwest. Q. Northwest, so north and then west. You'd have to go over a bridge, right? A. Right. Q. And the bridge that's closest to his office is north of his house? A. Actually, this one right here, Okeechobee. Okeechobee Boulevard right here. Q. So he would go over Okeechobee Boulevard and (561) 832?7506 Electronically signed by Jeana Ricciuti Electronically signed by Jeana Ricciuti (601 480-428-9381) bdcd1876-c729-432d?8cf0-b1 9ae$56129f Page 559 1 end up at his office, and Clark is between El Brillo and 2 Okeechobee Boulevard, correct? 3 A. Actually, Clark is north of Okeechobee 4 Boulevard. 5 Q. So is there a second bridge just to the north 3 6 of Okeechobee? A 7 A. Yes, there is a north bridge. I 8 Q. What's the name of that bridge? 9 A. The North Bridge. - 10 Q. And that's a bridge that comes west from Palm 11 Beach? 7 12 A. Yes. 13 Q. And ends up in this community of offices that 14 includes Mr. Epstein's office? 15 A. If his office was in Mr. Goldberger's office, 16 the quickest route would have been on Okeechobee. 17 Q. But one of the route you have to get off 18 the beach, right? 19 A. Correct. 20 Q. And there's two bridges that are connecting 21 the beach to the Palm Beach financial district, one 22 being Okeechobee and one being the bridge to the north 23 of it? 24 MS. ARBOUR: Form, asked and answered. 25 THE WITNESS: Right. There is one south, too, PROSE COURT REPORTING AGENCY, INC. (56 832?7506 (561) 832?7500 Elestronically signed by Jeana Ricciuti {-601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381l 715 -(561 MR. WEINBERG: Page 560 I?m sorry. I didn't want to just make you think there was only two bridges. Q. A. BY MR. WEINBERG: .Qn A. the victims, some of my supplements that were saved onto the thumb drive. That was turned over to the FBI. Q. also in the public records of the Palm Beach Police Department, or were there additional A. 832?7500 (D K) K) E) PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 That?s way south. That's southern. MS. ARBOUR: Objection, form. You had a thumb drive that you gave to the Yes. And the thumb drive consisted of what? The thumb drive consisted of photographs of Are those records that are on the thumb drive Those were actually my personal thumb drives. Those were your personal thumb drives? Yeah. Was everything on it also in the case file? Yes. So the photographs are in the case file? Yes. And these photographs came from driver's Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9331) bdcd1876-c729-432d-8cf0?b1 9a9656129f (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Page 561 5 license photos of the different witnesses? A. Driver's license photos and some of the yearbooks that were collected. Q. Were there surveillance of Mr. Epstein's residences? Have you seen them since September of 2005? A. What do you mean "surveillances"? Q. When you, assuming there were videos taken of Mr. Epstein's residence A. Correct, yes. Q. it showed the comings and goings of him? A. Correct. Q1 And did you watch them? I saw some of them, yes. Q. And did it show any particular people going into Mr. Epstein's home that you identified? A. Yes,_and she was subsequently interviewed as well. Q. And what was her name, if you remember? A. M.E., M.E. She was overagethe group of people that was over 18? A. Correct, and an aspiring model. She brought her portfolio over and did some minor modeling at the house. Q. Anybody else seen on these videos entering a Electronically signed by Jeana Ricciuti (601-2804286381) Electronically signed by Jeana Ricciuti (601-280-428~9381) bdcd?l (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Page 562 residence Mr. Epstein's residence? A. I'm trying to think. I can't recall. It's been a while since'Iive seen those. Q. Was Ms. M.E. somebody that was interviewed by you in '05 or '06? A. It might have been '06,when I interviewed herthe over 18 people that A. Correct. Q. that you ended up interviewing in phase two of your investigation of Mr. Epstein? MS. ARBOUR: -Form, asked and answered. THE WITNESS: Yes. BY MR. WEINBERG: Q. And you interviewed about how many people that told you they engaged in consensual.adult activities with Mr. Epstein? MS. Form. THE WITNESS: It's tough to say: I don't know, less than ten. I don't know. BY MR. WEINBERG: Q. And of the other people, taking Jane Doe 103 out and taking out the one other person who you mentioned who had the digital penetration that stopped when she withdrew, the other people told you that they consented to go to Mr. Epstein's home, correct? (561) 832*7506 Electronically signed by Jeana Ricciuti (601 -280-428-9381 Electronically signed by Jeana Ricciuti (601 -280~428-9381) 291 (561) 832?7500 BY MR. WEINBERG: Page 563 2 MS. ARBOUR: Form. THE WITNESS: Well, what do you mean "consented"? Q. They did so voluntarily. MS. ARBOUR: Same objection. THE WITNESS: Right. Nobody was bound and 'gagged. BY MR. WEINBERG: Q. Not only bound and gagged, but they made a decision that they were MS. Form, asked and answered. THE WITNESS: Right, they were going to go to the house. BY MR. WEINBERG: Q. And they, one way or the other, drove to Mr. Epstein's residence from wherever they lived or worked? MS. ARBOUR: Form, and asked and answered. BY MR. WEINBERG: Q. Is that correct? MS. ARBOUR: Same objection. THE WITNESS: Some of them took taxis. BY MR. WEINBERG: Q. Some of them got driven by friends and some of PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronicaily signed by Jeana Ricciuti (601-280?428-9381) bdcd1 876-c729432d?Bch-b19a9656129f Page 564 1 them drove themselves, correct? 2 MS. ARBOUR: Form, asked and answered 3 THE WITNESS: Correct. 4 BY MR. WEINBERG: 5 Q. And they all made a decision to drive their 6 cars or get into a taxi to be driven or to get into 7 their friends' cars to go to El Brillo Way? 8 7 MS. ARBOUR: Form, and asked and answered. 9 THE WITNESS: Correct. 10 BY MR. WEINBERG: 11 Q. They then told you, as a matter of routine and 12 practice, that they either were dropped off, parked 13 their cars and entered the first floor of Mr. Epstein's 14 home, correct? 15 MS. ARBOUR: Form. 16 THE WITNESS: Correct. 17 BY MR. WEINBERG: 18 - Q. They went inside and were greeted by someone 19 and often brought upstairs to the second floor, correct? 20 MS. ARBOUR: Form, and asked and answered. 21 THE WITNESS: Correct. 22 BY MR. WEINBERG: 23 Q. H.R., for instance, when you interviewed her, 24 said that on her first occasion, she was taken there by 25 a friend, went in the first floor door and was taken (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 ElectronicaHy signed by Jeana Ricciuti (601-280-428-9381) Electronicaily signed by Jeana Ricciuti (601-280-428?9381) bdcd1876-c729-432d-8ch-b1 93196561 29f Page 565 1 upstairs to the second floor, correct? a 2 A. Correct. 3 Q. rShe told you she gave Mr. Epstein a massage, 4 correct? A 5 .A. Yes. 6 Q. She told you Mr. Epstein perceived that she 7 was uncomfortable giving him a massage? 8 A. Yes. 9 Q. And that Mr. Epstein told her she didn't have 10 to or shouldn't not didn't have to strike that 11 but she wouldn't be asked to do what she was 12 uncomfortable with a second time? 13 MS. ARBOUR: Forms 14 THE-WLTNESS: Correct. 15 BY MR. WEINBERG: 16 Q- H.R., thereafter, said that she brought six 17 people to Mr. Epstein?s home? 18 A. Correct. 19 Q. And H.R. told you that on each and every one 20 of them, she told them.precise1y what they were going to 21 be asked to do, which was to give a massage to 22 Mr. Epstein in various states of undress, correct? 23 MS. ARBOUR: Form, and asked and answered. 24 THE WITNESS: Yes. 25 2:13; (561) PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601?280-428-9381) . Electronically signed by Jeana Ricciuti (601-280?428-9381) bdcd1876-c72e-432d-8cf0?b1 9ae6561 29f (561) PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Page 566 BY MR. WEINBERG: Q. And that they would be paid for it? A. Yes. MS. ARBOUR: Form, and asked and answered. BY MR. WEINBERG: Q. H.R. also told you that she told them to represent themselves as 18 years old, correct? MS. ARBOUR: Form. THE WITNESS: I don't know if she said that they have to be 18, unless if it's documented in the report, then it is. BY MR. WEINBERG: Q. At least some of the girls told you that, in fact, they told Mr. Epstein they were directed to tell Mr. Epstein they were 18 and, in fact, they did? MS. ARBOUR: Form. THE WITNESS: I know that on several occasions, some of the girls said, you know, that they knew that Mr. Epstein knew that they were in high school, that they were asked what high school they attended, what grade they were in, that kind of thing. BY MR. WEINBERG: Q. And other girls, like -, told you that they were told that they needed to say they were 18, they Electronically signed by Jeana? Ricciuti (601-2-80-428-9381) Electronically signed by Jeana 'Ricciuti (601 -280-428-9381) 9ae656129f (561) 832?7500 Page 567 needed to represent themselves as 18 if asked, and that she did represent herself to be an 18?year?old when she made her single visit to Mr. Epstein's home in the early part of 2005, correct? - MS. ARBOUR: Form, and asked and answered. THE WITNESS: That's the interview that Detective Pagan conducted. Can I just have two minutes? (A brief recess was taken.) BY MR. WEINBERG: Q. FBI agents, you had several meetings with them after this meeting with Special Agent Ortiz? Al I believe I had one more meeting with Kirkendahl and someone else. Q. Do you recall where that meeting occurred? A. I believe it was at the US Attorneyls office. Q. In Palm_Beach? A. West Palm. Q. West Palm? And was that a meeting at which you reviewed the evidence that you then collected pursuant to your role as the case agent in charge of the '05 Epstein i case? A. I believe I gave Agent Kirkendahl a summary of the case. There was another agent in there, I can't PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280?428-9381 Electronically signed by Jeana Ricciuti (601-280-428-9331) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 568 recall his name. - Q1 Does Jason Richards ring a bell? A. Jason came in after the fact, but there was someone else in there. Jason wasn't present in that meeting. Q. And this was the second meeting, the first one being with the Chief and Ortiz A. Correct. Q. and the other one being with Kirkendahl and the second agent; is that correct? A. Correct. Q. And this meeting got more detailed in terms of your giving the FBI agents, in essence, an overview of the results of your State investigation? A. Correct. And did you give them evidence at this time? A I don?t believe so. Q. Did you review evidence with them? A I might have had with me a small case file which had flight logs which had some of the flight logs, that I may have shown them. Q. And those would have been flight logs that would have derived from where? A. Mr. Dershowitz. Q. Was Mr. Dershowitz brought the flight logs to Electronically signed by Jeana Ricciutl Electronically signed by Jeana Ricciuti (601 ~280-428~9381) bdcd1 Page 569 the State Attorney? 2 A. Correct. 3 Q. And that was in connection with his efforts to 4 persuade the State Attorney that the State Attorney Km 5 should reject the initiatives of the Palm Beach Police 6 Department for more serious charges? 7 A. I believe so. 8 Q. And do you recall reviewing the message pads 9 at any time with the FBI agents? 10 A. I may have had some copies. Like I said, I 11 had a small case file; that I didn't bring the entire 12 case. I may have had some. 13 Q. And there would have been some report on the 14 chain of custody log regarding your having checked out 15 various exhibits to review and then return; is that 16 A possible? 17 AJ What I had was copies. 18 Q. So I'm showing you a supplement for a chain of 19 custody, a Palm Beach property receipt. And if you 20 would just refresh your recollection from.the lower two 21 lines and see if that provides us with some reflection 22 regarding the review of evidence. 23 A. Correct. 24 And what does that tell you now that your 25 memory is refreshed? (561) 832-7506 832w7500 PROSE COURT REPORTING AGENCY, INC. (561 Electronicaliy signed by Jeana Ricciuti (601 -280-428?9381) Electronically signed by Jeana Ricciu? (601-280-428-9381) Page 570 1 A. I signed it out on the 3rd and returned it on 2 the 4th. 7 3 Q. .And what did you sign out on the 3rd? i 4 A. Items No. 1 through 5, 8 through 12, 5 through And these were items that reflect evidence 7 .. that was seized on October 20th from Mr. Epstein's home? 8 A. Right. It would probably be the page right 9 before this one. 10 Q. And you checked it out on the 3rd and returned 11 it on the 4th because you wanted to view it with the 12 is that correct? 713 I A. Correct. 7 14 Q. And that's October 3, 2006, correct? 15 A. Correct. 16 Q. And if we then go back to what has been 17 separately admitted into evidence here I don't recall 18 the exhibit number, but I'm showing you what appears to 19 be a property receipt dated October 20th that has 20 numbers 1 through 58, and ask you whether or not those 21 four handwritten pages, numbered 1 through 58, are the 22 log of evidence that was taken from Mr. Epstein?s home 23 on October 20th, pursuant to your execution of the State 24 search warrant. 25 A. Correct. PROSE COURT REPORTING AGENCY, INC. (561 (561) 832?7500 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601 -280~428-9381) 29f Page 571 1 Q. And the numbers that appear on that inventory 2 7 log as having been checked out August correspond to the numbers that are on the 4 inventory from the search of October 20th, correct? 5 A. Correct. _6 Q. And so it's clear from reading those two 7 documents together, that on October 3rd strike 8 I that on August 3, 2006, you were reviewing with the 9- FBI the results of your search and seizure dating back 10 to October 20, 2005, correct? ""11 AJ Correct. 7 12 Q. And you were showing them things like message 13 pads, correct? 14 A. Correct. 15 Q. And you were informing them that the message 16 pads, in some respects, corroborated what you informed 17 7 them_were the results of your witness interviews?7 18 A. Correct. 19 Q. And you, in essence, were using the evidence 20 that came from Mr. Epstein's home to demonstrate that 21 there was support for these narratives that were given 22 to you by your various witness interviews that you began 23 to conduct in October of 2005, correct? 24 A. Correct. 7 25 Q. And 1 through 5 are largely the phone message (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832""7506 Electronically signed?by Jeana ?Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciutl (601-280428-9381) Bast-3561291 (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 572 book from the kitchen, the phone message book from the Is this your handwriting? office off the kitchen, the file folder of messages, shredded paper from_the office, an orange folder marked ?Messages,"hcorrect? A. Correct. Q. And then in addition, there were pictures 3 A. I think the orange folder was massages. 2 Q. Marked "Message," it says here, A. Okay. i Q. right? A. No. Q. Okay. And then there were photos that are numbered 8 through 12. If I can since I don't have a second copy of this, do you mind if I just read with you A. Absolutely. Q. so we can shortcut this already afternoon? 8 through 12 are the photos of difference pictures taken from Mr. Epstein's home. A. Correct. Q. And then 15 through 17 were more photos and more message books taken from the first floor, correct? A. Uh?huh. Electronically signed by Jeana Ricciuti (601-2804286381) Electronically signed by Jeana Ricciuti (601-280-428-9381) bdcd1876-c729-4326-8ch?b1 9ae6?56129l (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561 Page 573 Q. And then you checked out 20 through 22, which was photos from his-desk and from a table in the first floor office? A. Correct. Q. And then you went to 26 to 30, which were more pictures, transcript? That's Jane Doe 103, I assume? A. Correct. Q. So videotapes of what turned out to be adult pornography, correct? i A. Yes. i Q. More pictures? A. Yes. Q. And then 49 and 50 were two message books, correct? A. Correct. Q. And they came from the separate standalone residence that is called the guest house, correct? A. Correct. Q. And those ultimately were message books that were in the possession of one of Mr. Epstein's employees, correct? A. The houseman, yes. Q. But they were returned to the houseman; is that correct? A. The message books? It would indicate there if 832?7506 Eiectronicaily signed by Jeana Ricciuti Electronically signed by Jeana Ricciuti (601-280-428-9381) 291 Page 574 1 they were returned. 2 Q. Do you recall whether they were returned with 3 the rest of the houseman's-possessions? 4 A. I don't believe so. 2 5 Q. What was returned to the houseman were copies 6 kept by the Palm Beach Police Department? In other 7 words, were they copied and the originals were returned 8 to the houseman? 9 A. No. Items that belonged to the houseman were 10 returned right to the houseman. 11 Q. And no copies were kept by the Palm Beach 12 Police Department? 13 A. No. 14 Q. And therefore, none were turned over to the 15 FBI when they executed their later subpoena, correct? 16 A. They all-were turned over. 17 Q. To the houseman? 18 A. To the FBI. 19 Q. So the FBI got copies of everything that 20 appears on items 1 through 58 of the search warrant 21 inventory? 22 A. Items that belonged to Mr. Janusz were given 23 back to him. His personal computer, his external media, 24 his photo discs for his camera, those were returned. 25 Q. Was his computer reviewed before it was (56l) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601 -280-428~9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) bdcd1876-c7Ze-432d-8cf0-b1 939656129f Page 575 1 returned? 2 A. Yes, 3 - And it was, in other words, your forensic team 4 or your Sheriff's forensiC'team 5 A. The Sheriff's office. 6 reviewed the computer? 7 A. Correct. 8 I Q. And by reviewing the computer, they image the 9 computer, do they not? 10 A. Uh?huh. 11 Q. And they look through the image in order not A 12 to upset the authenticity of the different files and 13 folders that were in the original seized computer, 14 correct? 15 A. Correct. 16 Q. Because you didn't know what was in the 17 computer, did you? 18 A. Correct. 19 Q. So in the event there was something there that 20 would be evidence, you didn't want to copy it and change 21 the modification dates by looking at the original; is 22 that right? 23 A. Correct. 24 Q. So what happens is that the forensic team's 25 law enforcement, what they did in this case, they imaged (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832w7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 576 the Dell computer that was taken from the guest house? i 2 A. Correct. 3 Q. The image of the Dell computer was reviewed, 4 correct? - 5 A. Correct. 6 Q. As were different CPU units that were seized, 7 one on the first floor and one on the second floor of 8 Mr. Epstein's residence, correct? 9 A. I believe there was only one on the first 10 floor. I don't believe there was one on the second _11 floor. 12 Q. So there was an additional CPU unit. What iS? 13 a 2 14 A. Like, a computer processing unit. 15 Q. And that was imaged as well, correct? 16 A. Correct. 17 Q. And the image was looked through there as 18 well? 19 A. Correct. 20 Q. And the only piece of evidence that you 21 thought might be of value was a very hazy, dim lighted 22 picture of someone that might be 23 A. Correct. There was video images of that. 24 Q. But you couldn't tell for sure and, therefore, 25 you'd be candid with us and say, I'm not 100 percent (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601~280~428-9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) (561) 832-7500 sure that it was A. It might be somebody else. Page 577 Q. And that was the CPU that connected to the first floor camera, correct? A. Correct. Q. And that was the same CPU that was seen in 2003 to reflect the identify of the thief that was stealing the money from Mr. Epstein's desk? A. Possibly. Q. It was the same connection? There was a camera on the first floor directed at Mr. Epstein's desk? Correct. And the photos went into a separate unit? A A. Correct. That, I do remember. And there was nothing of value that was seen in Mr. Epstein?s first floor desk or office that was recorded by this camera that was in the clock, correct? A. Correct. Q. No sex, no massage, just a man at his desk? A. Correct. Q. Now, when the Dell computer was returned to Janusz from a complete search by the forensic team, was the image of the computer returned to him as well? A. I don't believe so. Electronicaily signed by Jeana Ricciuti (601-280-428?9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 578}; 1 Q. So the image was retained as evidencepacket of like CDs that contained the i 3 images of that. 4 Q, Of his computer? 5 His computer and the other CPU computer. 6 Q. And those were retained and not returned? 7 A. Correct. 8 Q. And then they were ultimately part of the 9 isubject of the grand jury subpoena that the Palm . -10 Beach 11 A. Correct. 12 Q. PD produced 13 A. Correct. 14 Q. later in August; is that correct? 15 A. Yes, sir. 16 Q. So that, if I'm clear, the computer forensic 17 procedures used on Janusz's computer, the Dell computer, 18 were identical to those that would be used on any seized 19 computer, which is a complete and thorough computer 20 review of the image of the hard drive of the seized 21 computer? 22 A. Correct. 23 Q. And it's essentially they just an A to 24 search to see whether or not the computer contains any 25 tile or folder or e?mail or data or picture that would PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 - 24.2.1: (561) 832?7500 signed by Jeana Ricciutl-(601-280-428-9381) Electronically signed by Jeana RicciutEIBOfl ?280-428-9381) (561) 832-7500 Page 579 be consistent and further your investigation? A. I don?t believe there were e?mails. I think?, it was file pictures or any data, but-I don?t think we went into emmails. Q. So you know these computers contain, essentially, a mountain of information when they are regularly used? A. Correct. Q. And what was done by your forensic team_is to essentially skim_or scan through or review this mountain of data to see if any one file or folder or piece of data was consistent with and furthered your? investigation? A. Correct. Q. And in terms of this Dell computer, the answer was none? A. Right. Q. And in terms of the CPU that was taken from an area on the first floor of Mr. Epstein's house, there was none with the exception of a single image that was hard to see and might be A. There were segments of videos, but again, the lighting was poor, Q. And again, when you went in there on October 20th with a warrant, you had no allegation from PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601 -280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Page 580 any particular witness that there would be anything on i any of those computers that would be a porn photo, for instance? MS. ARBOUR: Form- BY MR. WEINBERG: Q. No one told you that? A. No. Q- Now, this_was the first time that you had a discussion with Agent Kirkendahl regarding the Epstein investigation, August 3rd or 4th of 2006? A. I believe the first time was with Junior, the second time was with Kirkendahl and another agent. Q. Do you have any memos or notes of that meeting or were you essentially seeing them as a witness to their investigation? I mean strike that. Did you take any notes of that meeting? A. No, I did not take any notes. Q. And what did you see your role as at that meeting? A. Providing them, basically, a synopsis of the case and answering any questions that they may have. Q. Do you recall any particular questions? A. I knew that one of the questions were, did any of the victims fly out of the country with Mr. Epstein. At that point, I had that packet of some of the flight Electronically signed by Jeana Ricciuti (601-280-428?9381) Electronically signed by Jeana Ricciuti (601 ~280-428-9381) (561) 832?7500 logs, Q. Which came to you from Mr. Epstein's lawyer A. Right. Q. through the State Attorney? A. But there was several that were missing, so4.. Q. The ones you had reflected no trips on I Mr. Epstein's plane by any of the persons that you identified as being people who went to his house A. That's Q. in your case, correct? A. That's pretty much correct. Q- Was there a third meeting with the A. The third meeting I think it was when they showed up with the grand jury subpoena requesting all info on the case. Q. And did you have a substantive discussion with them on that occasion, or was it just an occasion where they served the subpoena on you as the person to whom A. They served a subpoena on me as the person who had the information. Q. And it was a broad subpoena that essentially asked you for everything? A. Everything. Q. And you produced everything because that's what you do when you get a federal subpoena? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601?280-428-9381) Electronically signed by Jeana Ricciuti (501-280?428-938?1) Page 581 3:34: (561) 832-7506 291 Page 582 1 A. Pretty much. 2 Q. ,And did you physically bring them_the case 3 materials? 4 A. No. They came to the police department and 5 took possession of them. 6 Q. Was this a fourth meeting with them? 7 A. No. That was the meeting. 8 Q. In other words, they called you in advance and 9 said they were coming with a subpoena, please 10 A. We're coming with a truck and subpoena, get 11 everything ready. 12 Q- And they got the results of the search and 13 seizure from October 20th; is that right? 14 A. Well, everything 15 Q. Everything on your inventory list. 16 A. Everything but what belonged to Janusz. That 17 .went back to him. 18 Q. Except what you imaged that belonged to 19 Janusz, which was maintained and turned over pursuant to 20 the subpoena? 21 A. Correct. 22 Q. Second is that you gave them all of the 23 physical results of the trash pulls, correct? 24 A. Correct. 25 Q. Both those that occurred in March_and April- (561) 832m7500 PROBE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601 -280?428?9381) Electronically signed by Jeana Ricciuti (601?280-428?9381) bdcd18?6-c7?2e?432d-8cf0?-b1 9ae656129f Page 583l? 1 under the aegis of Officer Pagan or the Burglary Task 2 Force, and those that were conducted under your 3 investigatory supervision, correct? 4 A. Correct. 5 Q. And did you watch the trash pulls or was that 6 something you said you assigned to others to watch? 7 A. That was assigned to others to watch. 8 Q. And they'd report to you that they watched it? 9 A. And they actually conducted their supplements. 10 Q. And physically, they took the bag of garbage ll from the garbage man, right? 12' A. Correct. 13 Q. By pre?arrangement, correct? 14 A. Uh?huh. 15 Q. At a place close to Mr. Epstein's home but 16 inaccessible to his Vision, correct? 17 A. Correct. 18 Q. And they then took that bag back to the Palm 19 Beach Police Department and searched within it for 20 evidence, correct? 21 A. Correct. 22 Q. And that bag, to your knowledge, was taken 23 from within Mr. Epstein's property gates? 24 A. Correct. 25 Q. Inside the gates. And it happened on occasion Electronically signed by Jea-na Ricciuti (601 ?280-428-9381) Electronically signed by Jeana Ricciuti (601 -280?428?9381) Page 584 1 two and three times a week? 2 A. I believe so. 3 Q. And it happened at times that there wouldn't 4 be ordinary garbage runs at Mr. Epstein's house? 5 A. Once a week there is a recycle pickup day. 6 Q. And did you participate in the search through 7 the garbage? 8 A. No. 9 Q. But others did.and you directed them as to 10 what to look for, correct? 11 A. Correct. 12 Q. Evidence of Mr. Epstein's meetings with or 13 phone call strike that. Evidence of Mr. Epstein's 14 meetings or relationships to different witnesses in.your 15 case? 16 Correct. 17 Leads to new witnesses, correct? 18 Correct. 19 Q. And you got leads to new witnesses from the 20 garbage pulls, correct? 21 A. Correct. 22 Q. And then you got more leads to new witnesses 23 from message pads that were seized from Mr. Epstein's 24 home on October 20th? 25 A. Correct. (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428?9381) Electronically signed by Jeana Ricciuti (661-280-428-9381) Page 585: I Q. Now, the FBI came and the file was essentially 2 checked out on October 28, 2006 at 1:30 3 A. Where it says TOT Yeah. 4 Q. Did you have any occasion to meet with the FBI 5 after October 28 or after August 28, 2006? 6 A. I think I was telephoned once by Agent 7 Kirkendahl requesting clarification on something, and 8 then I would call her, hey, how's everything going, can 9 you share anything, and no, I never got any response "10 back as far as what was going on I 11 Do you recall what the subject was that the 12 FBI agent asked you about, Agent Kirkendahlthat was the last substantive "?15 communication with Agent Kirkendahl? 16 A. Like I said, I would call her. .17 Q. Right, but those were essentially, what can 18. you tell 19 A. Nothing. 20 Q. There was no content to thoseAnd what about the male agent that you 23 remembered meeting with Agent Kirkendahl that was on i 24 August 4, 2006? Did you ever have a followup with him? 25 A. Shortly thereafter, I think he left the FBI, Eiectronically signed by Jeana Ricciuti (601-280-428?9381} Electronically signed by Jeana Ricciuti (601 ~280-423-9381) bdcd1876-c72e?432di8cf0-b1 9.2196561291I (561) 832?7500 Page 586 and that's when Jason stepped in. Q. Did you have any communications with Jason? A. I can't recall if I did or didn't. Q. And how about with any of the United States Attorneys, did you have any substantive communications with anyone in the upper hierarchy of the US Attorney's office? i A. No. Q. So there was no conversations between you and the US Attorney? A. No. Q. The acting US Attorney? A. No. Q. The head of criminal? A. No. Q. And how about the US Attorney in charge of the investigation of Mr. Epstein? A. No. Q. No meetings involved with Ms. Villafana? A. No. Q. All of your communications were with FBI agents, and you've provided us with the details regarding those meetings. And there were really primarily two meetings; one attended by Chief Reiter between you and Special Agent Ortiz, and then the PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601?280?428?9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) 291 (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Page 587 followup meeting which this evidence log reflects occurred on August 3rd or 4th wherein you reviewed largely the results of the search and seizure of Mr. Epstein's home on October 20, 2005? A- Correct. Q. Mr. Reiter, Chief Reiter or former Chief Reiter,?how often do you speak to him since he left office?* A. I've seen him maybe two or three times and, spoken to him maybe a handful of times. Q. Do you know whether or not he is employed or planning to be employed as a private investigator? A. I have no idea. Q. Do you know whether he was ever employed by the Rothstein firm? A. have no idea. Q. Do you know whether or not he's engaged in any private investigation in connection with any of the Plaintiffs' cases against Mr. Epstein? A. I have no idea. When we speak, we don't speak about business. Q. Understandably, given that you're being deposed. Before Chief Reiter left and, in fact, before the Plaintiffs' lawyers instituted these civil lawsuits, Electronically signed by Jeana Ricciuti (601?280-428-9381) Electronically signed by Jeana Ricciuti (601-280~428-9381) Page 588 1 though, you and the Chief would see each other 2 regularly, correct? 6 3 A. Yes. 4 Q. In fact, you and the Chief would e?mail each 5 other regularly regarding matters of common interests; 6 is that correct? 7 A. Yes. 8 Q. And you and the Chief would e?mail each other 9 about interests including the ongoing efforts of the 10 media to find out what's going on in the Epstein case? 11 A. Yes, through Google alerts and things he would 2 12 come across and things I would come across, I would send 13 to him. 14 Q. In other words, Reiter to Recarey, i 15 September 6, 2007, "Channel 5 ran a major story on 16 Epstein at 6:00. Showed footage of Epstein at PBIA and 17 audio of Connolly from Vanity Fair saying Epstein would 18 take a plea as early at tomorrow, signed Reiter." 19 Do you remember that one? 20 A. Yes. 21 Q. Or Reiter to Recarey, December 10, 2008, 22 "Shiny Shade advised me they're running her article 23 tomorrow that Epstein's on work release. Read it 24 online. Please notify Nesbitt. Thanks, Reiter." 7 25 Do you recall following that direction and - (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381.) Page 589 1 notifying me i 2 A. I may have called her and left_her a voice 3 mail, Nesbitt Kirkendahl. Like I said, everything with 4 the FBI is one way. They don't share the information. 5 A lot of times I would call her desk line and it goes 6 right to voice mail, so I would just leave her the 7 information 8 Q. Can you recall as an aftermath of that 9 information regarding work release that there was some 10 discussions as to whether or not Mr. Epstein's contract 11 required him to do day?to?day in prison, meaning to 12 serve 18 months, or whether instead he had?to be 13 sentenced to 18 months which would make him eligible for 14 work release and that the conclusion was that he was 15 eligible for work release like all others? 16 A. Correct- 17 Q. And.do you recall Mr. Reiter, Chief Reiter, 2 18 having ongoing communications with a Joyce Reingold at 19 the PB Daily News in the fall of 2008? 20 A. I have no idea. 21 Q. But you knew that he was the chief and he was 22 the contact person for a lot of the media?to?police 23 communications? 24 A. Actually, Janet Consuelo is the well, was 25 the PIO for the Police Department. She just retired (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601 480-428-9381) Page 590 1 last week. 2 Q. So you don't know about all these e?mails that 3 have been disclosed to us through public record searches 4 reflecting e?mails between Chief Reiter and the 5 different members of the media wherein he's keeping them 6 in touch with the events connected to the Epstein casehis e?mail to the US Attorney's office, 9 saying, "Contrary to your information, you may note that 10 nothing.in the story relative to the plea was attributed 11 to me, as I have not discussed this case with the news 12 media." 13 Are these not e?mails that you remember or 14 that you were copied onthe totem pole. 16 Q. I understand. That's why there's a chief and 17 the rest of us. 18 A. And many wigwams. 19 MR. WEINBERG: May I have one minute with my 20 co?counsel? This depo may be concluded. 21 (A brief recess was taken.) 22 MR. WEINBERG: In the interest of speed, I'll 23 say thank you for a long day, Detective Recarey. 24 I'm finished. 25 THE WITNESS: Thank you very much. PROBE COURT REPORTING AGENCY, INC. (561) 832?7506 (56l) 832?7500 Electronica?y signediby Jeana Ricciuti (601-280-428-9381) Electronicaily signed by Jeana Ricciuti (601-280-428-9381) Page 591 i CROSS (DETECTIVE JOE RECAREY) 2 BY MS. ARBOUR: 3 Q. Detective, the search warrant that you 4 executed on 358 El Brillo Way, prior to the execution in 5 October of 2005, did you do any research on who the 6 property owner was? 7 A. Yes. 8 Q. And were you able to determine who-owned that 9 property? 10 A. Yes. I believe it was Mr. Epstein, but I 11 think it was under a corporation. 12 Q. Did you do any research on potential residents 13 at that address? 14 A. Yes. 15 Q. And do you recall who you identified as a 16 potential resident, if anyone? 17 A. Mr. Epstein, I believe Nadia Marcinkova and 18 Adriana Musinska. 19 Q. Did you determine that it was an address used . 20 by Jeffrey Epstein? 21 A. Yes. I 22 Q. The message pads that you seized during the 23 search warrant in October of 2005, do you recall how 24 many there were? 25 AI Five, five or six, I think. (561) 832*7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Eiectronicaliy signed by Jeana Ricciuti (601-2804280381) Eiectronicaiiy signed by Jeana Ricciuti (601-280-428-9381) Page 592 1 Q. Does that include the ones that were a 2 ultimately returned to Mr. Janusz? 3 A. None were returned to Mr. Janusz. 4 (Deposition Exhibit No. 29 was marked for 5 identification.) 6 BY MS. ARBOUR: 7 I'll show you what I've marked as 29, and I'll 8 represent to you that I got those from a public records 9 request from the State Attorney. I'll ask you to flip ?10 through them and ask you if that seems to be all the 11 ones that you seized. 12_ A. This was three message books. This would be 13 No. 2 on the property receipt. 14 Q. So would there be an additional two or three 15 message books marked as No. 1 or something on the 16 property receipt? 17 A. There would,be No. 1, No. 2. On the search 18 warrant return, you would see the different ones that 19 had the different message books. 20 . Q. Do you recall, of all of the message books 21 that you reviewed, not just the one in May I just marked 22 as 29, what time period they coveredhead, no, I couldn't tell 24 you. 25 Q. Do you know if they extended into 2004? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-42841381) Electronically signed by Jeana Ricciuti (601-280-428-9381) ?are; ,7 (561) 832-7500 Page 593 A. I knew we got current books and older books, but I couldn't tell you the time frame. Q. Do you recall what rooms the message pads were taken from inside the main residence at El Brillo? A. There was some taken from the Small office in the kitchen area, there was some taken from the kitchen area, there was some taken from~w there was some taken from the guest house, I believe the pool house and then there is like a little pantry area. There was, I think, a book taken from there too. Q. And when you say the pool house, is that the room that Mr. Epstein or someone used as an office out by the pool? A. Yes. There was like a pad, you know, like a writing like an old grease marker pad. Q. Obviously, since I got those as part of a public records, a lot of them.are redacted. I'm just going to ask you if you recall seeing any of the following names on the pads. Anything you need to refer back, that's fine. Do you recall seeing the name Jane Doe 2 on any of those messages? A. Can I refer? Q. Absolutely. A. Do you know, more or less, when? PROSE COURT REPORTING AGENCY, INC. (561) Eiectronicallysigned byJeanarRicciuti Electronically signed by Jeana Ricciuti 7(601-280-42819381) 832?7506 bdcd1 876-0726432d-80f0-b19ae?56129f Page 594 1 Q. At any time. A. I recall a lot of names. Would you know, more R.) 3 - or less, what page? 4 Q. The truth is, I'm not even sure if she's in 5 there. I?m just asking if her name's in there. 6 A. Oh, I can't recall. 7 Q. Do you recall seeing the name Jane Doe 4 on 8 any of those messages? 9 A. Yes. 10 Q. Do you recall seeing the name Jane Doe 3 on ll any of those messages? 12 A. I can't recall. l3 How about Jane Doe 6? 14 No, I'm sorry. 15 How about Jane Doe 7? 17 And how about Jane Doe 8? 18 Q. A 16 A. Yes. A Yes, I remember Jane Doe 8. 19 2o 2l Do you recall seeing a - or a A Yes. 22 Do you recall seeing the name 23 A. Yes. 24 Okay. 25 Did you ever speak with at (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 7832-7506 Electronically signed by Jeana Ricciuti (601?280?428-9381) Eiectronicaiiy signed by Jeana Ricciuti (601 -280-428-9381) (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (56 Page 595 any point during your investigation? A. 7 It doesn't ring a bell. Q. Do you recall speaking to anyone who informed you'that they brought a girl named Jane Doe 8 to Epstein's house? A: No. Q. Do you recall ever speaking to a girl who informed you that she brought Jane Doe 6 to Mr. Epstein's home? A. No. Q. During your execution of the search warrant in October 2005, did you recover any vibrating massagers? A. I remember a twin torpedo, but no. Q. What is a twin torpedo? A. Double sided Q. Okay, some type of sex toy? i A. Yeah. Q. Which room did you recover that from? i A. That was from_a back bedroom. Q. Do you recall I'm sorry, did you recover any lotions from within a bathroom? MR. PIKE: Form. THE WITNESS: From.a small credenza, there was a lotion there was a lotion in a small credenza in the master bedroom, a little Joy Jelly bottle. Electronically signed by Jeana?Ricciuti (601-2804288381) Electronically signed by Jeana Ricciuti Page 596 1 BY MS. ARBOUR: 1 2 Q. And the master bedroom, was that the same 3 master bedroom you understood to be the massage room? 4 A. Yes. 5 Q. Turning back to your testimony about reviewing 6 the phone records for Ms. Kellen and Mr. Epstein I 7 believe you said you reviewed as part of youri 8 investigation. 9 A. Yes. 10 Q. When you reviewed Ms. Kellen?s phone records, 11 what period of time did those phone records cover? 1?12 A. I don?t know the specific time frame. 13 Q. Do you recall if it covered only 2005? 14 A. Possibly. I don't recall 15 Q. Would it be noted in the probable cause 16 affidavit? 17 A. Probably in the incident report. 18 Q. You can flip through if that helps to refresh 19 your recollection. 20 A. I wouldn't even know where to find it at this 21 point. 22 Q. You believe it?s in the incident report, 23 though? 24 A. I believe so. 25 Q. And would it be the same time period that (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601?280-428-9381) Electronically signed? by Jeana Ricciuti (601 -280-428-9381) bdcd1876-cTZe-432d-8cf0-b1 9a9656129f Page 597 1 covered Mr. Epstein's phone records as Ms. Kellen's? 2 A4 I believe Mr. Epstein's was not as in depth as 3 Ms. Kellen's. 4 Q. And with regard to the phones, did you pull 5 the phone records for the house phone itself or cellular 6 phones for each of the people? 7 A. I believe it was Ms. Kellen's cell phone and 8 house phone records. 9 Q. At any point, were you able to match up . 10 victims with Ms. Kellen's phone records where there had 11 been some communication between the two of them? 3 12 Yes. 13 MR. PIKE: Form. ?14 BY MS. ARBOUR: _15 Q. Were any of those victims under the age of 18 "16 at the time the phone calls were made? 17 MR. PIKE: Form. 18 THE WITNESS: I believe so. 19 MS. ARBOUR: Is your objection to the use of 20 the word "victim"? 21 MR. PIKE: Yes. 22 BY MS. ARBOUR: 23 Q. Were any-of the witnesses that you were able 24 to cross reference with Ms. Kellen's phone records under 25 the age of 18 at the time the phone calls appear to have Electronically signed by Jeana Ricciuti (601-280-428?9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 598 1 been made? 2 A. I believe so. 3 Q. Were you able to cross reference any of the 4 witnesses with Mr. Epstein's phone records? 5 A. I only subpoenaed the house phone records 6 because there was no indication of anything on his cell. 7 But there was, I believe, some phone calls made to the 8 victims/witnesses from.the houseany research to find out who 10 was the registered user of that house phone? 11 A. It was registered to Mr. Epstein. 12 Q4 Were you able to confirm that Ms. Kellen i 13 placed or received any phone calls from Jane Doe 4 14 during your review of her records? 15 A. Yes. 16 Q. Were you able to confirm that Ms. Kellen 17 received or made any phone calls to Jane Doe 18 A. Yes. 19 Q. Were you able to confirm that Ms. Kellen made 20 or received any phone calls from Jane Doe 3? 21 A. I can't recall if there were any calls to 22 Jane Doe 3. 23 Q. Were you able to confirm that any phone calls 24 had been made or received by the house phone by 25 Jane Doe 4? (561) 832?7506 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Riccluti (601 -280~428?9381) (561 Page 599: Form. THE WITNESS: I believe so, yes. 7 5 BY MS. ARBOUR: Q. Were you able to cross reference any phone calls received from or-made to Jane Doe 7 from the house 2 phone? 3 A. I can?t reCall from the house phone, I'm sorry. Q. When you interview as part of your investigation, you interviewed Janusz Banasiak; is that correct? A. Yes. Well, I take that back. I attempted it. That never happened. Q. At any point, did_you come to learn that he rented a car for Jane Doe 4 to use? A. Yes. And how_did you learn that? A. Through Jane Doe 4. And what did she tell you? MR. PIKE: Form. THE WITNESS: When I interviewed her, she told me that there was a rental car for her use that she was utilizing actually, when I went down to talk to her at University, I actually found the car parked in the school lot. 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280?428-9381) Page 600'; 1 BY MS. ARBOUR: 5 2 Q. What did she tell you about how she came to 3 acquire that car? 4 A. She needed a car to get around. 5 MR. PIKE: Form. 6 THE WITNESS: She asked Mr. Epstein if he 7 could rent her a car, at which time there was a 8 rental car available to her. 79 BY MS. ARBOUR: 10 Q. And you went back and researched who, in fact, 11 rented that car; is that right? 12 A. COrrect. 13 Q. And that was Mr. Banasiak? 14 A. Yes. 15 Q. When you met with each of the witnesses, each 16 of the girls who had later who you suspected may have 17 been at Mr. Epstein's house, did you tape record each 18 and every single one of the interviews? 19 A. Yes. 20 MR. PIKE: Form. 21 BY MS. ARBOUR: 22 Q. And when the incident report says that a 23 statement is sworn, that you took a sworn statement from 24 a witness, what does that mean? 25 A. Where I swear them in. I made them raise .. . . . . PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 (561) 832?7500 Electronicaily signed by Jeana Ricciuti (601-280-428-9381) Eiectronicatly signed 53] Jeana Ricciuti (601-280-428-9381) Page 601 1 their right hand and, do you solemnly swear to tell the a 2 truth, the whole truth and nothing but the truth. 3 Q. Are those the exact words that you used? 4 A. Yes. 5 5 Q. Have you since learned that some of those 6 girls that you interviewed did not tell you the entire 7 truth about what happened at Mr. EpsteinTs house? 8 MR. PIKE: Form. 9 THE WITNESS: I had heard, I believe, Jane 10 Doe 4 was not truthful, 100 percent truthful. 11 BY MS. ARBOUR: 12 Q. During the course of your entire 13 investigation, did you ever have an opinion or a feeling 14 that maybe one or more of the girls was holding back on 15 what happened at Mr. Epstein's house? 16 MR. PIKE: Form. 17 THE WITNESS: Yes. 18 BY MS. ARBOUR: 19 Q. Can you tell me more about that? 20 A. I actually went to interview Jane Doe 4 twice 21 because I had that feeling from her when I spoke with 22 her. I actually went down to twice to speak to 23 her. On the second time that I went down to speak to 24 her, I told her the reason why I came down was that I 25 felt she was being untruthful, or at least telling me a (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (661-280-428-9381) 7 Page 602 7 1 partial truth, and she did not elaborate any furtherthe other girls that you 3 interviewed give you that same impression, that they 4 were holding back or not telling the truth? 5 MR. PIKE: Form. 6 THE WITNESS: I also had that feeling from. 7 Jane Doe 7. 8 BY MS. ARBOUR: 9 Q. What is it about Jane Doe 7 that gave you that 710 feeling? 711 MR. PIKE: Form. 12 The fact that she was extremely 13 nervous, extremely scared when talking about the 7 14 investigation. ?15 BY MS. ARBQUR: 16 Q. When you spoke with Jane Doe 7, do you recall 17 if any of her parents were home? i 18 A. Yes, her mother was present. 19 Q. Was she in the same room as Jane Doe different room, do you recalldifferent room. 22 Q. How did you know to go and interview Jane Doe 23 7 as part of your investigation? 24 A. That name was given to me by H.R. 25 Q. Did she indicate that Jane Doe 7 was one of PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 (561) 832-7500 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 6032 1_ the girls she brought to Mr. Epstein's home? I 2 A. Yes. 3 Q. What did you tell Jane Doe No. 7's parents 4 about why you were there to interview Jane Doe 7, if you 5 recall? 6 A. Pretty much same as I told all, I believe that 7 they were either a victim/witness to an investigation 8 that I was conducting about.an individual that lived 9 within the Town of Palm Beach. 10 Q. When you met with Jane Doe 7 and spoke with 11 her, did she cry? 1 12 AJ She was scared and she was nervous. We were 13 sitting the first time I went out to her house, she 14 was not home. We waited for a little while and 15 eventually we left, not knowing what time she was going IC 16 to be back. When I received a phone call the following 17 morning, I went back out there and she was visibly 18 scared. You could tell, she was shaking. 19 Q. During the course of your interview, did she 20 tell you that Mr. Epstein touched her buttocks? 21 MR. PIKE: Form. 22 BY MS. ARBOUR: 23 Q. You eventually interviewed her, correct? 24 A. Yes. :25 Q. During the course of that interview, did she (561) 832*7506 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronicaliy signed by Jeana Ricciuti (601 -280-428-9381) Electronicaliy signed by Jeana Ricciuti (601 -280?428-9381) Page 604 1 tell you that Mr. Epstein touched her buttocks? 2 MR. PIKE: Form. 3 7 MS. ARBOUR: I believe so. 4 BY MS. ARBCUR: I 5 Q. During the course of that interview, did she 6 tell you that he_masturbated in front of her? 7 MR. PIKE: Form. 8 THE WITNESS: I believe so. 9 BY MS. ARBOUR: 10 Q. During the course of your interview, did 11 Jane Doe 7 play you a voice mail from Ms. Kellen? 12 A. Yes. 13 Q. What do you remember about that voice-mail? 14 MR. PIKE: Form. 15 THE WITNESS: It was a-voice mail left on her 16 cell phone from Sarah Kellen asking Jane Doe 7 to 17 call her and let her know what I was looking_into. 18 BY MS. ARBOUR: 19 Q. Did Jane Doe 7 tell you that Sarah had called 20 multiple times during the investigation? 21 MR. PIKE: Form. 22 THE WITNESS: Yes. 23 BY MS. ARBOUR: 24 Q. What is your understanding of how many times 25 Ms. Kellen called Jane Doe 7? PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 (561) 832-7500 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 605 1 A. I believe approximately three times that 2 evening. 3 Q. Did you ever review Jane Doe 7 or Ms. Kellen's 4 phone records to see how many phone contacts there were i 5 that day or within that period? 6 A. Again, I can't recall how many or the time 7 frame of the phone records. i 8 Q. Did Jane Doe 7 tell you that Ms. Kellen was 9 the one she spoke with in order to arrange Mr. Epstein's 10 massages? 11 MR. PIKE: Form. 12 THE WITNESS: Yes. I do recall Sarah. 13 BY MS. ARBOUR: 14 Q. Was it your understanding that Ms. Kellen 15 would call her or she would call Ms. Kellen or did you 16 get into that at all with her? i 17 MR. PIKE: Form. 18 THE WITNESS: How it was told to me was Sarah 19 would call like a day or two prior to their arrival 20 to Palm Beach, to coordinate a time and a date when 21 they were going to be in the Town of Palm Beach, 22 and if she was interested in working. 23 BY MS. ARBOUR: 24 Q. So it's your understanding Ms. Kellen would 25 make a phone call to Jane Doe 7 to schedule work? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Eiectr-onically signed by Jeana Ri?cciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381') Page 606 1 A. Yes. 2 During the course of your interview with 3 Jane Doe 7, did she tell you that she was paid to give 4 Mr. Epstein massages during which he touched her in a 5 sexual way? 6 MR. Form. 7 THE WITNESS: Yes. 8 BY MS. ARBOUR: 9 Q. Did you interview a girl named Jane Doe 3 as a 10 part of your investigation? 11 A. Yes, I did. 12 Q. How did you know to speak with Jane Doe 3? 13 A. I think this was another name provided to me 14 by H.R. 15 Q. Do you recall if Jane Doe 3 told you that H.R. 16 was the one who arranged for her to go to Mr. Epstein's 17 house? 18 MR. PIKE: Form. 19 THE WITNESS: I believe so. 20 BY MS. ARBOUR: 21 Q. At any point during your conversations with 22 Jane Doe 3, did she tell you that she was paid to give 23 Mr. Epstein a massage in which he touched her in a 24 sexual manner? 25 MR. PIKE: Form. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) (561 832?7500 PROSE THE BY MS. ARBOUR: Q. Did buttocks? MR. THE BY MS. ARBOUR: Q. Did breasts? MR. THE BY MS. ARBOUR: Q. Did of her? MR. THE BY MS. ARBOUR: Q. Did you were investigating Mr. Epstein before you went to speak with her? MR. THE associate of hers as well, and I had interviewed her prior to?Jane Doe 3. Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-423-9381) Page 607 WITNESS: That is correct. she tell you that Mr. Epstein touched her PIKE: Form. WITNESS: Yes. She tell you that Mr. Epstein touched her PIKE: Same objection. WITNESS: Yes. she tell you that he masturbated in front PIKE: Same objection. WITNESS: Yes- you ascertain from Jane Doe 3 if she knew PIKE: Form. WITNESS: I interviewed J.S., who is an COURT REPORTING AGENCY, INC. (561) 832?7506 bdcd1 876-c729-432d-8cf0-b1 9ae6561 29f Page 608 1 BY MS. ARBOUR: 2 Q. Did Jane Doe 3 indicate to you that she was 3 expecting you to come by or that someone had told her 4 that you were investigating? 3 5 MR. PIKE: Form. 6 THE WITNESS: Someone had told her. 7 BY MS. ARBOUR: 8 Q. Was it your understanding that J.S. told her 9 there was an investigation? 10 MR. PIKE: Same. '3 11 THE WITNESS: I believe so. 12 BY MS. ARBOUR: 13 Q. Did Jane Doe 3 ever tell you that she was paid 3 14 to bring other underaged girls to-Mr. Epstein's house 15 for massages? 16 MR. PIKE: Form. 17 THE WITNESS: I can't recall if she did or she 18 didn't. 19 BY MS. ARBOUR: 20 Q. Would it help to refer back to the Do you 21 have it there? 22 A. Yeah. 23 Q. I think page 8 is Jane Doe 3. 24 MR. PIKE: Same objection to the extent the 25 question is pending. (561) 832?7506 (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. Electronicatly signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti i(601-280-428-9381) bdcd1876-c72e?432d-8ch-b1 9a9656129f Page 609_? 1 THE WITNESS: Yes. 3 2 - BY MS. ARBOUR: 3 Q. Yes, she did tell you that? 4 MR. PIKE: Form. 5 THE WITNESS: That she had gone back to the _6 house with H.R. on two other occasions. 7 BY MS. ARBOUR: 8 Q. Did she tell you who she generally spoke with 9 in order to make arrangements to go to Mr. Epstein's 10 house for these massages, whether she was providing them 11 or another girl was? I2 MR. PIKE: Form. 13 THE WITNESS: The fact that she went with 14 H.R., so I'm sure they would contact Sarah. 15 BY MS. ARBOUR: 16 Q. Did you ever pull H.R.'s phone records as a 17 part of your investigation? 18 A. I believe they were pulled by Detective Pagan. 19 Q. Do you know how many times, if any, there was A 20 converse or there were phone calls between H.R.'s 21 number and Jane Doe 3's number on those records? 22 A. No. 23 Q. Let's focus on your interview with Jane Doe 4, 24 or your interviews with Jane Doe 4. At some point, she 7 25 did discuss or she did give you a version of events that 832?7506 PROSE COURT REPORTING AGENCY, INC. (561) (561) 832?7500 Electren'ically signedty Jeana Ricciuti (601-280-428-9381) Electronicatly signed by Jeana Ricciuti (601-280-428-9381) Page 610 1 occurred at Mr. Epstein's house; is that correct? 2 A. Correct. 3 Q. Did she tell you that she 4 MR. PIKE: Form. 5 BY MS. ARBOUR: 6 Q. went to Mr. Epstein's house more than one 7 time? 8 MR. PIKE: And form to this question. 9 THE WITNESS: Yes. 10 BY MS. ARBOUR: 11 Q. How many times did she tell you that she went 12 to Mr. Epstein's house to give him a massage? 13 MR. PIKE: Form. 14 (Mr. Epstein left the proceedings.) 15 MR. PIKE: You can continue. 16 THE WITNESS: I can't -- I don't know. 17 MR. PIKE: May I ask a quick question? Do you 18 need to terminate at 5:00? 19 MS. No. Thank you, though. 20 BY MS. ARBOUR: 21 Q. Would it help to look at the PCA, page 9? 22 A. Yes. Okay. 23 Q. Did she tell you how many times she went to 24 Mr. Epstein's house to give him a massage? 25 MR. PIKE: Form. (561) 832?7500 COURT REPORTING AGENCY, INC. (561) 832?7506 PROBE Electronically signed by Jeana Ricciuti (601-280-423?9381) Electronically signedLby Jeana Ricciuti (601-280-428-9381) 291 Page 611-: 1 THE WITNESS: A lot is what she claimed. 2 BY MS. ARBOUR: 3 Q. And over what period of time do you understand 4 she was going to Mr. Epsteinis home to give him these 5 massages? 6 A. Since she was 16. 7 MR. PIKE: Form. 8 BY MS. ARBOUR: 9 Q. What is your understanding of how she came to 10 Mr. Epstein's house for the first time? 1 11 A. I believe she was taken to the house by H.R. 12 Q. And did she~tell you on her subsequent viSits 13 how she would make arrangements to get to Mr. Epstein's I 14 house, if she would call Ms. Kellen or if she would call 15 the house, or can you walk me through what she told you 16 about how she got there? 17 MR. PIKE: Form. 18 THE WITNESS: If I can refer to it? 19 BY MS. ARBOUR: 20 Q. Absolutely, go ahead. 21 A. Okay. 22 Q. Did she tell you that she would call 23 Ms. Kellen to make arrangements to come over and give 24 Mr. Epstein massages? 25 MR. PIKE: Form. Electronically signed by Jeana Ricciuti (601-230-428-9381) Electronically signed by Jeana Ricciuti (601 ?230?428?9381) Page 6127 1 THE WITNESS: Correct. 2? BY MS . ARBOUR: I 3 Q. Did she tell you that Ms. Kellen would call 4 her to make arrangement to come over and give 5 Mr. Epstein a massage? A 6 MR. PIKE: Form. 7 THE WITNESS: On occasion. 8 BY MS. ARBOUR: 9 . Q. Did she tell you that she would make 10 arrangements through H.R. to go over to Mr. Epstein's 11 house to give him.a massage? 12 A. Initially. 13 Q. Did you ever cross reference Jane Doe 4'8 14 number on Sarah Kellen's phone records, specifically, 15 that you recall? 16 A. Jane Doe 4, I do remember on her cell phone. 17 Q. And do you recall if Jane Doe 4's number 7 18' appeared on Ms. Kellen's phone records? 19 A. Jane Doe 4, I believe so, yes. 20 Q. Do you know if you looked specifically Ms. Kellen's phone records indicated 22 communication between Jane Doe 4 and Ms. Kellen 23 strike that, let me start over. 24 Do you recall looking at phone records prior 25 to June of 2005 to see if there were any cross (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Riceiuti (601-230-428~9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) (561 Page 613 references prior to Jane Doe 4 turning 18? A. I don?t know. I can't recall the time.frame of the cell phone records. Q. Do you recall if, at the time you did find Jane Doe 4's number on Ms. Kellen's records, Jane Doe 4 was under 18? A. Not w" I'm not sure because I don't know the time frame I have the cell phone records from. Q. Did Jane Doe 4 tell you that Mr. Epstein touched her in a sexual manner on more than one occasion? A. Yes. Q. Did she tell you that Mr. Epstein masturbated in front of her? PIKE: Form to the last questi0n7 and form to this question. 3 THE WITNESS: Yes. MR. PIKE: You're just too fast. MR. GARCIA: I join_ BY MS. ARBOUR: Q. Did Jane Doe 4 tell you that she was nude in front of Mr. Epstein during the massages she gave him? MR. PIKE: Form. THE WITNESS: I believe down to her thong underwear. PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 832-7500 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) (561) 832-7500 Page BY MS. ARBOUR: Q. And did Jane Doe 4 tell you if Mr. Epstein ever touched her buttocks? MR. PIKE: Form. THE WITNESS: Yes. BY MS. ARBOUR: Q. Did Jane Doe 4 tell you that Mr. Epstein touched her breasts? A. Yes. MR. PIKE: Form. BY MS. ARBOUR: Q. Did Jane Doe 4 tell you that Mr. Epstein touched her genitals? MR. PIKE: Form. THE WITNESS: That, I don?t recall. BY MS. ARBOUR: Q. Did Jane Doe 4 tell you that Mr. Epstein performed oral sex on her? MR. PIKE: Form. THE WITNESS: No. BY MS. ARBOUR: 614 Q. Did Jane Doe 4 tell you that Mr. Epstein used a vibrator or a vibrating massager on her? MR. PIKE: Form. THE WITNESS: She claimed that the vibrator PROSE Electronically signed by Jeana Ricciuti Electronically signed by Jeana Ricciuti (601-280-428-9381) COURT REPORTING AGENCY, INC. (561) 832-7506 Page 6l5? was not used on her. She knew of the vibrator, but 2 it was not used on her. 3 BY MS. ARBOUR: 4 Q. Is it your understanding that when MH when 5 Jane Doe 4 so going back to what she did tell you, 6 which is that he touched her buttocks and her breasts at 7 least, was it your understanding that those incidents 8 occurred when she was under the age of 18? 9 MR. PIKE: Form, move to strike. 2 10 THE WITNESS: Yes. 11 BY MS. ARBOUR: 12 Q. Did she tell you that the touching of the 13. buttocks and the touching of the breasts occurred before 14 she was 18? 15 MR. PIKE: Form. 16 THE WITNESS: She had been going there since 17 the age of 16. I can't recall if she said she was 18 under 18 when he was touching her buttocks and 19 breasts. 20 BY MS. ARBOUR: 21 Q. When you interviewed Jane Doe 4, where did the 22 interview take place? 23 A. Universityparticular place, in a 25 particular room, or (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronicallysigned by Jeana Ricciuti (601-2864288381) Electronically signed by Jeana Ricciutl? (601-2804288381) bdcd1876-c72e?432d?8cf0-b1 9a9656129f Page 616_small office room within next 2 to the PE room. '3 Q. And was anyone else present? 4 A. Detective Dawson. 5 Q. And did Jane Doe 4 during the course of 6 your_interview, was Jane Doe 4 crying? 7 A. She was shaken, nervous and occasionally she 8 would cry. 9 Q. Was that the first interview or the second I 10 interview that took place ?w 11 A. The first one. 12 in that room? i A The first one. 14 Q. Where did the second interview take place? 15 A She had just finished playing soccer. I want 16 to say the second one, I believe, was in the PE area. 17 It was like a gym, like a gymnasium. 18 Q. And in that second interview, was she crying 19 when she spoke with you? 20 A. I can't recall if she was or if she wasn't. I 21 know the first one she was. 22 Q. Did she ever ask you if she was in trouble for 23 what happened at Mr. Epstein's house? 24 MR. PIKE: Form. 25 THE WITNESS: I don?t recall. (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-423-9381) 29f (561 Page 617 BY MS. ARBOUR: Q. Do you recall if any of the witnesses that you interviewed asked if they were in trouble for what happened at Mr. Epstein's house or for what they say happened at Mr. Epstein?s house? MR. PIKE: Form. THE WITNESS: I recall J.S. was concerned that she might have been be getting into trouble. BY MS. ARBOUR: Q. Let me show you this, marked 30. (Deposition Exhibit No. 30 was marked for identification.) BY MS. Q. 'Detective, have you seen that document before? A. Yes. Q. And what are you recognizing this document to be? A. It is from a memo pad, from Mr. Epstein's memo pad. It's a sheet. Q. Did you recover this document from a trash pull that you did on Mr. Epstein's residence? A. Yes. Q. There's a name that's redacted on there. Do you remember if that name was Jane Doe 4? A. Yes. 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana?Ricc?ruti (601-280-428-9381.) Electronically signed by Jeana Ricciuti (601n280-428-9381) Page 618 1 Q. The number that's on there, do you 2 see that? 3 A. Yes. 4 Q. Did you do any investigation into that number? 5 A. Yes. 10 And what did you find it to be? I believe that was Jane Doe 4's number. A 8 Q. And how about the other number that's on to there,?, did you investigate that number? 10 A. I believe I did request subscriber information 11 on that. I can't recall who that came back to, though. 12 MS. Can we go off the record for a 13 minute? 14 MS. ARBOUR: Sure. 15 (Discussion held off the record.) 16 BY MS. ARBOUR: 17 . Did you ask Jane Doe 4 about this note? 18 No. 19 E) K) Why not? 20 A. I felt that she was holding back from me, so I 21 didn't want to let her know what I knew. I stressed to 22 her that I knew a lot more than what I was letting on 23 to, but she continued with her limited story. 24 Q. At any point, did Jane Doe 4 tell you that she (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601 -280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 619 i 1 MR. PIKE: Form. 2 THE WITNESS: II can't recall if she said 3 anything. 4 BY MS. ARBOUR: 5 Q. Do you recall if any of the witnesses that you 6 spoke with told you that they told Mr. Epstein about the 7 police investigation, your investigation? 7 8 MR. PIKE: Form. 9 THE WITNESS: I believe L.A., when I 10 interviewed her in Orlando. 11 BY MS. ARBOUR: 12 7 Q. Did that interview take place before or after 13 Jane Doe 4?s first interview? 1 14 A. After. 15 Q. And what did you and L.A. discuss about her 16 reporting to Mr. Epstein about your investigation? 7 17 MR. PIKE: Form. 18 THE WITNESS: That she had been contacted 19 prior to me by a private investigator and wanted to 20 know what she knew about the police investigation 21 and wanted her to call the investigator after I 22 would leave. i 23 BY MS. ARBOUR: 24 Q. Did she tell you who this supposed 25 investigator worked for (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280?428?9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) bdcd1B76?c729-432d-8cf0?b1 9aeB56'! 29f Page 620 1 MR. PIKE: Form. 2 BY MS. ARBOUR: 3 Q. Hm that had called her?V 4 MR. PIKE: Same. 5 THE WITNESS: I want to say Mr. Black's 6 office. 7 BY MS. ARBOUR: 8 Q. Do you recall the name of the investigator she 9 told you was trying to contact her? 10 MR. PIKE: Form. 11 THE WITNESS: I don't know. I can't recall. 12 There were so many PIs. 13 BY MS. ARBOUR: 14 Q. Does the name Bill Reilly ring a bell? 15 A. Yes. 16 Q. Was he the investigator that L-A. said called 17 him_?? or called her, I'm sorry? 18 A. I believe so, yes. And they had met in an 19 MR. PIKE: Form. 20 THE WITNESS: Applebee's or like a 21 Chili's/Applebee's type restaurant. 22 BY MS. ARBOUR: 23 Q. Did any of the other witnesses that you 24 interviewed indicate that Mr. Reilly had tried to 25 contact them? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronicaily signed by Jeana Ricciuti (601 ?280-428~9381) Electronicaily signed by Jeana Ricciuti (601-280-428-9381) bdcd1876-c72e-432d-8cf0-b1 9a9656129f (561) Page 621 PIKE: Form. Form. It's hearsay, that?s all. MS. ARBOUR: You said form twice. MR. PIKE: I?m just making sure you?re not beating me to the punch with another fast question. After I had interviewed certain people, I've gotten phone calls that the private 2 investigator had shown up and asking them questions similar to the questions I was asking. BY MS. ARBOUR: Q. And of those phone calls that you've received, were those all after the grand jury indictment in the summer of 2006? Prior. l0 Prior to? Okay. And do you recall if Jane Doe 4 ever told you that she had_been contacted by Mr- Reilly? A. I can't recall if she did. Q. Let me show you this one. We'll mark this 31. (Deposition Exhibit No. 31 was marked for identification.) THE WITNESS: Yes, I remember that. BY MS. ARBOUR: Q. Have you seen this document before? A. Yes. 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832*7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601 ~280~428~9381) (561 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Page 622 Q. What do you recognize this to be? A. This came from a trash pull where it says Jane Doe 4 cannot come at 7:00 because of soccer. Q. And so the name that's redacted on there is Jane Doe 4? A. Yes. Q. Did you ever ask Jane Doe 4 about this note? A. No, I did not. Q. For the same reason you didn't ask her about the other one? A. Correct. Q. During the course of your investigation, did i you uncover any other alleged victims who were named Jane Doe 4? MR. PIKE: Form. THE WITNESS: No, I did not. BY MS. ARBOUR: Q. Do you recall your interview with Jane Doe 2? A. Yes. Q. And you testified about it in the previous deposition, so I want to ask you just a couple of followup questions about that. How did you know to speak with Jane Doe 2? MR. PIKE: Form. THE WITNESS: Her name I think her name was Electronica?y signed by Jeana Ricciuti Electronica?y signed by Jeana Ricciuti (601 -280-4'28-9381) bdcd1876-c729?432d-8cf0-b1 9ae656129f (561 Page 623 given by her name was given by another female, another of the witnesses. BY MS. ARBOUR: Q. Would it have been Jane Doe 3 who told you her name? MR. PIKE: Form. BY MS. ARBOUR: Q. Do you recall? A. I believe so. I'm_not 100 percent certain, though. Q. If it would be in the PCA, if you want to take a look, that's okay. I think she's page 18. A. I believe sol Q. Is it your understanding that Jane Doe 2 was brought to Mr. Epstein's home prior to turning 18 in order to provide him a massage? A. Yes. MR. PIKE: Form. BY MS. ARBOUR: Q. Did she tell you that during the course of a massage with Mr. Epstein, she was touched in a sexual manner by Mr. Epstein? MR. PIKE: Form. THE WITNESS: Yes. BY MS. ARBOUR: 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) bdcd1876-c72e432d?8cf0-b1 9ae656129f Page 624 I Q. Did she tell you that Mr. Epstein asked her to 2 'remove her pants and her shirt during that massage and, 3 in fact, she did remove her pants and shirt? 4 MR. PIKE: Form. 5 THE WITNESS: That she did, yes. 6 BY MS. ARBOUR: 7 Q. Did Jane Doe 2 tell you if Mr. Epstein removed 8 her bra and touched her breasts? 9 7 MR. PIKE: Form. 10 THE WITNESS: I believe so. 11 BY MS. ARBOUR: "12 Q. Did she tell you that Mr. Epstein masturbated- 13 in front of her? 14 MR. PIKE: Form. 15 THE WITNESS: Yes. A 16 BY MS. ARBOUR: 17 Q. Did she tell you that Mr. Epstein touched her 18 vaginal area? 19 MR. PIKE: Form. 20 THE WITNESS: Yes. 21 BY MS. ARBOUR: 22 Q. Did she is this the one you were referring 23 to earlier where she told you that he put his fingers 24 inside of her vagina? 25 MR. PIKE: Form. (561) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Eiectronicaliy signed by Jeana Ricciuti (601 -280-428-9381) Electronically signed by Jeana Ricciuti (601 (561) 832?7500 Page 625 THE WITNESS: Yes. 5 BY MS. ARBOUR: Q. Did she tell you that Mr. Epstein made any comments about her clitoris? MR. PIKE: 'Form. THE WITNESS: I believe he mentioned how large it was. BY MS. ARBOUR: Q. Is it your understanding that from what Jane Doe 2 told you, that these events happened before Jane Doe 2 turned 18? MR. PIKE: Form. THE WITNESS: Yes. BY MS. ARBOUR: Q. Did Jane Doe 2 tell you she went there?before she turned 18? MR. PIKE: Form. THE WITNESS: Yes, she told me she was, I believe, 16 years of age. MR. PIKE: Can we take a quick break? MS. ARBOUR: I?m almost done. Just for the record, I've got the most amount of plaintiffs and I've been the quickest. (A brief recess was taken.) BY MS. ARBOUR: Electronically signed by Jeana Ricciuti (601 -280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Page 626 1 Q. You testified earlier that you turned over a 1 2 thumb drive to the FBI that had pictures of victims on 3 it 4 A. Correct. 5 Q. is that what you said? 6 A, Correct. 7 7Q. Do you recall what girls were on that thumb 8 drive that you turned over? 9 A. The girls that were mentioned in the report. 10 I know I acquired yearbooks from the schools for what 11 they looked like back then, compared to BL photos that 12 we were able to save their image. Of course I went onto 13 my thumb 14 Q. And now the FBI has that? 15 A. Any and all information. 16 Q. You said it was in the report, the girls would 17 be listed in the report. What report are you referring 18 to? 19 A. The incident report. 20 Q. Do you recall if there were any pictures of 21 Jane Doe 2 on that thumb drive? 22 A. Yes, there was. 23 How about Jane Doe 4? 24 A. Yes, there was. 25 How about Jane Doe 3? (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428?93781) Electronically signed by Jeana Ricciuti (601 -280-428-9381) Page 627?? Yes, there was. i How about Jane Doe 7? Yes. How about a girl that we haven't discussed named Jane Doe 5? 10 10 No. How about a girl named Jane Doe 6? No. How about Jane Doe 8? No. At any time during your investigation, did you speak to Jane Doe 5? Q. No. Did you speak to a girl named Jane Doe 6? No. Did you ever speak to a girl named Jane Doe 8? No. You were asked some questions earlier about a private investigator following you and pulling your trash I believe you said. A. Q. Yes. Can you tell me more about that? MR. PIKE: Form. THE WITNESS: Sometime during the investigation, it was discovered that we had (561) 832?7500 EROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electmnically signed by Jeana Ricciuti (601-280-428?9381) Electronically signed by Jeana Ricciuti? (601 480-428-9381) bdcd1876-0729432d-36fO-b1 9396561 29f Page 628 1 private investigators following myself and former 2 Chief Reiter. When I would leave work and I'd go 3 - visit my children, I would notice a car two 4 ?behind me doing the exact same moves I did. If I 5 sped up, he sped up; if I slowed down, he slowed 6 down." 7 I purposely I purposely drove way under the 8 speed limit just to see if he would go around. No 9 cars around us and he stayed right behind me. I 10 made several U?turns, he did the same exact thing. 11 So it was clearly evident I was being followed. 12 I did manage?to obtain a driver's license 13 plate number and it came back to a private 14 investigator. 15 I was actually called by one of the PIS, which 16 the phone number came back to the Law Office of Roy 17 Black in Miami. 18 As far as my trash being pulled, it became 19 clearly evident the day after Thanksgiving where 20 there is no trash pickup in my neighborhood, at my 21 house, the day after Thanksgiving, it's a holiday, 22 everybody's cans were full and mine is empty. 23 MR. PIKE: Form. Move to strike. 24 BY MS. ARBOUR: 25 Q. Did you ever do any research to determine the (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronicaiiy signed by Jeana Ricciuti (601?280?428-9381) Electronicatly signed by Jeana Ricciuti (601 -280-428-9381) Page 629: 1 identity of the private investigators that you believed 2 were follOwing you? 3 A. Yes. I did obtain based on their license 4 plate, I was able to obtain who they were and which PI 5 firm-they represent. 6 Q. Did you ever speak to any 7 MR. PIKE: Same objection. 8 BY MS. ARBOUR: '9 Q. Did you ever speak to any representatives of 10 that PI firmyou have any information about who, if 13 -anyone, hired them to follow you? 14 A. Aside from that one phone call that came back 15 to Roy Black's office. 16 Q. And that was the investigator's calling you or 17 you were calling the investigators? 18 A. No. They actually called me by mistake. 19 Q. Okay. So you didn't actually speak to anyone? 20 A. No. They asked me who I was, and I said who 21 are you, and they hung up. I had the number on my 22 caller ID. I cross referenced the phone number and it 23 came back to it. 24 Q. And to the best of your recollection, all of 25 this occurred sometime in that September to May 2006 (561) 832?7506 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Eiectronicaliy signed by JeanaiRicciuti (601?2804283381) Electronically signed by Jeana Ricciuti (601-280-428-9381) (561) Page 630 September '05 to May 2006 time period? A. Yes. Q. Did you ever speak with any of the other witnesses who indicated to you that they believed they were being followed? A. Yes. Q. What witnesses indicated they thought they were being followed? A. I received several phone calls from Jane Doe 103, indicating that she was her neighbors-were being talked to. People were going to her door representing themselves to be a police officer at first and then later identifying themselves as a private investigator. i Q. And did that occur sometime in that same September '05 to May 2006 time period? A- Correct. Q. Did any other witnesses that you can recall express similar concerns about being followed or being investigated? A. Yes. Jane Doe II. I had received several text messages and phone calls indicating similar, where PIS were speaking to her friends, her family, previous boyfriends and following her around. MR. PIKE: Form. BY MS. ARBOUR: 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronicaliy signed by Jeana Ricciuti (601 ~280?428-9381) 291 (561) 832?7500 Page 631 1 Q. Did Jane Doe 7 ever express to you that she 2 was worried she was being followed or investigated by a 3 private investigator? 4 MR. PIKE: Form. 5 THE WITNESS: Not that I can recall; 6 BY MS. ARBOUR: 7 Q. How about Jane Doe 3? 8 MR. PIKE: Form. 9 THE WITNESS: Not that I can recall. 10 BY MS. ARBOUR: 11 Q. wa about Jane Doe 4, did she ever indicate to 12 you that she was worried that she was being followed or 13 investigated? _14 MR. PIKE: Form. 15 WITNESS: Not that I can recall. i .16 MS. ARBOUR: I think that's all I have. 17 CROSS (DETECTIVE JOE RECAREY) 2 18 BY MR. GARCIA: 19 Q. Just a couple of questions. Jane Doe II, you 20 just mentioned her, how many phone calls or how many 21 conversations did you have with her? 22 A. Probably less than a handful. By phone or in person or A. By phone. And how did you meet Jane Doe PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 Electronica?y signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428~9381) bdcd1876-c72e-432d-8cf0~b1 9ae6561291 Page 632; 1 A. Actually, she came to the police station and 2 spoke with Detective Dawson once there was information 3 pertaining to Mr. Epstein's arrest. 4 After the arrest was made? 5 A. Correct. 6 Q. Why was that assigned to Detective Dawson as 7 opposed to yourself? 8 MR. PIKE: Form. 9_ THE WITNESS: I had taken a week vacation. 10 BY MR. GARCIA: 11 Q. Was there any followup after Detective Dawson 7 12 spoke to her? 13 A. Yes, I did make telephone contact with her, to 7 14 let her know that I had the case, and that I was going 15 to be looking into the case further. When the FBI took 16 all the information, I notified her and let her know 17 that the FBI was going to be looking into this as well. 18 And then it was clearly evident to me that it was just 19 going to be the FBI looking into this, 20 Q. And now, was the I'm trying to just piece 21 together the sequence. You said she came to you after 22 Epstein was arrested, correct? 23 A. Correct. 24 Q. Had the FBI already taken your files at that 25 point? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832m7506 Electronically signed by Jeana Ricciuti (601?280-423-9381) Electronically signed by Jeana Ricciuti (601 ~280-428-9381) Page 633 1 A. Negative. 7 2 7 Q. So there was an arrest. And the plea deal, 3 was that struck shortly after the arrest? 4 A. The plea deal didn't get struck until further 5 down the road. 6 Q. But it was after the FBI took all your 7 documents? 8 A. ,When she came in? 9 Q. ?No, in terms of the plea deal. :10 A. Oh, yeah, it wasiafter, way after. 11 Q. And other I have one statement that she 12 gave to detective 11m sorry, Sergeant Dawson, apparently. Itts dated can you tell me what the date .T14 of that report is? 91-5 A. 7/28/06. 16 Q. Do you know if there are any other reports _17 that were taken of Jane Doe II's involvement in this - 18 case from the Palm Beach Police Department? 19 A. Not that I'm aware of. 20 Q. That's the only one? Okay. 21 Did you ever present her information to the 22 'State Attorney's office for a criminal prosecutionyou know why? 25 A. Prior to me getting into the case, there was PROSE COURT REPORTING AGENCY, (561) 832F7506 (561) 832?7500 Eiectronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428~9381) Page 634 1 already the discussion was occurring already with the i 2 FBI, and there was original talk in the very beginning 3 with the State Attorney's office that they were going to 4 amend the charges, depending on the new victims that 5 came forward and what they had to say. And then the i 6 Feds came in and i 7 Q. And then that was that? 8 A. That was it. 9 Q. Do you know a man named Charles or Gerald 10 Goldsmith? He ran for mayor or something. 11 A. Yeah, I know of him, 12 Q. You've never met him? i 13 A. I mean, I know who he is if I see him, but he 14 doesn?t we don't speak 15 Q. Did Chief Reiter ever tell you or confide in 16 you or report to you that Mr. Goldsmith was seeking 17 information about the investigation of Mr. Epstein? 18 I A. He had mentioned that to me. 19 Q. And what did he tell you about that? 20 A. That he had received basically an inquiry from 21 Goldsmith and basically to back off the investigation. 22 Q. Do you recall when Chief Reiter reported this _23 to you? 24 A. No. 25 MR. PIKE: Form. a (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601?280-428?9381) Electronicaily signed'by Jeana Ricciuti (601-280-428-9381) bdcd'l 876-c72e-432d-8cf0-b19a96561 29f Electronically signed by Jeana Ricciuti (601 -280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 635 1 BY MR. GARCIA: I 2 Q. Was there any issue about any donations that 3 - Mr. Epstein had made to the Police Department? 4 A. You know, I heard he had made a donation and 5 it was returned to him, but I don't know any of that' 6 information at all. 7 Q. Regarding the conversations that you had with 8 Jane Doe II, you said there were some text messages or 9 phone calls. Did you make any reports of those 10 conversations? ll A. No, I did not. The text messages was because _12 she was concerned that her family, her boyfriend were 13 being questioned by PIs, they were being told certain . 14 things about the case, and she was concerned that it was i 15 like a harassment type of thing. 16 Q. Was she able to ascertain the names of the 17 investigators? 18 A. I believe she did. I believe it was on the 19 text message she sent me. i 20 MR. GARCIA: Okay, that's all I have. 21 MS. ARBOUR: Can I just ask one more? Is that 22 all right? 23 RECROSS (DETECTIVE JOE RECAREY) 24 BY MS. ARBOUR: 25 Q. Detective, during the course of your bdcd1 876?cWe-432d-8ch?b1 98196561 293? Page 636 investigation, would you say that it was absolutely 2 critical that you knew the amount of times a girl went 3 to Mr. Epstein's house? 4 MR. PIKE: Form. 5 THE WITNESS: Would I say it was critical? I 6 wanted to know if it was once or twice, more than 7 10, more than 15, more than 20. 8 BY MS. ARBOUR: 9 Q. Would it be fair to say it was more important 10 to you, during the course of your investigation, to get 11 a general sense of what happened and approximately how 12 many times it happened rather than an exact number of 13 times? 14 A. Correct. ?15 MS. ARBOUR: That's all I have. fl6 RECROSS (DETECTIVE JOE RECAREY) 5 17 BY MR. GARCIA: - 18? Q. I'm sorry, I forgot to ask you something. The 19 Assistant State Attorney that you were working with on 20 this case 21 A. Yes. 22 Q. I keep forgetting her name. What's her 23 name again? 24 A. Lanna Belohlavek. 25 Q. Now, is she an attorney who tried a lot of (561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381), Electronically signed by Jeana Riccluti (501-280?428-9381) (561) cases for the State Attorney's office or did she work more in the intake section of the State Attorney's office, if you know? A. I don't know exactly how many times she's been to trial, but I couldn?t tell you. Q. And did she make the presentation to the grand jury? A. Yes. Q. By herself? A. ?es. Q. Did you ever participate in any cases where she was the trial attorney for the State Attorney's office? that these minor girls who were lured, in exchange for compensation to_perform sex acts on Mr. Epstein, were not victims in her mind? THE WITNESS: Based on the MySpace pages that she viewed, she had made that determination. BY MR. GARCIA: Q. Just based on that? A. me. 832?7500 Q. Page 637 Ned No, I did not. And did she explain to you why she thought MR. WEINBERG: Form. That was my that's what she basically told PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-230-428-9381) Electronically signed by Jeana Ricciuti (601-280?428-9381) bdcd?l 876-6729-4'32d-8cf0-b1 9a96'56129f Page 638 1 Q. Did she know that it was a federal crime to solicit underaged women for prostitution? 3 MR. PIKE: Form. 4 BY MR. GARCIA: 5 Q. Or did she appear to know that? 6 MR. PIKE: Same. 7 THE WITNESS: I have no idea. 8 MR. GARCIA: All right. Thanks. 9 MR. PIKE: Any followup? Okay. 10 MS. So we're concluded, right? 711 PIKE: We are concluded. 2 12 MS: We're going to read. l3 l4 2 IS (Witness excused.) l6 (Deposition was concluded(561) 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronicatiy signed by Jeana Ricciuti (601?280?428?9381) Electronicatly signed by Jeana Ricciuti (601-280-428?9381) 291 6 I: 10 11 12 (561) 832?7500 Electronically signed by Jeana Ricciuti (601480?428-9381) Electronically signed by Jeane Ricciuti (6012280-428?9381) the undersigned authority, 8 was duly sworn on the 27th day of April, Dated this 27th day of April, PROSE CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH 2010. 2010. if well; WW {a Jeana Ricciuti, RPR, FP3 Notary Public State of My Commission Expires: 2/17/2013 My Commission No.: DD 854778 COURT REPORTING AGENCY, INC. (561) 291 Page 639 certify that 7 DETECTIVE JOE RECAREY personally appeared before me and 832*7506 (561 832?7500 PROSE COURT REPORTING AGENCY, INC. (561) 832~7506 Page 640 I I A THE STATE OF FLORIDA COUNTY OF PALM BEACH I, Jeana Ricciuti, Registered Professional Reporter and Notary Public in_and for the State of Florida at large, do hereby certify that I was authorized to and did report said deposition in stenotype; and that the foregoing pages are a true and correct transcription Of my shorthand notes of said deposition. I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out. I further certify that I am not an attorney or counsel of any of the partiess nor am I a relative or 3 employee of any attorney or counsel of party connected is with the action, nor am.lrfinancially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter- Dated this 11th day Of May, 2010. I ?if. =??tmr'is?? [Jets-swig rinii?aha Ricciu?qf?i, RPR, FPR, CLR Electronically signed by Jeana Ricciuti (601 -280~428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) Page 641 i 1 DATE: May 11, 2010 2 TO: DETECTIVE JOE RECAREY c/o Joanne M. O'Connor, Esquire 3 JONES, FOSTER, JOHNSTON STUBBS 505 South Flagler Drive, Suite 1100 4 West Palm Beach, Florida 33401 5 IN RE: Jane Doe 2 v. Epstein 6 Please take notice that on Tuesday, the 27th of April, 2010, you gave your deposition in the 7 above?referred matter. At that time, you did not waive signature. It is now necessary that you sign your 8 deposition. As previously agreed to, the transcript will 9 be furnished to you through your counsel. Please read the following instructions carefully: 10 At the end of the transcript you will find an errata sheet. As you read your deposition, any changes 11 for corrections that you wish to make should be noted on i 5- the errata sheet, citing page and line number of said i 12 change. DO NOT write on the transcript itself. Once you have read the transcript and noted any changes, be 13 sure to sign and date the errata sheet and return these pages to me. 14 If you do not read and sign the deposition within a reasonable time 30 days unless otherwise 15 directed) the original, which has already been forwarded to the ordering attorney, may be filed with the Clerk of 16 the Court. If you wish to waive your signature, sign your name in the blank at the bottom of this letter and 17 return it to us. 18 Very truly yours, 19 Jeana Ricciuti, RPR, FPR, CLR Prose Court Reporting Agency, Inc. 20 250 S. Australian Avenue, Ste 1500 West Palm Beach, Florida 33401 21 22 I do hereby waive my signature. 7 23 24 DETECTIVE JOE RECAREY 25 (561) 832?7506 - (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciuti (601*280-428-9381) Electronically signed by Jeana Ricciuti (60148042849381) bdcd1 876-c72e-432d-80fO-b1 9a96561291 (561) 832?7500 Page 642 I I A THE STATE OF FLORIDA COUNTY OF PALM BEACH I hereby certify that I have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the any corrections or notations made on the errata sheet, if one was executed. Dated this day of best of my knowledge and belief, with the exception of 2010. I DETECTIVE JOE RECAREY PROSE COURT REPORTING AGENCY, INC. (561) 832?7506 Electronically signed by Jeana Ricciuti (601-280-428?9381) Electronically signed by Jeana Ricciuti (601 ?280-423-9381) WNW (561) 832u7500 PROSE COURT REPORTING AGENCY, INC. Page 643 A A IN RE: JANE DOE 2 v. EPSTEIN CR: JEANA RICCIUTI DEPOSITION OF: DETECTIVE JOE RECAREY TAKEN: April 27, 2010 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGE LINE CHANGE REASON Please forward the original signed errata sheet to this office so that copies may be distributed to all parties. Under penalty of perjury, I declare that I have read my deposition and that it is true and correct subject to any changes in form or substance entered here. DATE: SIGNATURE OF DEPONENT: :1 7:7 7:77 amuwwz :1 1 1 (561) 832?7506 Electronically signed by Jeana Ricciuti (601 280-428-9381) Electronically signed by Jeana Ricciuti (601 -280-428-9381) bdcd1