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Case 9:08-cv-80736-..AM Document 291-27 Entered on . 3D Docket 01/21/2015 Page 5 of 5 
Page 105 
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that her husband's law firm had represented Mr. 
2 
Epstein. And maybe even done damage to the point 
3 
that because that happened it should be handled by 
4 
another circuit. 
5 
This was a case that I felt 
6 
absolutely needed the attention of the State 
7 
Attorney's Office, that needed to be prosecuted in 
8 
state court. It's not generally something that's 
9 
prosecuted in a federal court. And I knew that it 
10 
didn't really matter what the facts were in this 
11 
case, it was pretty clear to me that Mr. Krischer 
12 
did not want to prosecute this case. 
13 
Q Did he, in fact, make that clear to you at 
14 
some point verbally? 
15 
A 
Not in those exact words. But the 
16 
suggestion that multiple victims and some of the 
17 
crimes, felonies, that he should write a notice to 
18 
appear for a misdemeanor and the scheduling of a 
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grand jury on an issue like this is extremely rare. 
20 
The fact that he and I had an 
21 
excellent relationship. I was the speaker at his 
22 
swearing in ceremony. And that he wouldn't return 
23 
my phone calls, I mean it was clear to me by his 
24 
actions that he could not objectively look at this 
25 
case. 
Page 106 
1 
Q At some point, did you feel, or did you 
2 
become aware, that maybe he had been threatened in 
3 
some regard, either regarding his job or personally 
4 
in any regard? 
A No. 
6 
MR. CRITTON: Form. 
7 
BY MR. KUVIN: 
Q You're aware that obviously his position 
9 
is an elected position? 
10 
A lam aware. 
11 
Q Did you know whether or not he had had any 
12 
discussions with anyone about his political career 
13 
if this case did not go a certain way; did you ever 
14 
become aware of that in any regard? 
15 
MR. CRITTON: Form. 
16 
THE WITNESS: No. He had already publicly 
17 
announced he wasn't running for re-election. 
18 
MR. KUVIN: All right. This is actually a 
19 
good stopping point for a quick lunch if you 
20 
want to take a quick one, I just have to eat. 
21 
I'm hopefully not far from concluding. 
22 
THE VIDEOGRAPHER: We're off the record at 
23 
12:35. This is the end of tape 2. 
24 
(Recess) 
25 
THE VIDEOGRAPHER: We're back on the 
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Page 107 
record at 1:44. This is the beginning of tape 
3. 
BY MR. KUVIN: 
Q Okay. When we left off we were talking 
about Barry Krischer's office. And before I move on 
from that subject I just have one other question. 
Are you aware of any contact that was 
made with Mr. Krischer's office from anyone in the 
democratic party or the DNC at all? 
MR. CRITTON: Form. 
THE WITNESS: Relative to this case? 
BY MR. KUVIN: 
Q Yes, relative to the Epstein case? 
A No. 
Q Are all of the officers that were involved 
in the investigation listed or contained within the 
incident report that we've marked as Exhibit 2, and 
were there any additional officers that were 
involved that may not be listed in there? 
A Typically and generally when you say 
involved, I mean that could encompass all sorts of 
different people. It might be -- I don't even know 
that this was the case but it might ask the patrol 
officer in the area to collect license tags from a 
street or something like that. I mean if they 
Page 108 
1 
aren't writing a report and they aren't doing 
2 
something that's probably important later on as a 
3 
witness, they might not appear in there. But the 
4 
detectives who conducted the investigation are 
5 
listed in there from what I recall the last time I 
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read it, and it's been a while, but as far as I 
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know. 
8 
Q At any point, did you have to remove for 
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any reason anyone in your department from the 
10 
investigation for any reason? 
11 
A 
No. It took place over a fairly long 
12 
period of time so people were transferred and so on, 
13 
but I didn't personally remove someone for any 
14 
reason. 
15 
Q And it may not have been you personally, 
16 
but just to make sure that it encompasses all 
17 
potential iterations of that question, was anyone 
18 
removed for any reason other than just someone 
19 
transferring out? 
20 
A 
Do you mean for -- I think you have to 
21 
explain that. 
22 
Q 
Were any of the investigating police 
23 
officers removed for any potential conflicts, 
24 
refusal to follow direction, any reason, other than 
25 
just a transfer out of the department for some 
Pleasanton, 
27 (Pages 105 to 108) 
Greenhill, Meek and Associates 
EFTA00188988

i 
I 
EFTA00188989

Case 9:08-cv-80736-. .44 Document 291-28 Entered on . 3D Docket 01/21/2015 Page 1 of 5 
EXHIBIT 29 
EFTA00188990

Case 9:08-cv-80736....AM Document 291-28 
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Page 2 
ROMA 
IN THE CIRCUIT COURT OF THE 
ENTH JUDICIAL 
CIRCUIT IN AND FOR PALM BEACH COUNTY, 
CASE No.502008CA037315900004B AB 
6 
VOLUME! OF II 
7 
JEFFREY EPSTEIN 
6 
AND 
9 
Defendants. 
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11 
12 
DEPOSMON OF 
13 
DETECTIVE. JOSEPH RECAREY 
14 
Friday, March 19, 2010 
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19 
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21 
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Reported By: 
23 
Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
24 
Prose Can Reporting 
Job No.: 1509 
25 
"a".. 
1 
Page 3 
2 
UNTIED STATES DISTRICT COURT 
3 
SOUTHERN DISTRICT OF FLORIDA 
4 
CASE NO. 10-80309 
5 
JANE DOE NO. 103, 
6 
7 
-vs- 
VOLUME I OF II 
8 
JEFFREY EPSTEIN, 
9 
Defendant. 
10 
11 
12 
DEPOSITION OF 
13 
DETECTIVE JOSEPH RECAREY 
14 
Friday, March 19, 2010 
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9:37 - 5:12 m 
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Reported By: 
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Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
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Prose Court Reporting 
Job No.: 1509 
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Entered on . .SD Docket 01/21/2015 Page 2 of 5 
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APPEARANCES: 
2 
Oa Mho/ford= Plaintiffs," 
3 
SPENCER T. KUVrN, 
UfRE 
K
I 
6 
7 
On behalf of the Plaintiff:1.u.. and 
lane Doe: 
a 
9 
BRADLEY J. ®WARDS, ESQUIRE 
FARMER, JAFFE, WEISSING, EDWARDS 
10 
IRMAN 
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On 
owe 
1 dutch 8: 
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JESSICA ARBOUR, ESQUIRE 
.t.,410WITZ. P.A. 
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ICAIIIERINE W. EZELL, ESQUIRE 
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22 
23 
in
24 
25 
Sera& Ahatowildasexabiseatanney.con 
On behalf ache Hatt 
Jane Does 101, 102/M 
103: 
Page .; 
Page 
1 
Appeantnces oontirhted.. 
2 
On Wulf of the Pluntiffs. 
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ISIDRO MANUEL GARCIA, PIQIIIRE 
MUNGER 
4
7 
TARA A FINNIGAN, ESQUIRE 
GAN, P.A. 
8
10 
11 
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On betalfofthe Defendant kIlier EPOS: 
MICIIAEL PIKE ESQUIRE 
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, LUITER & COLEMAN, LLP 
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and 
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JACK ALAN GOLDBERGER. ESQUIRE 
ER ER & WEISS, P.A. 
18
20 
21 
and 
22 
MILTON 0. WEINBERG, ESQUIRE 
OF MILTON O. WEINBERG 
23 
25 
2 (Pages 2 to 5) 
PROSE COURT REPORTING AGENCY, INC. 
EFTA00188991

Case 9:08-cv-80736-.,AM Document 291-28 Entered on 
_SD Docket 01/21/2015 Page 3 of 5 
Page 279 
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Q. I mean, I'm sorry for such a bad question, 
2 
but in looking at these property receipts, I just 
3 
don't see where it tells me how much time each 
4 
interview had taken. So, I mean, is there an 
5 
average? 
6 
A. That's not going to indicate on any property 
7 
receipt. There is no... 
B 
Q. Right. Okay. Have you ever seen the 
9 
nonprosecution agreement? 
10 
A. No. 
11 
Q. Have you ever seen the attached list of 
12 
victims that was attached as an addendum to the 
13 
nonprosecution agreement? 
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MR. PIKE: Form. 
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THE WITNESS: I believe the Chief had a 
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copy of it. He may have, you know, done one of 
17 
these, but, no, not in my physical hands. 
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MR. PIKE: And just for the record when 
19 
the witness said —
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THE WITNESS: I held it up. 
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MR. PIKE: -- one of these, he held up 
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Exhibit 29. 
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MR. EDWARDS: Which said memorandum. 
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MR. PIKE: Memorandum. 
25 
THE WITNESS: I just held it up. 
Page 281 
1 
A. I remember getting documents from Alan 
2 
Dershowitz which were flight logs pertaining to 
3 
Mr. Epstein's plane. And I subpoenaed the information 
4 
from Jet Aviation, but I don't, I don't recall preparing 
5 
a flight log. 
6 
Q. Okay. Do you remember receiving 
7 
information from Jet Aviation directly? 
8 
MR. PIKE: Form. 
9 
THE WITNESS: Jet Aviation does not keep 
10 
records according to them as to who flies on 
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what plane. I guess you can just drive up to a 
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plane, board it. They have no idea who's on 
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the, who is flying on the plane. They have 
14 
records of when the plane comes in, if the 
15 
plane is serviced, and when the plane leaves. 
16 
BY MR. EDWARDS: 
17 
Q. Did you ever attempt to check with customs 
18 
or FAA on any of the passengers that have ever been 
19 
on international flights with Jeffrey Epstein or on 
20 
his planes? 
21 
MR. PIKE: Form. 
22 
THE WITNESS: I'm trying to recall. 
23 
BY MR. EDWARDS: 
24 
Q. At the current time do you have any 
25 
knowledge of that being done by either the U.S. 
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Page 280 
BY MR. EDWARDS: 
Q. If a memorandum exists and it is the 
attached addendum to the nonprosecution agreement 
containing the names of the underage victims, would 
that be something in the possession currently of the 
Palm Beach Police Department? 
MR. PIKE: Form. 
THE WITNESS: I don't believe so. 
BY MR. EDWARDS: 
Q. Is that something that's been destroyed or 
also --
MR. PIKE: Form. 
THE WITNESS: I never received a copy of 
it so... 
BY MR. EDWARDS: 
Q. Have you ever seen it? 
A. Like 1 said, I may have seen it. I may have 
been shown it, you know, and just by holding it up and I 
am only using this exhibit as an example. It may have 
been just shown to me like this but not in my hands 
where I actually read the entire document. 
MR. PIKE: Move to strike. 
BY MR. EDWARDS: 
Q. In your investigation, did you prepare a 
flight log summary? 
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Page 282 
Attorney's office or the FBI? 
A. I have no idea what the FBI does. They are 
primarily one way. You give them the information and 
nothing comes back, so... 
Q. I am starting to get that idea. I am 
understanding that. Okay. 
A. But you know, and I work with them almost on a 
daily basis, so I am in direct contact with them. And 
still I have yet to see information come back the other 
way. 
Q. Just so the record is clear, when you say 
you're working with them on a daily basis, when 
you're in the Organized Crime Unit on other cases, 
correct? 
A. Yeah, and I am also assigned to the JTTF, the 
Joint Terrorism Task force here in West Palm Beach. 
Q. My understanding from reading your reports 
is that you also subpoenaed phone records of 
numerous individuals, correct? 
A. Correct. 
Q. One of those individuals is Jeffrey 
Epstein? 
A. I believe so. 
A. Yes. 
39 (Pages 279 to 282) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601-051.976.2934) 
Electronically signed by cynthia hopkIns (601-051.976.2934) 
Electronically signed by cynthia hopkIns (601-051.976.2934) 
sa2a5ddb-fa81-O(6-b3b7-dcda51494142 
EFTA00188992

Case 9:08-cv-80736-..AM Document 291-28 Entered on 
—.3D Docket 01/21/2015 Page 4 of 5 
Page 299 
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stuck around just to assist the victims. 
2 
BY MR. EDWARDS: 
3 
Q. And when you talk about the statement that 
4 
you provided, did you present testimony related to 
5 
all of the minor females that you discovered to have 
6 
come in contact with Jeffrey Epstein or only the 
7 
four or five names that ultimately were at the end 
8 
of your probable cause affidavit? 
9 
MR. PIKE: Form and compound. 
10 
'NE WITNESS: As far as my testimony at 
11 
the grand jury, I only answered the questions 
12 
that were asked of me by the state. At that 
13 
point it was Lanna Belohlavek. 
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I'm sorry about the last name. Won't 
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know how to spell her last name. 
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BY MK EDWARDS: 
17 
Q. And in talking with the State Attorney's 
18 
Office during the investigation, did you indicate to 
19 
them the number of underage females that you were 
20 
aware had come in contact sexually with Mr. Epstein? 
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MR. PIKE: Form and assumes facts not in 
22 
evidence. 
23 
THE WITNESS: Yes, they were aware of the 
24 
probable cause affidavit which indicated all 
25 
the facts. 
Page 301 
1. 
between the Palm Beach Police Department and the 
2 
State Attorney's Office? 
3 
A. Yes, there was. 
4 
Q. And --
5 
A. This case was originally brought to their 
6 
attention very early on in the investigation to which 
7 
they were, you know, very gung-ho, very let's go, let's 
8 
do this, up until, up until, up until the meeting with 
9 
Alan Dershowitz and the State Attorney. And then it, it 
10 
all took a turn. 
11 
Q. Were you at that meeting? 
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A. 1 attended one meeting where I believe it 
13 
Dershowitz, Krischer, and Belohlavek. 
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MR PIKE: Object to form. 
15 
BY MR. EDWARDS: 
16 
Q. What was said during that meeting? 
17 
MR. PIKE: All right. With regard to this 
18 
line of questioning, I just want to be clear 
19 
that I have form objections to this line of 
20 
questioning. And the fact that under various 
21 
Federal Rules, I believe it's 408, 410 as well 
22 
as various rules under Florida Evidence Code, 
23 
some of these discussions are protected as 
24 
potential plea negotiations. So, having said 
25 
that... 
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Page 300 
BY MR. EDWARDS: 
Q. And can you recall what their position was 
on the various acts that are related in the probable 
cause affidavit? And ultimately I am asking why is 
it that they were not interested in hearing from all 
of the girls and only a select few? 
MR. PIKE: Form and compound. 
THE WITNESS: That's a question that 
you're going to have to ask Lanna Belohlavek 
because she was aware of all the people that I 
submitted to her, and yet she choose three 
people to appear before the grand jury, one 
knowing that she was not going to be able to 
appear. 
MR. PIKE: Move to strike. 
BY MR. EDWARDS: 
Q. And who was the person that was not going 
to be able to appear? 
A. That would have been Jane Doe No. 103. 
Q. Do you know why she was unable to appear? 
A. Because it was finals week in her university 
and the limited time that they had scheduled the grand 
jury and the time that it would have been for her to 
make arrangements to come down was very short. 
Q. Was there a disagreement about this case 
Page 302 
1 
BY MR. EDWARDS: 
2 
Q. What was said during these, this meeting 
3 
that you attended? 
4 
A. Several of the girls' MySpaces were discussed. 
5 
MySpace being the social network. They all had 
6 
MySpaces. And the girls, the girls were actually who 
7 
had the MySpaces had inputted, you know, various 
8 
different things regarding alcohol use or marijuana use 
9 
or that kind of thing. 
10 
Q. And what was brought up at that meeting as 
11 
to the relevance of whether or not these females 
12 
that had been to Jeffrey Epstein's house while 
13 
underage used alcohol or drugs? What was the point 
14 
of that? 
15 
MR. PUCE: Form. 
16 
THE WITNESS: To show that the character 
17 
of the girls were not, was not to be believed. 
18 
BY MR. EDWARDS: 
19 
Q. Okay. It was specifically to attack their 
20 
credibility? 
21 
MR. PIKE: Form, move to strike. 
22 
THE WITNESS: Correct. 
23 
BY MR. EDWARDS: 
24 
Q. So, at that point in time who was making 
25 
those arguments on behalf of Jeffrey Epstein? 
PROSE COURT REPORTING 
Electronically signed by cynthla hopktns (601-051-976-2934) 
Electronically signed by eynthia hopkins (601-051.976-2934) 
Electronically signed by cynthla hopkins (601-051.976.2934) 
44 (Pages 299 to 302) 
AGENCY, INC. 
aa2a5ddb-1481-06-b3b7-deda51494142 
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Page 307 
attorneys have been unanswered and messages remain 
unreturned. Is that a statement that you agree 
with? 
A. Absolutely. 
Q. How many messages do you think that you 
left the State Attorney's Office that were 
unreturned? 
A. Quite a few. I actually showed up at Lanna's 
office because I had left her several messages and 
didn't, didn't return get a return phone call. And it 
was during the time where: We're going to the grand 
jury, no, we're not going to grand jury-, yes, we're 
going; no, we're not. 
And it was, I believe, the following day 
when we were supposed to go to the grand jury and I 
still had not heard from her as to what time nor had 
I received a subpoena So, I had contacted her 
numerous times during that day. I would say three 
to four times during that day. In the afternoon 
actually showed up at her office where she was 
sitting in her office. 
Q. Did you speak with her? 
A. Yes, I did. 
Q. And what happened within that 
conversation? 
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Page 309 1
A. Correct. 
MR. PIKE: Form. 
BY MR. EDWARDS: 
Q. So, are you talking about A.D., C.L., 
S.G., and Jane Doe No. 103? 
MR. PIKE: Form. 
THE WITNESS: From S.G.'s family I had 
gotten multiple phone calls during that day. 
BY MR. EDWARDS: 
Q. During any of the meetings -- how many 
meetings are you aware of that Mr. Dershowitz 
participated in with the State Attorney's Office? 
A. There were a couple. Like I said, I attended 
one. 
MR. PIKE: Form. 
THE WITNESS: I didn't attend the second 
one. I want to say two to three. 
BY MR. EDWARDS: 
Q. And he is a person who also is found in 
the message pad as somebody who has called Jeffrey 
Epstein's home, correct? 
A. As far as I can recall, yes. 
Q. And did he ever indicate to them that he 
was actually at the home on various occasions when 
some of these underage girls would come over to 
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Page 308 
MR. PIKE: Form. 
TI-LE WITNESS: There was actually a time 
where there was a plea negotiation being 
discussed where it was to one count of felony, 
five years probation, and I believe no one had 
been contacted regarding to that negotiations. 
BY MR. EDWARDS: 
Q. When you say no one, are you speaking 
about the police or victims? 
MR. PIKE: One second. Form. I'm going 
to move to strike and I am going to continue to 
assert the same privileges under the Federal 
Rules 408, 410, and 401.9. I'm sorry. Go 
ahead. 
BY MR. EDWARDS: 
Q. When you say no one had been contacted, 
are you speaking about no police officers that were 
on the case or no victims? 
A. Both the police officers and the victims 
because I was getting phone calls from the victims' 
parents as to what time are we needed. 
Q. And when you say we were getting phone 
calls from the victims' parents, are those the 
victims that ultimately were listed as victims in 
the, in the plea that transpired? 
Page 310 
1 
Mr. Epstein's house? 
2 
MR. PIKE: Form. 
3 
THE WITNESS: Not that I recall. 
4 
BY MR. EDWARDS: 
5 
Q. In fact, was he trying to convey to the 
6 
State Attorney's office that you should not believe 
7 
these girls that they were at his house at all 
8 
because they have credibility problems? 
9 
MR. PIKE: Form, asked and answered. 
10 
THE WITNESS: That's, that was the 
11 
impression I received, yes. 
12 
MR. EDWARDS: The next portion is going to 
13 
take a long time. I mean it's getting into the 
14 
juice of it. So, are we at a point that you 
15 
want to stop rather than getting into something 
16 
that's going to take a long time? 
17 
MS. O'CONNOR: How long? 
18 
MR. EDWARDS: Couple of hours. 
19 
MS. (YCONNOR: I need to stop. 
20 
MR. KUVIN: Okay. 
21 
MR. PUCE: All right. So we are going to 
22 
break. We have an agreement on the record that 
23 
Detective Recarey, and correct me if I am 
24 
wrong, Ms. O'Connor will get back to us through 
25 
you sometime next week with a few available 
46 (Pages 307 to 310) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthla hopkins (601-051.976.2934) 
Electronically signed by cynthia hopkins (601-061-976-2934) 
Electronically signed by cynthia hopkins (601.051-976-2934) 
aa2aftddb-fa81-41%-b3b74/cda61494142 
EFTA00188994

EFTA00188995

Case g:08-cv-00,S6 ...I Document 291-29 Enle... 
_SD...01/MM 
Page 1 of 1 
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