EFTA00298259

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-CIV-80119-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
VOLUME I OF II 
Related cases: 
08-80232, 08-08380, 08-80381, 08-80994 
08-80993, 08-80811, 08-80893, 09-80469 
09-80591, 09-80656, 09-80802, 09-81092 
DEPOSITION OF 
DETECTIVE JOSEPH RECAREY 
Friday, March 19, 2010 
9:37 - 5:12 p.m. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting 
Job No.: 1509 
PROSE COURT REPORTING AGENCY, INC. 
EFTA00298259

EFTA00298260

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 
2 
CASE No.502008CA0373150000TMB AB 
3 
5 
6 
7 
B.B.
8
Plaintiff, 
-vs- 
VOWME 1 OF11 
~SI 
Defendants. 
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10 
11 
12 
DEPOSMON OF 
DETECTIVE JOSEPH RECAREY 
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Friday, March 19, 2010 
937- 5:12 pm. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Cynthia Ilepldns, RPR, FPR 
23 
Notary Public, State of Florida 
Prose 
 Reporting 
24 
ØQØ 
509 
25 
1 
APPEARANCES 
2 
On behalf or Ole Plaintiffs, BE, CL: 
3 
SPENCER T. KUVIN, ESQUIRE 
LEOPOLD KUVIN 
2925 PGA Boulevard 
State 200 
5 
Palm Beach Gardens, Florida 33410 
Phone: 
6 
On behalf of the Plaint", L.M., SW. and 
Jane Doe: 
e 
9 
BRADLEY J. EDWARDS. ESQUIRE 
FARMER. LOW, WEISSRM. EDWARDS 
10 
195 Kra & LEHRMAN, P.L 
425 North Andrews Avenue 
11 
Suite 2 
Fort Lauderdale, Florida 33301 
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Mom' 
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On lzhalf 
Ø6h 8:
14 
JESSICA ARBOUR, ESQUIRE 
MERMELSIEN 8cHOROWITZ,P.A. 
25 
18205 Biscayne Boulevard 
Suite 2218 
16 
Miami, Florida 33160 
Plasm. 
17 
E-mail: 
18 
0815~0 o 
K 
i 
, 
488 
103: 
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KATHERJHE W. EZELL ESQUIRE 
PODHURST ORSECK 
21 
25 West Elegier Street 
Suil4 800 
22 
Minne- FØ 
33130 
Ph 
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onc~ 
<Via 
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Page 3 
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UNTIED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 10-80309 
4 
5 
JANE DOE NO. 103, 
6 
Plaintiff, 
7 
-vs- 
VOLUME I OF R 
8 
JEFFREY EPSTEIN, 
9 
Defendant. 
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I 
DEPOSITION OF 
DETECTIVE JOSEPH RECAREY 
Friday, March 19, 2010 
9:37 - 5:12 p.m. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Cynthia Hopkins, RPR, FPR 
23 
Notary Public, State of Florida 
Parse Court Reporting 
24 
fob No.: 1509 
25 
1 
Apecaianoes (*mimed 
2 
On behalf of the Ptainttffs: 
3 
ISIDRO MANUEL GARCIA, ESQUIRE 
GARCIA, ELKINS & LIOEBRINOER 
224 Datura Awnuc, Sub< 900 
W491 him Beach, Florida 33401 
5 
!tone 
6 
and 
7 
TARA A. FINNIGA/4, ESQUIRE 
TARA A. FINNTOAN, P.A. 
a 
224 Datum Street 
Suite 900 
9 
West Min Buck Florida 3340) 
Phone' 
10 
11 
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On behalf of the Defendant, Jeffrey Egleix 
MICHAEL PIKE, ESQUIRE 
BURMAN, LØN, 
LUTITER & COLEMAN. LLP 
13 
303 Banyan Boulevard 
SUN 400 
14 
West Palm Beach. florid' 33401 
Phone 
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16 
and 
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JAC* ALAN GOLDBERGER., ESQUIRE 
ATTERBURY, GOLDB/eRGF.R & WEISS, P.A 
18 
250 Australian Avenue South 
Suite 1400 
19 
West Patin Eked\ Florida 334014012 
Phone: 
20 
21 
22 
and 
MILTON G. WEINBERG, ESQUIRE 
LAW OFFICE OP MILTON G WEINBERG 
23 
10 Park Plata 
Suite 1000, 
24 
Bost" Map:schwa 02116 
Phon 
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2 (Pages 2 to 5) 
PROSE COURT REPORTING AGENCY, INC. 
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PLAINTIFFS EX. 1 
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AFFIDAVIT 
PLAINTIFFS EX. 2 
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PLAINTIFF'S EX 3 
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PLAINTIFFS EX 4 
Appearances continued... 
2 
On behalf of the Witness: 
3 
JOANNE M. O'CONNOR, ESQUIRE 
JONES, FOSTER, JOHNSON & STUBBS, PA 
4 
505 South Flagler Drive, Suite 1100 
: 
West t
ida 33401 
Phone 
Also Present: Jeffrey Epstein 
INDEX 
EXAMINATION 
DIRECT CROSS REDIRECT 
DETECTIVE JOSEPH RECAREY 
MR. KUVIN 
9 
BY MR. EDWARDS 
242 
EXHIBITS
EXHIBIT 
DESCRIPTION 
PAGE 
PROBABLE CAUSE 
15 
INCIDENT REPORT 
23 
INCIDENT REPORT 
45 
PROPERTY RECEIPTS 
126 
1 
PROCEEDINGS 
2 
MR. KUVIN: Just so we're clear with 
3 
respect to the deposition, I understand that 
4 
Mr. Epstein has three attorneys here today but 
5 
only one of them, pursuant to the Rules, is 
6 
going to be permitted to object to questions. 
7 
So I just wanted a designation as to which 
8 
attorney is going to be objecting to questions. 
9 
MR. PIKE: I will be objecting and 
10 
Mr. Weinberg will probably be asking questions. 
11 
I don't — 
1 2 
MR. KUVIN: I have no problem -
13 
MR. PIKE: Do you have any objection with 
14 
that? 
15 
MR. KUVIN: I have absolutely no problem 
16 
if you want to switch it up as to who is 
17 
objecting and who is asking questions. That's 
18 
not a problem. I just don't want to get three 
19 
set of objections. 
20 
MR. PIKE: twill be the main on the 
21 
objections and Mr. Weinberg will be taking, 
22 
asking the questions. 
23 
MR. GOLDBERGER: Do we have to tag each 
24 
other? 
25 
MR. KUVIN: No. I would prefer you 
2 
MERITS CONTINUED_ 
MINT 
DESCRIPTION 
PAGE 
nAmmnsEcaAnwnnvmximn 
127 
PLAINTIFFS EC 5 SUPPLEMENT FOR own 151 
OP CUSTODY LOG 
PLAINEFFS EC 6 PAGE FROM MESSAGE PAD 196 
PLAINTIFFS ER 7 Moue MESSAGE 
204 
PIA/MPS EX 8 PHONE MESSAGE 
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PLAINTIFFS DC 9 PHONE MESSAGE 
208 
PLAINTIFFS DC 10 PHONE MESSAGE 
209 
PLAINTUTS EX 11 PHONE MESSAGE 
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PLAINTIFFS EC 12 PHONE MESSAGE 
212 
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PLAINTIFFS EC 13 PHONE MESSAGE 
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PLAINTEFFS DC 14 PHONE MESSAGE 
215 
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PLAINTIFFS Et. 15 PHONE MESSAGE 
215 
PLAINTIFF'S DC 16 PHONE MESSAGE 
217 
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PLAINTIFFS DC 17 PHONE MESSAGE 
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PLAINTIFFS DC 18 PHONE MESSAGE 
220 
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PLMNTIFFS DC. 19 PHOLE MESSAGE 
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PLAINTIFFS DC 20 PHONE MESSAGE 
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PLAINTIFF'S DC 21 PHONE MESSAGE 
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PLAINTIFFS EX. 22 PHONE MESSAGE 
225 
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PLAINTIFFS Et 23 AND 24 PHOTOS 
227 
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PlAINTIFFS EX. 26MS. 
240 
PLAIN
 EC 25 PH 
E 
230 
CELLPHONE LOG 
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pLAEMPFS EX. 27 LEITER DATED JULY 24, 241 
2006 
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PLAINTIFFS DC 28 INTELLIGENCE REPORT 243 
DATED 112804 
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Page 7 
Page 9 
1 
wouldn't talk at all, but we'll deal with that 
2 
later. 
3 
(A discussion was held off the 
4 
record.) 
5 
Thereupon, 
6 
(DETECTIVE JOSEPH RECAREY) 
7 
Having been first duly sworn or affirmed, was 
8 
examined and testified as follows: 
9 
THE WITNESS: I do. 
10 
DIRECT EXAMINATION 
11 
MR. KUVIN: All right. Just as a 
12 
stipulation on the record so that we have it 
3 
all clear, what we have discussed prior to 
14 
starting the deposition is, is that since we're 
15 
discussing girls which were under the age of 
16 
18, minors at the time of the incidents 
17 
involved in this case, we're going to be using 
18 
their names as previously agreed to in all the 
19 
other depositions in the case pursuant to court 
20 
order. 
21 
The names will be used in the 
22 
deposition, but they will not be used in 
23 
the official transcript. There will be a 
24 
key at the end of the transcript which 
25 
will be sealed and confidential onl for 
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the eyes only of the attorneys involved in 
2 
this litigation. 
3 
Therefore, Detective Recarey should 
4 
feel free to discuss names with the 
5 
understanding that those names shall not 
6 
be made public outside the lawsuits that 
7 
are currently pending in both state and 
B 
federal court. But that way hopefully it 
9 
will avoid confusion and I just want to 
10 
make sure we get agreement from all 
11 
counsel sitting around the table that that 
12 
is the understanding. And if there is any 
13 
clarification on that issue, please let us 
14 
know. 
15 
MR. PIKE: Agreed. 
16 
MR. EDWARDS: Agreed. 
17 
MR. GARCIA: Agreed. 
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MS. ARBOUR: Agreed. 
19 
MR. KUVIN: Katherine, agreed? 
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MS. P7RII • Yes, I am here. 
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MR. KUVIN: Did you hear my stipulation? 
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MS. P7Pli  : Yes. 
23 
MR. KUVIN: Do you agree with that? 
24. 
MS. WPM: Yes. 
25 
MR. KUVIN: Okay. 'just wanted to make 
Page 12 
1 
Q. All right. We're going to be talking to 
2 
you today about incidents that occurred back in 
3 
roughly 2005,'6, and 7. During that period of 
4 
time were you a detective? 
5 
A. Yes. 
6 
Q. Okay. All right. And lets just 
7 
summarize briefly what you're going to talk about 
8 
first and then we'll get down into the details of 
9 
it. 
10 
Did you have occasion to begin an 
11 
investigation with respect to a gentleman by the 
12 
name of Jeffrey Epstein? 
13 
A. Yes, I did. 
14 
Q. And when did that investigation begin 
15 
roughly? 
16 
A. That case was assigned to me on September. ] 
17 
believe, of 2005. 
18 
Q. And what were you assigned to investigate? 
19 
A. There was an allegation of an underaged female 
20 
that had went to the home of Mr. Epstein and was asked 
21 
to perform a massage at which time it became sexual in 
22 
nature and she was paid for her services. 
23 
Q. All right. 
24 
MR. PIKE: fin going to object to fomi as 
25 
speculation and hearsay and move to strike. 
Page 11 
1 
it clear. 
2 
MS. EZELL: Thank you. 
3 
BY MR KUVIN: 
4 
Q. Why don't you give us your full name, if 
5 
you would, please. 
6 
A. Joseph Recarey. 
7 
Q. Detective Recarey, could you please tell 
8 
us what you do fora living. 
9 
A. I am a detective with the Town of Palm Beach 
10 
Police Department. 
11 
Q. How long have you been a detective for the 
12 
Town of Palm Beach? 
13 
A. Approximately 15 years. 
14 
Q. And what is your exact title there for the 
15 
Town of Palm Beach? 
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A. Detective or a police officer. 
17 
Q. Do you work in a particular unit? 
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A. The — currently assigned to the Organized 
19 
Crime/Vice and Narcotics. 
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Q. How long have you been assigned to that 
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unit? 
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A. Approximately three years. 
23 
Q. Okay. What did you do before that for the 
24 
town? 
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A. I was a general detective. 
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Page 13 
BY MR. KUViN: 
Q. With respect to the investigation that you 
performed, how long roughly did that investigation 
last? in other words what period of time are we 
looking at here from beginning to end? And if it 
helps you, I have the incident report. 
A. It was approximately, I believe, a year. 
Q. Okay. Could you summarize for us 
generally, and like 1 said we'll get into details by 
going through it, but generally what did you do 
during the investigation? 
MR. PIKE: Form. 
THE WITNESS: Conducted interviews, 
executed a search warrant, issued subpoenas. 
continued with interviews. 
BY MR. KUVIN: 
Q. When you did the interviews, are we 
talking about any interviews with Mr. Epstein? 
A. No, there was no interviews with Mr. Epstein. 
Q. Did he ever agree to talk to you? 
A. Originally when I was speaking with attorney 
Guy Fronstin, there was a mention that he would be 
available for an interview. However, that never came to 
be. 
Q. Why not? 
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MR. PIKE: Same objection. 
1 
with either 
In Mend 
who were 
2 
THE WITNESS: It was discussed that he 
2 
minors at the time of the incidents that 
3 
would not appear to, for any interview. 
3 
occurred. 
4 
BY MR. KUVIN: 
4 
MR. PIKE: Move to strike. 
5 
Q. All right. Eventually a probable cause 
5 
BY MR. ICUVIN: 
6 
affidavit was filled out in and around May of 2006; 
6 
Q. Did you feel there was sufficient possible 
7 
is that coned? 
7 
cause to charge Mr. Epstein at that time and if so 
8 
A. Correct. 
8 
with what? 
9 
Q. And what was the basis of the probable 
9 
MR. PIKE: Font 
10 
cause affidavit if you could summarize for it for 
10 
NE WITNESS: Yes, I did, and it was with 
11 
us? What were — what did you find after doing your 11 
four counts of Unlawful Sexual Activity with a 
12 
investigation? 
12 
Minor, and one count of Lewd and Lascivious 
13 
13 
Molestation. 
MR. PIKE: Form. 
14 
THE WITNESS: There were several victims 
14 
BY MR. KUVIN: 
15 
that had been interviewed based on their age, 
15 
Q. All right. The lewd and lascivious 
16 
the acts that occurred at the residence. There 
16 
molestation charge, could you explain that a little 
17 
was enough probable cause to request a warrant 
17 
more as well? 
18 
for Mr. Epstein. 
18 
MR. PUCE: Form. 
19 
BY MR. KUVIN: 
19 
THE WITNESS: The victim, that was the 
20 
Q. All right. And for those that might not 
20 
initial victim that came forward, it was a 
21 
understand, a warrant means what? 
21 
14-year-old minor at the time of the incident. 
22 
A. An arrest warrant. 
22 
She had gone to the house. This was the 
23 
MR. KUVIN: Okay. I would like to show 
23 
initial report that was taken by Officer Pagan. 
24 
you what we'll mark as Exhibit 1. Why don't 
24 
14 at the time. Was brought over to perform a 
25 
you give me a shed 
25 
massage. The incident turned into a, sexual in 
Page 15 
Page 17 
1 
(Plaintiffs Exhibit No. 1 was marked for 
1 
nature, and it was at the time she was paid for 
2 
identification.) 
2 
her services and left. 
3 
BY MR. KUVIN: 
3 
MR. PIKE: Move to strike.
4 
Q. All right. What we have marked as 
4 
MR. KUVIN: 
5 
Exhibit 1, is that the probable cause affidavit that 
5 
Q. Okay. Now, this personM,col ou come 
6 
you filled out with respect to Mr. Epstein? 
6 
to learn that her name at the time was 
7 
A. Correct. 
7 
A. Yes, I did. 
8 
Q. And does your signature appear on each and 
8 
Q. All right And according to the 
9 
every page of this probable cause affidavit? 
9 
information you had, she was how old at the time 
10 
A. Correct. 
10 
that she came over to Mr. Epstein's house for the 
11 
Q. And is that your signature at the bottom 
11 
sexual contact? 
12 
left corner? 
12 
MR. PIKE: Form. 
13 
A. Yes, bottom right 
13 
THE WITNESS: Fourteen. 
14 
15 
Q. Bottom right. I apologize. 
All right: Let's go to, if we could, 
14 
15 
BY MR. KUVIN:
Q. All right Was she the youngest that you 
16 
Page 22 of 22. And the last paragraph, could you 
16. 
were able to determine came to Mr. Epstein's home 
17 
explain to us the conclusions in the probable cause 
17 
during your investigation? 
18 
affidavit and exactly what Mr. Epstein was being 
18 
A. Coned. 
19 
arrested for at the time? 
19 
MR. PIKE: Form. 
20.
MR. PUCE: Form. 
20 
BY MR. KUVIN:
21 
THE WITNESS: Based on the interviews 
21 
Q. All right. With respect to the others, 
22 
conducted, it was determined that Mr. Epstein, 
22 
justso we have it on the record and we're clear,. 
23 
who at the time of the incident was 
23 
would have been whom? 
24 
approximately 51 years of age, did have vaginal 
24 
A. Jane Doe No. 103. 
25 
intercourse either with his penis or
25 
5 (Pages 14 to 1 7) 
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A. Jane Doe No. 2. 
2 
MR. PIKE: I am going to object to form 
3 
through these series of questions so we don't 
4 
have to keep repeating with regard to the 
5 
information. 
6 
MR. KUVTN: Yeah, well, I want to make 
7 
sure I understand what is the form objection. 
8 
MR. PIKE: Your, your questions are 
9 
relating back to opinion and hearsay evidence 
10 
and the investigation. So, actually just go 
11 
ahead and I will put it on the record. Go 
12 
ahead. 
13 
MR. KINN: All right. I just wanted to 
14 
make sure I knew because I wanted to fix them 
15 
if there was something that I could do to fix 
16 
them. 
17 
MR. PIKE: I don't think you can unless 
18 
you want to start the depo over. 
19 
MR. ICUV1N: No, but I can start from now. 
20 
MR. PIKE: Let's go. 
21 
BY MR. KUVIN: 
22 
Q. All right. During your investigation did 
23 
you identify who III was, and if so who? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: Yes, I did. I identified 
Page 20 
1 
A. So many things occurred with the State 
2 
Attorneys Office. Originally it was determined that it 
3 
was going to.be a grand jury. 
4 
Q. Okay. 
5 
A. And then the case was going to be presented to 
6 
the grand jury. That was later retracted and they 
7 
wanted a probable cause affidavit 
8 
Q. Okay. 
9 
A. I submitted the probable cause affidavit 
10 
Shortly thereafter I was told we're going back to the 
11 
grand jury. 
12 
Q. Okay. Well, let me ask you this: After 
13 
the probable cause affidavit was issued, did you 
14 
institute the search of the home at that point or 
15 
you institute the search of the home before the 
16
davit was —
17 
A. Prior, prior to theMaffidavit. 
18 
Q. Okay. All right. Let's go back. Why 
19 
don't you give us, if you would, briefly your 
20 
training and experience as an officer. Just start 
21 
with, you know, where you went to the academy and 
22 
where you started working and then kind of work us 
23 
through to when you got your job at Palm Beach 
24 
County or Palm Beach. 
25 
A. I went to the police academy back in 1990 --
Page 19 
S 
2 
BY MR. KUVIN: 
Q. 
C
A
 
is who? 
3 
: Same objection. 
6 
BY MR. KUVIN: 
7 
Q. Okay. Now, these girls that you 
8 
identified in your probable cause affidavit here at 
9 
the conclusion, did you find that all of these girls 
10 
were under the age of 18 at the time they went to 
1.1 
Mr. Epstein's home? 
12 
MR. PIKE: Form. 
13 
THE WITNESS: Correct. 
14 
BY MR. KUVIN: 
15 
Q. And how old were they? 
16 
A. They were approximately 16, 15, 16 and/or up 
17 
to 17 years of age. 
18 
MR. PIKE: Form. 
19 
BY MR. KUVIN: 
20 
Q. Okay. All right: Do you recall how old 
21 
C.L. was? 
22 
A. I believe she was 16. 
23 
Q. After filling out and signing the probably 
24 
cause affidavit, could you explain to us what 
25 
reared next? 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
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15 
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17. 
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23' 
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Page 21 
Q. Okay. 
A. -- down here in Palm Beach County. I was 
hired by Palm Beach in 1991 where 1 did three years on 
the, as a patrol officer. 
Q. Okay. 
A. I was transferred then to the detective 
bureau. 
Q. Roughly when? 
A. '94. 
Q. Okay. 
A. From the detective bureau, I went to the 
Organized Crime/Vice and Narcotics Unit where I spent 
about five, six years. 
Q. When did you get into that unit roughly? 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
. 
A. 
2006. 
I would say *96, '95, '96. 
Okay. And you spent how long there? 
About roughly five to six years. 
All right. Then where did you go? 
Back to the detective bureau. 
So we're looking at like 2000 and 2001? 
Correct 
All right 
I was there for up to 2006, I believe, 2000 --
Okay. And then in 2006? 
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A. They created another, a unit from the 
2 
Organized Crime/Vice and Narcotics Unit. Made it 
3 
special investigations. Went over to there where Pm --
it was renamed back to the Organized Crime/Vice and 
5 
Narcotics. 
Q. Okay. 
A. That's basically what we would operate on. 
8 
Q. Gotcha. And you've been in that unit 
9 
since then to the present day? 
10 
A. Correct 
11 
Q. Okay. Have you ever worked in any other 
12 
department? 
13 
A. I worked for the State Attorney's Office as a 
14 
process server for five years. 
15 
Q. Okay. And that was before going to the 
16 
academy in 1990? 
17 
A. Correct. 
18 
Q. Okay. High school graduate? 
19 
A. Correct. 
20 
Q. Any secondary schooling, college? 
21 
A. College credits and specialized training with 
22 
the police department. 
23 
Q. Okay. Did you get an AA in college or no? 
24 
A. No. 
25 
Q. Okay. Where did you get your college 
Page 24 
1. 
Department Incident Report which appears to be 
2 
numbered, thankfully, and consists of 87 pages plus 
3 
one. It looks like there is 87 consecutively 
4 
numbered pages and then a single page again numbered 
5 
as Page I, just for the record. 
6 
All right. First of all, do you 
7 
recognize what we have marked as Exhibit 2? 
8 
A. Yes, !do. 
9 
Q. And could you describe for us what that 
10 
is? 
11 
A. It is the Palm Beach Police Department's 
12 
Incident Report. 
13 
Q. AM right. When this investigation first 
14 
began, were your, were you the first one that was 
15 
contacted regarding potential allegations against 
16 
Mr. Epstein? 
17 
MR. PIKE: Form. 
18 
THE WITNESS: No, I was not. 
19 
BY MR. KLIVIN: 
20 
Q. Who was the first one that was actually 
21 
contacted, and could you explain to us if you NNW IL. 
22 
how they were contacted? 
23 
A. It was Officer Michele Pagan. 
24 
Q. Okay. And do you blow as you sit her: 
25 
today under what circumstances she was contacted? 
1 
credits? 
2 
A. PBCC. 
3 
Q. Are you from here locally, Palm Beach? 
4 
A. No. 
5 
Q. Where from? 
6 
A. New York City. 
7 
Q. When did you come down here? 
8 
A. 1980. 
9 
Q. Okay. All right Let's walk through kind 
10 
of chronologically what occurred in this particular 
11 
case. And just so that it's easier for you, let me 
12 
give you the incident report. What I will do is I 
13 
am going to ask you questions. 
14 
If you need to refresh your 
15 
recollection at any point with the incident report, 
16 
just let us know that you're using it to refresh 
17 
your recollection which is fine. I just want to 
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make sure that we can distinguish between what you 
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may recall indepcudendy versus what you may be 
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using to refresh your recollection. 
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(Plaintiffs Exhibit No. 2 was marked for 
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identification.) 
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BY MR. KUVIN: 
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Q. All right. I'm going to give what you we 
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have marked as Exhibit 2 as the Palm Beach Police 
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A. I believe it was telephonicalliiitelephone. 
Q. Okay. Was she contacted by 
herself 
or her parents, do you remember? 
MR. PIKE: Form. 
THE WITNESS: I totally believe it was the 
step-mother that called her. 
BY MR.. KUVIN: 
Q. Okay. When Ms. Pagan took down that 
inforMation, how soon after were you actually 
brought into the investigation? 
A. I believe she took the report in March, and I 
took, I took possession of the case in September. 
Q. Do you know why the break in time between 
March and September when you actually get it? In 
other words do you know why you got the case some 
months later? 
A. She was transferred to patrol. 
Q. Okay. So, Ms. Pagan was originally 
investigating this case —
A. Correct. 
Q. -- until she got transferred to patrol? 
A. Yes. 
Q. Did her transfer to patrol have anything 
to do with this case? 
A. No. 
.7crodrol.16 
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Q. Okay. When you take over the 
2 
investigation in September — and just so we're 
3 
clear we're talking about September of 2005? 
4 
A. Correct. 
5 
Q. When you take over that case, do you take 
6 
any particular action to bring yourself up to speed 
7 
on what's going on? 
8 
A. I reviewed her reports and listened to the 
9 
interviews and what she had already evidentiary-wise. 
10 
Q. Okay. Let's go to, if you would, Page 22 
11 
of the incident report. Just so we can make sure 
12 
that we have an accurate chronology here, it appears 
13 
right in the middle of the page we have got the date 
14 
of September 8, 2005. And it states: I reviewed 
15 
the case notes of this file as the case will be 
16 
turned over to Detective Recarey. Do you see that? 
17 
A. Yes, I do. 
18 
Q. Was that roughly the dale that the 
19 
investigation was turned over to you? 
20 
A. No. It was turned over officially I think the 
21 
19th. 
22 
Q. Okay. And we see that in Narrative 2 at 
23 
the bottom of the same page? 
24 
A. Correct 
25 
Q. All right. And the first entry there says 
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the investigation early on --
MR. KUVIN: Okay. 
THE WITNESS: — as bringing ill 
BY MR. KUVIN: 
Q Okay. Any other minors that you can 
recall came up at that point; in other words the 
point between when Ms. Pagan starts the 
investigation until when you take it over? 
MR. PIKE: Object to the fonn. 
THE WITNESS: No, not that I can recall. 
BY MR. KUVIN: 
Q. Okay. Where is Ms. Pagan today? Is she 
here locally? 
A. Yes, she's still with the police department. 
She rides the bicycle. 
Q. Okay. If you would, can you turn to 
Page 17 for me of the Incident Report. Towards the 
bottom, third paragraph from the bottom, it 
tefetwces a cross-reference of Epstein's residence. 
Do you see that? 
A. Uh-huh. 
Q. What was the residence that you found for 
Mr. Epstein, the address, the physical address? 
A. 358 El Brillo. 
Q. Palm Beach Island? 
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Page 27 
on September 19, 2005, you met with Officer Pagan 
and received the information pertaining to the case? 
A. Correct. 
Q. All right. When you received that 
information, is it safe to assume that you reviewed 
the investigation materials that Michelle Pagan had 
collected up until that date? 
A. Yes, I believe so. 
Q. Okay. At this point in time do you know 
bow many potential victims there were of 
Mr. Epstein? 
MR. PIKE: Form. 
THE WITNESS: No, we didn't know the 
octant of how many victims at that point. 
BY MR. KUVIN: 
Q. All right. We 'mow that 
step-mother had called in and there as an 
investigation regarding her. Were there any other 
minors at that point that had come into the 
investigation? 
MR. PIKE: Fonts. 
WITNESS: We knew of a girl by name of 
MR. KUVIN: Okay. 
THE WITNESS: That her name had come up in 
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Page 29 
A. Correct. 
Q. Okay. And it states there that a 
cross-reference of that address revealed certain 
affiliated names. Could you give us those names? 
MR. PIKE: I am sorry, Counsel, what 
paragraph? 
MR. KUVIN: Third from the bottom starting 
with the cross-reference. 
MR. PIKE: Appreciate it. 
MR. KUVIN: S 
TILE WITNESS
 Mark 
Epstein, and Ghislaine Maxwell. 
BY MR. KINN: 
Q. Okay. How is it those affiliated names 
came up? In other words what database were you 
looking at to reference those names? 
A. If she cross-referenced it, she used the Town 
of Palm Beach CAD system. 
Q. And just for those that may not know, what 
is the CAD system? 
A. The CAD system is basically if someone is, is 
we had a 911 hangup or an slant) call or any kind of 
incident that accrues within the Town of Palm Beach, 
when the officer responds and they encounter someone at 
the home, whatever the reason, whether it be a false 
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alarm, 911 hangup, you get their information. That 
2 
information gets put into the CAD system as to who, who 
3 
the officer encountered on that property. 
4 
Q. Okay. Is it regular practice for you as a 
5 
detective when taking over a file from another 
6 
detective to review all the materials that they have 
7 
put together? 
B 
A. Yes. 
9 
Q. All right. And are these records 
10 
contained within the Palm Beach Police Department? 
11 
In other words are these the regular business 
12 
records of the department --
13 
A. Yes. 
14 
Q. -- the information contained within the 
15 
investigation that Ms. Pagan had put together? 
16 
A. It is no longer in the department if that's 
17 
what you're asking. 
18 
Q. No, I mean at the time, when you take over 
19 
sometime in September. 
20 
A. Yes, correct. It would be. 
21 
Q. Okay. 
22 
A. It would be. 
23 
Q. All the information is contained within 
24 
the Town of Palm Beach investigative unit? 
25 
A. Correct. 
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Page 32 
point during the massage Mr. Epstein - this is 
all off recollection by the way. 
MR. KUVIN: If you want to use the 
incident report, what we're referring to would 
be on Pages 11 through roughly 15 of the 
incident report —
MR. PIKE: Just --
MR. KUVIN: — if you need it to help 
refresh your recollection. 
MR. PIKE: Just so the record is clear, 
we're still on the one question. There is a 
form objection on the same answer. 
THE WITNESS: It was — I haven't found 
exactly where she goes into the story, however 
I know —
MR. KUVIN: I think ifs at Page 14. 
THE WITNESS: — where there was some 
touching involved, and Mr. Epstein then, I 
believe, introduced a massager. 
BY MR. KUVIN: 
Q. A vibrator? 
A. Correct. 
Q. Okay. Was she asked to take her clothes 
off according to what she told the police 
department? 
Page 31 
1 
Q. I understand. Now, it's obviously not 
2 
public at that point. You're keeping the 
3 
investigation private? 
4 
A. Correct 
5 
Q. But nonetheless all those documents that 
6 
you would have reviewed front Ms. Pagan would have 
7 
been business records of the police department at 
8 
the time? 
9 
A. Correct. 
10 
Q. I understand. Now, when you reviewed this 
11 
information from Detective Pagan, could you walk us 
12 
through exactly what■ had explained occurred to 
13 
her? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: She was taken to 
16 
Mr. Epstein's house for the purpose of making 
17 
money, providing a massage. 
18 
MR. KUVIN: Okay. 
19 
THE WITNESS: Once she got there, she was 
20 
taken upstairs to the bedroom area At that 
21 
time what my understanding was is they were 
22 
taken to the bedroom area through the stairwell 
23 
where Mr. Epstein was awaiting to do a massage. 
24 
MR.. KUVIN: Okay. 
25 
THE WITNESS: The massage began. At some 
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Page 33 
MR. PIKE: Font 
THE WITNESS: Yes. 
BY MR. KUVIN: 
Q. And how old was she at the time? 
MR. PIKE: Form. 
THE WITNESS: Fourteen. 
BY MR.. KUVIN: 
Q. Was there an investigation as to howl. 
actually was taken to the home? In other words did 
you determine who took her there? 
A. Correct 
Q. Who was that? 
A. 
BY MR. KUVIN: 
Q. Did Ms. Pagan interview Ms. MI? 
A. No, she did not. 
Q. Not at this point? 
A. No. 
Q. Did you ultimately interview Ms. IM 
A. Yes, I did. 
Q. With respect to whatMxplained. I 
would like to walk through this if I could for a 
minute. 
MR. PIKE: What sage are vou on? 
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Page 34 
MR. KUVIN: Fourteen. 
BY MR. KUVIN: 
Q. Was there another woman that she described 
in the home at Epstein's house? 
MR. PIKE: Form. 
THE WITNESS: Yes. She described a tall 
blonde female which I believe was 
BY MR. KUM: 
Q. Okay. And what did IIIM.10 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. -- as far as what she described to you? 
MR. PIKE: Same objection. 
THE WITNESS: If I can just — I am going 
to-- 
MR. KUVIN: Yeigie a look. 
THE WITNESS: 
was the one who took 
her upstairs, I believe. 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. Upstairs in Mr. Epstein's house? 
MR. PIKE: Same objection. 
THE WITNESS: Yes. 
Page 36 
1 
THE WITNESS: He told her to remove, take 
2 
off her clothe's. 
3 
BY MR. ICUVIN: 
4 
Q. Okay. And she's 14 at this point? 
5 
MR. PIKE: Form. 
6 
THE WITNESS: Cared. 
7 
BY MR. KUVIN: 
8 
Q. What did 
explain was his demeanor, 
9 
Mr. Epstein's demeanor with respect to asking her to 
10 
take off her clothes? 
11 
MR. PIKE: Form. 
12 
THE WITNESS: I believe he was stern when 
13 
he instructed her to remove her clothing. 
14 
BY MR. KUVIN: 
15 
Q. What was he dressed in? 
16 
MR. PIKE: Form. 
17 
THE WITNESS: In a towel. 
18 
BY MR. KUVIN: 
19 
Q. Could you explain to us exactly what 
20 
Mr. Epstein supposedly instructed her to do —
21 
MR. PIKE: Form. 
22 
BY MR. KUVIN: 
23 
Q. — and then what he did? 
24 
MR. PIKE: Same objection. 
25 
THE WITNESS: He instructed her to provide 
Page 35 
1 
BY MR KUVIN: 
2 
Q. The same home that we described before on 
3 
El Brill° Way? 
4 
MR. PIKE: Form. 
3 
THE WITNESS: Yes. 
6 
BY MR. KUVIN: 
7 
Q. All right. Let's walk through some of 
8 
this. When she gets upstairs, the woman leaves the 
9 
room? 
10 
MR. PIKE: Form. 
11 
. THE WITNESS: Correct. 
12 
BY MR. KUVIN: 
13 
Q. Okay. At that point does she tell you 
14 
that Mr. Epstein comes in? 
15 
MR. PIKE Form. 
16 
THE WITNESS: This is what she's informing 
17 
Officer Pagan. 
18. 
BY MR. ICUV1N: 
19 
Q. Pagan, yes? 
20 • 
A. Yes. 
21 
MR. PIKE: Same objection. 
22 
BY MR. KUV1N: 
23 
Q. All right. And what does Mr. Epstein do 
24 
at that point according to what El explained? 
25 
MR. PIKE: Form. 
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Page 37 
a massage pointing to the specific lotion for 
her to use. He laid on the table face down. 
As she was providing the massage, he asked her 
to get onto his back. She straddled herself 
along his back and advised that her exposed 
buttocks was touching his bare buttocks. 
MR. PIKE: Form, move to strike. 
BY MR. KUVIN: 
Q. What happened next? 
MR. PIKE: Form. 
THE WITNESS: He turned over onto his back 
and was masturbating. 
BY MR. KUVIN: 
Q. Okay. Did he masturbate to conclusion 
according to her? 
MR. PIKE: Form. 
THE WITNESS: It doesn't state in the 
Mort. 
BY MR. KUVIN: 
Q. Okay. Did 
describe what her reaction 
was to what was occurring at this point? 
MR KUVIN: Form. 
THE WITNESS: She was disgusted by his 
actions but didn't say anything. 
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Page 40 
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BY MR. KUVIN: 
2 
Q. Okay. Was Ms.■ able to describe the 
3 
home? 
4 
MR. PIKE: Form.
5 
THE WITNESS: Correct, she did. She 
6 
described Epstein's house as a two-story pink 
7 
house with a Cadillac Escalade parked in the 
driveway. 
9 
BY MR. KUVIN: 
10 
Q. .Was she able to describe the inside of his 
11 
home? 
12 
MR. PIKE: Form. 
13 
THE WITNESS: Yes. 
14 
BY MR. KUVIN: 
15 
Q. Did your investigation uncover any reason 
16 
why a 14-year-old girl, other than what she 
17 
described for you, may know what the inside of 
18 
Mr. Epstein's home looked like? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: I'm sorry? 
21 
BY MR. KUVIN: 
22 
Q. Did your investigation wit* 
any legal 
23 
reason why a 14-year-old girl lik 
would know 
24 
what's inside of Mr. Epstein's home ooked like 
25 
other than what she had described to you? 
1 
THE WITNESS: Yes. 
2 
BY MR. KUVIN: 
3 
Q. How did she describe it? 
4 
A. She stated that his, quote, wee-wee was very 
5 
tiny. 
6 
Q Okay. 
7 
MR. PIKE: Form, move to strike. Just so 
8 
the record is clear, Detective Recarey is 
9 
reading from a document that has been marked as 
10 
Exhibit --
11 
MR. KUVIN: Two. 
12 
MR. PIKE: Exhibit 2. 
13 
BY MR. KUVIN: 
14 
Q. Just so we can clarify for the record, 
15 
Detective, as a detective for the department, do you 
16 
regularly rely upon reports that are taken down by 
17 
other detectives in the department? 
18 
A. Yes. 
19 
Q. Do you regularly trust other officers to 
20 
take down certain reports with respect to an 
21 
investigation? 
22 
• 
A. Correct. 
23 
Q. And is that part of the regular practice 
24 
of an investigating detective, in other words to 
25 
refer to reports that are taken down by other 
Page 39 
1 
MR. PUCE: Form. 
2 
THE WITNESS: No. 
3 
BY MR. KUVIN: 
4 
Q. If we go onto Page 15 of the incident 
5 
report, does she describe fairly — well, you 
6 
explain to me what detail she described with respect 
7 
to the interior of the home. Was it detailed? Was 
8 
it vague? How would you describe it? 
9 
MR. PIKE: Form and speculative. 
10 
THE WITNESS: When we executed the search 
11 
warrant, items that she had mentioned, the 
12 
photos lining up the stairwell were there, the 
13' 
pink and green sofa was there, and there were 
14 
several photographs of naked women that was 
15 
there as well. 
16 
• BY MR. KUVIN: 
17 
Q. So, essentially everything she described 
18 
in her initial report to Detective Pagan was 
19 
verified when you did the search warrant videotape? 
20 
A. Correct. 
21 
MR. PUCE: Form. 
22 
BY MR. KUVIlt 
23 
Q.. All right. Dididescribe whether or 
24 
not she was able to see 
. Epstein's penis? 
25 
MR. PIKE: Rent 
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41 
officers during the, during an investigation? 
A. Yes. 
Q. Okay. Just so we're clear, she referenced 
his wee-wee. Was she referring to his penis? 
MR. PIKE: Form. 
THE WITNESS: Yes. 
BY MR. KUVIN: 
Q. Okay. Was there any legal or lawful 
reason that you could uncover during your 
investigation why'. may know the size, shape, or 
description of Mr. 
ein's penis being a 
14-year-old girl? 
MR. PIKE: Form. 
THE WITNESS: No. 
BY MR. KUVIN: 
Q. All right. And did lescribe to 
Detective Pagan whether or not she received money 
for this event? 
A. Yes, she did. 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. During an investigation like this when 
interviewing a 14-year-old, 15-year-old, any let's 
say girl that's under the age of 18, a minor, as 
ofr ur investirtion, do you have to make a 
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determination as to whether you believe a witness is 
2 
telling the truth or not? 
3 
MR. PIKE: Form. 
4 
THE WITNESS: Obviously when you're 
5 
conducting an interview, you blow, based on the 
6 
information gathered, you would want to verify 
7 
any information that she provides. So, yes, 
you would. 
9 
BY MR. KUVIN: 
10 
Q. Okay. Is what you are telling me that 
11 
when you have a witness talk to you about an event, 
12 
you always try to verify what they have said? 
13 
A. Correct. 
14 
Q. Okay. Is it also part of your job as a 
15 
detective in your training to interview a witness 
16 
and make an internal decision whether you think they 
17 
are being truthful or not nuthful based upon how 
18 
they tell the story, the detail in which they tell 
19 
it, and their reaction and other factors involved? 
20 
A. Obviously when she's providing, when anyone is 
21 
providing information and all the information gathered 
22 
has to be verified --
23 
Q. Okay. 
24 
A. -• you know, in any interview regarding any 
25 
case. 
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Page 44 
THE WITNESS: I cannot recall at this time 
whose number that was assigned to. 
BY MR. KUVIN: 
Q. Okay. There was apparently a purple item 
pulled from the trash pull. Do you see that? 
A. Yes. 
Q. • All right. I am hying to fmd, just so 
that I can tie it into the trash pull itself, if we 
look at Pages 1 through 19, where is it that the 
trash pull occurs? Does she note it here? 
MR. PIKE: Form. 
MR. KUVIN: Just so that I can have a 
timeline. 
MR. PIKE: Same objection. 
BY MR. KUVIN: 
Q. I may have it in the other document, 
actually. Let me ask it this way: Can you tell by 
looking at that investigative report when that trash 
pull occurred, initially, the first one? 
MR. PUCE: Form. 
THE WITNESS: No, I am looking for — it 
might have been after based -- ifs how the 
• 
reports are inputted. 
MR. KUVIN: Here it is. Hang on one 
second. Let's do this; this may help. As part 
Page 43 
Q. All right. Before you were involved, did 
2 
the department or did Officer Pagan do a trash pull 
3 
of the home? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: I believe so, yes. 
6 
BY MR. KUVIN: 
7 
Q. And this first trash pull occurred before 
8 
you got involved in the investigation? 
9 
A. Correct. 
10 
Q. All right. Let's look at Page 19. I want 
11 
to clarify just a couple of things that we have gone 
12 
over in some other depositions. 
13 
MR. PIKE: Form, move to strike. 
14 
BY MR. KUVIN: 
15 
Q. First of all, there was a subpoena request 
16 
for a T-Mobile wireless phone number. Do you see 
17 
that? 
18 
A. Correct 
19 
Q. All right. That number that's there in 
20 
the incident report, did you determine what number 
21 
that referenced? In other words what person that 
22 
number referencecia.was it 
Ms. 
23 
Mr. Epstein, Ms. =, 
Ms. 
24 
MR. PIKE: Form. 
25 
MR. KUVIN: -- or someone else? 
Page 45 
1 
of a subpoena to the Palm Beach Police 
2 
Department, we received a copy of e-mails that 
3 
existed with respect to this case and 
4 
Mr. Epstein. 
5 
What I would like to mark is what 
6 
we'll call Exhibit 3 I think we're up to 
. 7 
now. I knew I saw it. I was trying to 
8 
' figure out where. Hang on a second. 
9 
BY MR. KUVIN: 
10 
Q. This is a e-mail from Nickie Altornaro. 
11 
Who was that? 
12 
A. She was the detective bureau secretary. 
13 
. MR. KUVIN: Okay. And it's indicated it 
14 
looks like October 17, 2005. Let me just show 
15 
it quickly to opposing counsel. It was in the 
16 
recent production by Palm Beach. 
17 
. 
(Plaintiffs Exhibit No. 3 was marked for 
18 
identification.) 
19 
BY MR. KUVIN: 
20 
Q. Do you mind if I look over your shoulder 
21 
while he looks at it. And I want to give you what 
22 
we have marked as Exhibit 3. This might help a 
23 
little bit. Can you describe for us generally what 
24 
this is? 
25 
A. This, it appears to be Officer Pagan's 
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incident report which was inputted by Nickie Altomaro. 
2 
Q. Okay. Can you describe for us the process 
3 
by which the information is generally taken down at 
4 
the department back in 2005, and how it makes it 
5 
into the incident report? 
6 
A. Nickie Altomaro was the detective bureau 
7 
secretary. As we update the incident report, you type 
8 
up your report. And at this time we were using a DOS 
9 
system. 
10 
Q. Okay. DOS as opposed to Windows based? 
11 
A. Yes. 
12 
Q. Gotcha. 
13 
A. And we would type up the report, forward it to 
14 
her either in Word Document or WordPerfect. She would 
15 
convert the document into a DOS format and input it into 
16 
the system. 
17 
Q. All right. If we turn to -- it looks like 
18 
these are in, somewhat in date order. If we turn to 
19 
3/21/05 which is on the eighth page. Did you get to 
20 
the date of 3/21/05? 
21 
A. Yes. 
22 
Q. Okay. Was surveillance instituted on 
23 
Mr. Epstein's home at this time? 
24 
A. Correa. 
25 
Q. All right. So we're talking March 21st, 
Page 48 
1 
Q. The well being the back of the trash 
2 
truck? 
3 
A. Correa 
4 
Q. Before it goes into the main bin? 
5. 
A. Correct. 
6 
Q. Crotcha. Okay. 
7 
A. Once that area is, we're confirmed that it is 
8 
empty, they go onto the property, remove the trash and 
9 
place it into the well. We then follow it to an 
10 
unspecified location where we actually remove the 
11 
contents from the well. 
12 
Q. All right. Let's walk through now, 
13 
continue turning to the date of 4/1/05 through 
14 
4/3/05. You should be an additional three pages 
15 
down. 
16 
A. 4/1. 
17 
Q. Yes, sir. All right. If we look at 4/1 
18 
through 4/3/05, what was occurring on those dates? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: She met with Detective 
21 
Mattel of the police department. 
22 
BY MR. KUVIN: 
23 
Q. Was there any additional surveillance 
24 
conducted? 
25 
A. Yes. 
2 
3 
4 
5 
6 
8 
9 
10 
11 
12 
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Page 47 
2005, surveillance began at his home on El Brillo 
Way; is that correct? 
MR. PIKE: Form. 
THE WITNESS: Correct. 
BY MR. KUVIN: 
Q And on that exact date of 3/21/05 what 
else took place? 
MR. PIKE: Form. 
THE WITNESS: Officer Pagan requested and 
Detective Lee initiated trash pulls from 358 
El Brillo. 
BY MR. KUVIN: 
Q. Can you describe to us what a trash pull 
is? What do you do? 
A. Well, you inform the supervisor of sanitation 
that you're interested in pulling your target's trash, 
you fund the location, who in turn informs the driver 
that you're going to be pulling the trash. 
Q. The driver of the trash truck? 
A. The driver the trash truck. 
Q. Ootcha. 
A. Once that's done, we coordinate with the trash 
buck driver to ensure that the well is empty prior to 
him going to your target location. He goes -- we follow 
him to the target location. 
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Page 49 
Q. Okay. And what were the dates of the 
surveillance? 
A. It appears she met with members of the B.S.F. 
Unit, Burglary Strike Force is what it was, for the 
purpose of conducting surveillance at 358 El Brillo. 
Q. Okay. Now, this surveillance, was this 
kept by the department? 
A. Correct 
Q. Still held by the department? 
A. Not 100 percent certain on that. It might 
have gone over to the FBI. 
Q. Okay. We'll talk about that when we get 
to that point. But nonetheless before the FBI came 
in, all of this was kept by the department? 
A. Correct. 
Q. By your department Okay. All right If 
we look at the bottom of the page, what's the date 
that the trash pull was actually done? 
MR. PIKE: Form. 
THE WITNESS: On the bottom of the page? 
BY MR. KUVIN: 
Q. Yeah, the one we were talking about. 
A. I'm still looking at Exhibit 3. 
Q. Yep. 
A. So, it would be --
.0.6•APODA, 
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Page 50 
Q. Top of the page it starts "at times 
appear." 
A. Correct. 
Q. All the way at the bottom of the page, 
last line. 
A. On April 5111,2005, the trash pull was 
7 
conducted by Detective Lee. 
3 
Q. All right. And what did Detective Lee 
9 
fmd? 
10 
MR. PIKE: Form. 
11 
THE WITNESS: It was a message from 
12 
indicating, and redacted, at 11:00 a.m. or 11. 
13 
MR. KUVIN: Okay. 
14 
THE WITNESS: The following information 
15 
was obtained from the trash from 358 El Brillo. 
16 
BY MR. KUVIN: 
17 
Q. What additional messages w 
18
A. One from Jean Luc, David, 
There 
19 
was some redacted 
redacted, Brit Ri n 
20 
is redacted, redacted, 
21 
a message fora receipt dated 4/4 at 1:05, 
22 
ith a phone number, and she's looking to 
23 
spe to you. 
24 
Q. Okay. Let's talk about this fora minute. 
25 
The redacting, do you know why those are redacted at 
1 
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3 
4 
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6 
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8 
9 
10 
11 
12 
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18 
19 
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23 
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Page 52 
of it. But if we go back to Page 19, keep both of 
those documents available in case we need to refer 
to them. 
But if we go back to Page 19 of the 
incident report, do you see towards the bottom of 
the page it references a purple item retrieved from 
the trash pull? 
A. Yes. 
Q. Okay. This particular purple item, did 
Officer Pagan attempt to identify what it was? 
MR. PIKE: Form. 
THE WITNESS: Yes, she did. 
BY MR. KUVIN: 
Q. And at the point she attempted to identify 
it, what did she identify it as at this point back 
in April of '05? 
MR. PIKE: Form. 
THE WITNESS: She believed it was an anal 
wand of some sort. 
BY MR. KUVIN: 
Q. And how did that identification take 
place? 
A. I believe she researched it on the Internet. 
MR. PIKE: Form. 
1 1 
Page 51 
1 
this point? 
2 
MR. PIKE: Form. 
3 
THE WITNESS: Yes, I do. 
4 
BY MR. KUVIN: 
5 
Q. Why? 
6 
A. It indicates either the names or the initials 
7 
of the victims. 
8 
Q. The victims, what age were the victims? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: As young as 14 to 16. 
11 
BY MR. KUVIN: 
12 
Q. Okay. So if we see a redacted portion 
13 
here, can we safely assume that that references one 
14 
of the victims? 
15 
MR. PIKE: Form. 
16 
THE WITNESS: Correct. 
17 
BY MR. KUVIN: 
18 
Q. Is there any other redactions that would 
19 
take place other than the names of the potential 
20 
victims? 
21 
MR. PIKE: Form. 
22 
THE WITNESS: Not that I am aware of 
23 
BY MR. KUVIN: 
24 
Q. All right There was a reference that I 
25 
had started with. I 'ust wanted to see the timi 
Page
1 
BY MR. KUVIN: 
2 
Q. This particular jelly anal wand, this 
3 
purple item, was it later identified as something 
4 
different? 
S 
A. Yes, it was. 
6 
Q. Okay. Can you describe that for us? 
7 
MR. PUCE: Form. 
8 
THE WITNESS: It was during the execution 
9 
of the search warrant. During the search we 
10 
found that it, it was a handle of a, of a 
1.
4 
15
6
office. 
17 
that I have to leave later. She works with our 
MR. GARCIA: There is a summary judgment 
MR. PIKE: For the record she works with 
1 
utensil used to eat. 
2 
(Ms. Finnigan entered the room.) 
3 
MR. KUVIN: We added a person. 
18 
SW, with Sid Garcia's office. 
19 
MR. GARCIA: She shares a space with me. 
20 
That's close enough. 
21 
MR. KUVIN: Let's continue with the 
22 
incident report. 
23 
MR. PIKE: Actually, no, let's not 
24 
Is she listed as counsel? 
25 
MR. GARCIA: No. She a 
at 
14 (Pages 50 to 53) 
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Page 54 
Page 56 
1 
Mr. Epstein's deposition before. 
2 
MR. KUVIN: Has she filed a notice of 
3 
appearance? 
4 
MR. GARCIA: No. 
5 
MR. KUVIN: I am going to ask her to, ask 
6 
to excuse her. She has not filed a notice of 
7 
appearance. There are confidential issues in 
8 
this case and there are various orders that are 
9 
binding on various lawyers in this case. 
10 
Sid, this is one of the very few 
11 
depositions that you have actually been in 
12 
attendance at, and if she has not filed a 
13 
notice of appearance, if she has not 
14 
signed any pleadings in this case, I am 
15 
going to ask that she leave otherwise the 
16 
deposition is not going to go forward. 
17 
MR. GARCIA: On what authority? 
18 
MR. PIKE: She is not counsel. She has no 
19 
right to be here. 
20 
MR. GARCIA: She's assisting me with this 
21 
case. She appeared at your own client's 
22 
deposition which you did not attend. 
23 
MR. PIKE: That's all well and good but 
24 
the fact is is that she does not have a notice 
25 
of appearance here in this. 
1 
MR. PIKE: Form. 
2 
THE WITNESS: Yes. Captain David Rodgers, 
3 
Co-captain Larry Visosld, flight engineer, 
4 
Larry Morrison. 
5 
BY MR. KUVIN: 
6 
Q. Okay. In this trash pull were there also 
7 
messages left by some of the potential victims in 
8 
this case? 
9 
A. Correct. 
10 
Q. All those victims being under the age of 
11 
18? 
12 
MR. PIKE: Form, and form to the last one. 
13 
THE WITNESS: Correct 
14 
BY MR. KUVIN: 
15 
Q. And that's why they are blacked out? 
16 
MR. PIKE: Form. 
17 
THE WITNESS: Correct. 
18 
BY MR. KUVIN: 
19 
Q. All right. Let's turn to the next page of 
20 
the investigation. Actually, you know what, let's 
21 
go to the part where you start here which would be 
22 
Page 22. 
23 
MR. PIKE: Thank you. 
24 
MR. KUVIN: For what? 
MR. PIKE: Identifying the page. 
Page 5T, 
1 
MR. GARCIA: She will file one today. 
2 
MR. PIKE: We're not going to go forward. 
3 
MR. KUVIN: I am not stopping. 
4 
MR. PIKE: The fact is these are 
5 
confidential communications. 
6 
MR. GARCIA: Why don't you file a notice 
7 
of appearance and come back. 
8 
MS. FINNIGAN: Okay. 
9 
MR. GARCIA: That will resolve it. 
10 
(Ms. Finnigan left the deposition 
11 
room.) 
12 
BY MR. KUVIN: 
13 
Q. All right Let's continue on. 
14 
Going to Page 20 of the incident 
15 
report, at some point did you gain information with 
16 
respect to Jet Aviation, and if so could you 
17 
describe what information was obtained by Officer 
18 
Pagan regarding Jet Aviation? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: I believe it was a trash 
21 
pull where an itinerary was found within the 
22 
trash pull. 
23 
BY MR KUVIN: 
24 
Q. Were there additional names found within 
25 
the itine 
of ilots? 
Page 57 
1 
MR. KUVIN: I thought I did something you 
like and I want to take it back. 
3 
MR. PIKE: No. 
4 
BY MR- KUVIN: 
5 
Q. All right. What is the Burglary Strike 
6 
Force? 
7 
A. It is now a disbanded unit. However, it was a 
8 
unit of plain clothed officers. At that time we were 
9 
being struck with burglaries. 
10 
Q. Okay. 
11 
A. It was a unit created just to combat and 
12 
locate people that were on properties, stuff like that. 
13 
Q. Okay. Were you part of that strike force? 
14 
A. No. 
15 
Q. Okay. What occurred with the Burglary 
16 
Strike Force once you got involved with the case? 
17 
MR. PIKE: Fonn. Actually I will withdraw 
18 
it. That question is fine. 
19 
THE WITNESS: The Burglary Strike Force 
20 
had been conducting surveillance at the home of 
21 
Mr. Epstein at 358 El Brill°. 
22 
BY MR. KUVIN: 
23 
Q. Okay. Which officer was assigned to 
24 
monitor Mr. Epstein's home? 
25 
A. Officer Mun an. 
15 (Pages 54 to 57) 
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Page 58 
Page 60 
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2 
.3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18. 
19 
20 
21 
22 
23 
24 
25 
Q. Any others? 
A. Sergeant Sorge and Officer Minot. 
Q. Are they still with the department? 
A Officer Munyan is no longer with the 
department. Sergeant Sorge has since retired. And 
Officer Minot is still with the police department. 
Q. All right And what did the surveillance 
find on that particular date? 
MR. PIKE: Form. 
THE WITNESS: I had asked them to input 
that into their report so there should be 
supplements by them as to what was, what they 
observed. 
BY MR. KUVIN: 
Q. Well, if you look at the summary in the 
incident report, what is reported there? 
MR. PIKE: Form. 
THE WITNESS: They filled out an attached, 
a surveillance log which was a placed in the 
attachment file. 
MR. KUVIN: Okay. 
THE WITNESS: Mr. Epstein had left for the 
airport on his jet which was over at, I 
believe, Jet Aviation. 
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9 
10 
11.
12 
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25 
trash pull; is that correct? 
A. Correct. 
Q. Can you explain to us what that note was? 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. Just so I'm clear, you saw the note 
yourself, correct? 
A Yes. 
Q. Clay. Can you explain what it was? 
A. This notes contained names of different girls 
with different times. 
MR. PIKE: Form, move to strike. 
BY MR. KUVIN: 
Q. If we go with the word "additionally," 
halfway down the paragraph, do you see that where I 
am starting? 
A. Yes. 
Q. It says "Additionally there was a —
A. "There was a note" and a redaction. 
Q. Do you know who that redaction name is 
referring to? As you sit here today can you recall? 
A. I can't recall. 
Q. All right. What did the note say? 
A.
 "For a good time call," redaction, "and 
Page 59 
1 
BY MR. KUVIN: 
2 
Q. Okay. Was it determined during your part 
3 
of the investigation that the jet was, in fact, 
4 
Mr. Epstein's jet? 
5 
MR. PIKE: Form. 
6 
THE WITNESS: Correct. 
7 
BY MR. ICUV1N: 
8 
Q. All right. Lets get to your next report 
9 
which looks like Narrative 5 on Page 24. We come 
10 
down the first paragraph. It looks like this is 
11 
documenting an additional trash pull that took 
12 
place? 
13 
MR. PIKE Form. 
14 
THE WITNESS: Correct. 
15 
BY MR. KUVIN: 
16 
Q. Were you a part of the trash pull on 
17 
September 21 of 2005? 
18 
A. No, I was not. 
19 
Q. Who was? 
20 
A. Sergeant Szarszewski. 
21 
Q. All right. Did you review the evidence 
22 
that came out of this trash pull? 
23 
A. Correct. 
24. 
Q. All right. Halfway down the paragyaph, 
25 . 
there was a note that was apgarently pulled on this 
Page 61 
1 
Q. Okay. Why would that name be redacted - 
2 
MR. PIKE: Form. 
3 
MR. KUVIN: — if you know? 
4 
THE WITNESS: It would have been the name 
5 
of a minor, victim. 
6 
BY MR. KUVIN:
Q. Okay. If we go onto the next sentence, it 
8' 
says: "Also there was another telephone number on 
9. 
note"; is that correct? 
10 
MR- PIKE: Form. 
11 
THE WITNESS: Yes. 
12 
BY MR. KUVIN: 
13 
Q. . And then there is a redaction, correct? 
14 
A. Yes. 
15 
Q. Is that the redacted phone number of a 
16 
minor? Is that why it's redacted? 
17 . 
MR. PIKE: Form. 
18 
THE WITNESS: Yes. 
19 
BY MR. KUVIN: 
20 
Q. Then it says: "Also found was a written 
21 
note which stated," redaction, "cannot come at 
22 
7:00 p.m. tomorrow because of soccer"? 
23 
A. Correct. 
24 
Q. You saw that note? 
25 
A. Yes. 
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Page 62 
1 
Q. And as you sit here today do you know or 
2 
do you recall who that person may have been, which 
3 
minor? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: I believe it was Jane Doe 
6 
No. 4, Jane Doe No. 4. 
7 
BY MR. KUVIN: 
8 
Q. Okay. Was she in high school at the time? 
9 
A. Yes. 
10 
MR. ME: Form 
11 
BY MR. KUVIN: 
12 
Q. Playing soccer? 
13 
MR. PIKE: Form. 
14 
THE WITNESS: Yes. 
15 
BY MR. KUVIN: 
16 
Q. Let's go the next thing that I wanted to 
17 
ask you about and clarify. GO to Page 16, if you 
18 
would. 
19 
A. Actually if I can clarify my answer --
20 
Q. Sure. 
21 
A. -- on that one. She might have graduated from 
22 
high school already --
23 
Q. Okay. 
24 
A. -- and started attending her university. 
25 
Q. Gotcha. 
Page 64 
1 
stimulation. Do you see that? 
2 
A. Correct 
3 
Q. I am trying to find out: This was a 
4 
broken piece of hard plastic. Was this what you 
5 
ultimately determined was the utensil or was this 
6 
something different? 
7 
A. Yes, that was the utensil. They were 
8 
different colors. They were purple, white. I believe 
9 
they were blue. 
10 
Q. Okay. 
11 
A. But they all were shaped very similar. It was 
12 
about that long. I wotdd say four to five inches long. 
13 
Q. Okay. 
14 
A. And it had groves and had bumps along the way 
15 
with a rounded end and came beck around. 
16 
Q. Gotcha. 
17 
MR. PIKE: Form, move to strike. 
18 
BY MR. KUVIN: 
19 
Q. All right Let's go to the date of 
20 
10/7105 which is the next page, 27. This is 
21 
reported by you; is that correct? 
22 
A. Correct 
23 
Q. Can you describe for us what you did on 
24 
this particular date? 
25 
A. Ins contacted by Sergeant Frick. 
Page 63 
MR. PIKE: Form. For purposes of the 
2 
record, you're pointing to Page 24 of Exhibit 
3 
2, correct? 
4 
THE WITNESS: Correct. 
5 
BY MEL KUVIN: 
6 
Q. And we're talking about Jane Doe No. 4? 
7 
A. Yes. 
Q. Okay. Regardless was she still under the 
9 
age of 18; is that why the name was redacted? 
10 
MR. PIKE: Form. 
11 
MR. KUVIN: If you know. 
12 
THE WITNESS: I can't recall but --
13 
BY MR. KUVIN: 
14 
Q. Okay. Let's go to Page 26 fora moment 
15 
It looks like there was an additional trash pull 
16 
that was done on October 3rd, 2005; is that correct? 
17 
A. Yes. 
18 
Q. All right And in this particular trash 
19 
pull, the next paragraph says: "Inside one of the 
20 
white and color bags, I located a broken piece of 
21 
hard plastic or clear acrylic stick which was shaped 
22 
with small ridges." Do you see that? 
23 
A. Correct. 
24 
Q. This device is commonly used as a sexual 
25 
toy which is inserted into the vagina or anus for 
Page 65 
1 
Mr. Epstein had been observed riding his bicycle along 
2 
South County Road which meant he was back in town. We 
3 
set up to interview 
4 
Q. Okay. 
5 
A. We went out to her house, knocked on the door. 
6 
She agreed to accompany us back to the police department 
for Rather questioning. 
8 
Q. All right. 
9 
MR. PIKE: Move to strike. 
10 
BY MR. KUVIN: 
11 
. 
1. 
go onto Page 28. Did you bring 
12 
h4s
back to the department? 
13 
A. That's correct-
14 
Q. Ms. 
at this time is how old? 
15 
A. I believe she was IS. 
16 
MR. PIKE: Form. 
17 
BY MR. KUVIN: 
18 
Q. Okay. And when you bring her back to the 
19 
department, do you interview her? 
20 
A. Yes,1 did. 
21 
Q. And what exactly does she explain to you 
22 
during this— well, let me ask you this: At this 
23 
point is she a suspect in a crime? 
24 
A. At this point she was a witness. 
25 
Q. Okay. 
17 (Pages 62 to 65) 
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Page 66 
A. As she was the one that brought the initial 
victim to the house. 
Q. Initial victim being. 
A. Correct. 
MR. PIKE: Form, move to strike. 
BY MR. KUVIN: 
Q. So, at this point she's a witness to 
bringing that initial victim,■ to Mr. Epstein's 
home; is that correct? 
MR. PIKE: Form. 
THE WITNESS: Correct. 
BY MR. KUVIN: 
Q. So as such any need to read her her 
Miranda Rights at this point? 
MR. PIKE: Form. 
THE WITNESS: No. 
BY MR. KUVIN: 
Q. And during the witness interview that you 
did with her, what did she describe to you occurred? 
MR. PIKE: Form. 
THE WITNESS: During a sworn taped 
statement she explained how she met 
Mr. Epstein; the time that she went to his 
house, she provided a massage for Mr. Epstein. 
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Page 68 
MR PUCE: Form, move to strike. And for 
the record, Detective Recarey, you are still 
reading from Exhibit 2, correct? 
THE WITNESS: Some recollection, some off 
the report. 
MR. PIKE: The document is in front of 
you? 
THE WITNESS: Yes, sir. 
MR. PIKE: And that's what is refreshing 
your recollection? 
MR KUVIN: Hey, l appreciate your 
objection. Objection to the form works and 
then I will continue with my deposition and you 
can cross him later. 
MR. PIKE: That's not a, that's not a form 
objection. That's to make sure that the record 
is clear as we go along that Detective Recarey 
is reading from Exhibit 2 which you previously 
marked and I am going to continue to do it. 
lam not going to interrupt your 
deposition, but I am going continue to do 
it to insure that the record is clear that 
he is reading from the document that is in 
front of him. You can proceed. 
I 
Page 67 
1 
BY MR. KUVIN: 
2 
Q. Now, at the time she told you she provided 
3 
a massage, how old was she? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: I believe she stated she was 
6 
17. 
7 
BY MR. KUVIN: 
8 
Q. Okay. Let's go down if you would, third 
9 
paragraph about the sixth line, seventh line from 
10 
the bottom. It starts with the words "he 
11 
explained.' Do you see that? 
12 
A. Yes. 
13 
Q. During the interview did 
recount 
14 
any statements regarding Epstein and obtaining other 
15 
girls? 
16 
A. Yes. 
17 
MR. PIKE: Form. 
18 
BY MR. KUVIN: 
19 
Q. What was explained? 
20 
A. She stated that Mr. Epstein explained that he 
21 
knew she was not comfortable with providing the massage 
22 
but he would pay her to bring some girls, told her the 
23 
younger the better. 
explained that she brought a 
24 
23•year-old to perform a massage, and she was told that 
25 
she was too old. 
Page 69 
1 
BY MR. KUVIN: 
2 
Q. Detective Recarey, as you sit here today 
3 
do you have an independent recollection of that 
4 
initial interview with 
5 
A. Yes, sir. 
6 
Q. Do you recall whether she discussed 
7 
conversations with Mr. Epstein about bringing girls 
8 
to the home? 
9 
A. Yes. 
10 
Q. She discussed that with you? 
11 
A. Yes, she did. 
12 
MR. PIKE: Form. 
13 
BY MR. KUVIN: 
14 
Q. All right. Are we talking now independent 
15 
from the incident report that we were referring to 
16 
before? 
17 
A. Yes. 
18 
Q. And that independent recollection by 
19 
looking at the incident report, does that help 
20 
refresh your recollection? 
21 
A. Yes, it does. 
22 
Q. All right. But that's not your entire 
23 
recollection of the incident, is it? 
24 
A. No. 
25 
MR. PIKE: Fonn. 
earrexuatiseraa..... 
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Page 70 
1 
BY MR. KUVIN: 
2 
Q. You are not just reading a report into the 
3 
record, are you? 
4 
A. No, sir. 
5 
Q. Okay. You were there, right? 
6 
A. Correct. 
7 
Q. Sitting in the room with Ms. Mwhile 
8 
she was talking to you? 
9 
A. Yes, I was. 
10 
Q. Okay. What did Mr. 
tell you, if 
11 
anything, about bringing young women to 
12 
Mr. Epstein's home? 
13 
MR. PIKE: Form. 
14 
THE WITNESS: She brought a 22, 
15 
23-year-old to the house to perform a massage 
16 
end was told that the girl was too old, was 
17 
told to bring girls; the younger the better. 
18 
BY MR. KUVIN: 
19 
Q. Was there any age cutoff as far as how 
20 
young; Inman 10, 11, 12, was that described? 
21 
MR. PIKE: Form, move to strike. 
22 
THE WITNESS: She did not advise. 
23 
BY MR. KUVIN: 
24 
Q. Just the younger better? 
25 
A. Younger the better. 
Page 72 
1 
explained it that she had brought additional women, and 
2 
she explained that she had received monies for bringing 
3 
these girls to the house, basically, yes, that she had 
4 
incriminated herself. 
5 
Q. With respect to potential crimes? 
6 
A. Correct 
7 
Q. At that point did you read her her rights, 
8 
her Miranda Rights? 
9 
A. At that point when we explained it to her, it 
10 
was Sergeant Frick who is now a captain, she expressed 
11 
her willingness to cooperate in hopes that in the, for a 
12 
lesser charge. 
13 
Q. Okay. So, she agreed voluntarily to 
14 
cooperate with the investigation? 
15 
A. Comm. 
16 
Q. And did she cooperate with the 
17 
investigation? 
18 
MR. PIKE: Form. 
19 
THE WITNESS: When she got home and spoke 
20 
with her family in regards to the interview, it 
21 
was her family's determination and hers not to 
22 
assist. 
23 
BY MR. KUVIN: 
24 
Q. Do you 'mow why? 
25 
MR. PIKE: Form. 
Page 71 
MR. PIKE: Form. 
2 
BY MR. KUVIN: 
3 
Q. And that was told to her by whom? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: Mr. Epstein. 
6 
BY Iva KUVIN: 
7 
Q. And not a third party, but directly from 
8 
Mr. Epstein? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: Correct 
11 
BY MR. KUVIN: 
12 
Q. Did you ask her which one was youngest? 
13 
MR. PIKE: Form. 
14 
THE WITNESS: I did ask her which one was 
15 
theyotma.- t. She claimed that the initial 
16 
victim, 
would have been the youngest. 
17 
BY MR. KUVIN: 
18 
Q. She was how old? 
19 
MR. PIKE: Fain. 
20 
THE WITNESS: Fourteen. 
21 
BY MR. KUVIN: 
22 
At some point during your interview with 
23 
Ms. ME did you determine that she might actually 
24 
be charged with a crime? 
25 
A. At the conclusion of the interview as she 
Page 73 
1 
MR. KUVIN: If you know? 
2 
MR. PIKE: Form. 
3 
THE WITNESS: I lave no idea why. 
4 
BY MR. KUVIN: 
5 
Q. Just so I understand, initially she agreed 
6 
to cooperate. She then goes home, talks to family, 
7 
and then comes back and says she's not going to 
8 
cooperate; is that the sequence of events? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: Correct. 
11 
BY MIL KUVIN: • 
12 
Q. While you're taking her back home, is a 
13 
tape recorder surveillance placed into the police 
14 
vehicle? 
15 
A. Correct. 
16 
Q. And were you one of the ones that took her 
17 
home? 
18 
A. Yes. 
19 
Q. All right. What did she say during that 
20 
drive home —
21 
MR. PIKE: Form. 
22 
BY MR. KUVIN: 
23 
Q. — as best you can recall? 
24 
MR. PIKE: Same objection. 
25 
THE. WITNFSS: She stated that she was like  ,51 
19 (Pages 70 to 73) 
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