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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 II 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. 
 au& 
Electronically signed by eynthla hopkins (601 
Electronically signed by cynthia bodkins (601 
Electronically signed by cynthia hopkins (601 
ea2stiddbfaB1-4f16-b3b7deda51494142 
EFTA00298293

EFTA00298294

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE No.502038CA0373I9/000CMB AB 
131 
B.B. 
4 
Plaintiff 
S 
6 
-vs- 
VOLUMBIIOFII 
7 
jA121.11 
8 
Defendants. 
9 
10 
11 
12 
DEPOSITION OF 
DETECTIVE JOSEPH RECAREY 
13 
14 
Friday, March 19, 2010 
15 
9:37 - 5:12 p.m. 
16 
250 Australian Avenue South 
Suite 1500 
17 
West Palm Beach, Florida33401 
18 
19 
20 
21 
22 
Reported By. 
Cynthia Hopkins, RPR, FPR 
23 
Notary Public, State of Florida 
Prose Court Reporting 
24 
Job No.: 1509 
25 
Page 132 
2 
UNITED STATES DISTRICT COURT 
SOUITIIRN DISTRICT OF FLORIDA 
3 
CASE NO. 10.80309 
4 
5 
JANE DOE NO. 103, 
6 
Plabtiff, 
7 
-vs- 
VOLUME II OF II
8 
JEFFREY EPSTEIN, 
9 
Defendant. 
10 
11 
12 
DEPOSITION OF 
DETECTIVE JOSEPH RECAREY 
13 
14 
Friday, March 19, 2010 
IS 
9-37 - 5:12 pm. 
16 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Cynthia Hopkins, RPR, FPR 
23 
Notary Public, State of Florida 
Prose Court Reporting 
24 
Mb No.: 1509 
25 
t 
APPEARANCES 
2 
On bead( cflbe Plaintiffs, B3.CL 
3 
SPENCER T. KUM!. ESQUIRE 
LEOPOLD KUVIN 
4 
2925 PGA Bodevard 
Suite 200 
5 
Pam 
flaida 33410 
Phone. 
7 
On behalf et the Pin:dirk Ltd E.W and 
Jane Doe: 
6 
15 
16 
17 
18 
19 
20 
KAI/691M W EZELL, ESQUIRE 
PODHURST ORSEOC 
21 
25 Wen Hagler Street 
SAC 800 
22 
Moe: 
23 
(Via 
one) 
24 
25 
9 
BRADLEY J. EDWARDS, ESQUIRE 
FARMER, JAFFE, WEISSING, EDWARDS 
10 
FISTOS & LEHRMAN, P.L. 
425 Rath Anikens Avenue 
11 
Stile 2 
1 2 
Fat 
33301 
Maw 
13 
On behalf 
ace 
a I Drench 8. 
14 
JESSICA ARDOUR. ESQUIRE 
MERMELS1131N k HOROW112., P.A. 
16205 Biscayne Boulevard 
Suite 2218 
Miami, 
3 60
nom 
&mad 
Onbelsalf, t e 
3Ulli..S 
s 
, 
and 
103. 
Page 133 
1 
Appearances oonimued 
2 
On behalf of the FlairditT, Ina Doe No.11: 
3 
IDDRO MANUEl. °ARM, ESQUIRE 
GARCIA ELKINS& BOEHRINCER 
4 
224 Diva Ann, Sale 900 
Wen PUS& 
33401 
5 
Phe
6 
and 
7 
TARA A FDDILGAN, ESQUIRE 
TARA A MINICAR. P A 
8 
224 Dina Street 
Suite 900 
9 
West tide 
3340! 
Mae: 
10 
1/. 
Cte tehalfof the Defendant inlay Epstein: 
12 
MICHAEL PIKE, ESQUIRE 
BURMAN, ORITTON, LUIT1ER & COLEMAN, U.1)
13 
303 Barn Bouienad 
Suite 4t0 
14 
West tads. 
33401 
Phone-
15 
16 
and 
17 
AO; ALAN GOUAERGER, ESQUIRE 
ATTERBURY, GOLDBERGER & WELSS, PA 
10 
250 Attu Wine Avenue Sash 
Suite 1400 
19 
west P 
• 
'dm 334014012 
Phan' 
20 
21 
and 
22 
lifiLTON G. wrgramo. ESQUIRE 
LAW OFFICE OF MILTON 0. WEIMER° 
20 Pat Plaza 
Sine I COO, 
Boston. 
02116 
Phone 
23 
24 
25 
2 (Pages 131 to 134) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
na2a6ddb.fa81-41f6-b3b7-deda61494142 
EFTA00298295

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Page 135 
Appearances continued... 
2 
On behalf of the Witness: 
3 
JOANNE M. O'CONNOR. ESQUIRE 
JONES, }vs eft, JOHNSON & STUBBS, P.A. 
4 
505 South Elegies Drive, Suite 1100 
West Nitride 
33401 
Phone:
Also Present: Jeffrey Epstein 
INDEX 
EXAMINATION 
DIRECT 
CROSS REDIRECT 
CONTINUED EXAMINATION BY 
het ICUVIN 
134 
BY MR. EDWARDS 
243 
• 
EXHIBITS 
EXHIBIT 
DESCRIPTION 
PAGE 
PLARTI1FF'S EX. S SUPPLEMENT FOR CHAIN 151 
OF CUSTODY LOG 
24 
PLAINTIFFS EX. 6 PAGE FROM MESSAGE PAD 196 
PLAINTIFFS EX. 7 PHONE MESSAGE 
204 
25 
3 
4 
5 
6 
7 
8 
9 
10 
12 
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Page 137 g 
CONTINUED DIRECT EXAMINATION 
BY MR. KUVIN: 
Q. All right. We were going over the 
property receipts for the search warrant when we 
left off. And specifically we were at Page 2. We 
were looking at some of the things that you took in. 
Each item that you took dining the search warrant 
was numbered; is that correct? 
A. Correct 
MR. PIKE: Foram. 
BY MR. KUVIN: 
Q. And the item number appears where? 
MR. PIKE: Form. 
THE WITNESS: Under item number. 
BY MR. KUVIN: 
Q. All right And this is a standard form 
wed by the police department? 
A. That's correct. 
MR. PIKE: Fonm 
BY MR. KUVIN: 
Q. All right If we look at Item Number 24, 
what MS that? 
MR. PIKE: Form. 
THE WITNESS: It was a twin torpedo in a 
brown box. 
2 
3 
4 
EXHIBITS CCeITINUED 
MONT 
DESCRIPTION 
PAGE 
PLANETS EX S PHONE MESSAGE 
205 
PLAINTIFFS Ex 9 PHONE MESSAGE 
208 
$ 
PLAINTIFFS EC 10 PHONE MESSAGE 
209 
PLAINTIFFS EC 11 PHONE MESSAGE 
211 
6 
PLAINTIFFS EX 12 PHONE MESSAGE 
212 
PLAINTIFFS EX 13 PHONE MESSAGE 
213 
7 
PLAINTIFF'S EX 14 PHONE MESSAGE 
215 
PLA/NIIFF'S EC 15 PHONE MESSAGE 
215 
8 
FIAINTIFFS EC 16 PHONE MESSAGE 
217' 
PLAINTIFFS EX 17 PHONE MESSAGE 
219 
9 
PLAINTIFFS EX IS PHONE MESSAGE 
220 
PLAINTIFFS EC. I9 PHONE MESSAGE 
221 
10 
PLAINTIFFS DC 20 PHONE MESSAGE 
222 
PLAINTIFFS DC 21 PHONE MESSAGE 
223 
11, 
PLAINTIFFS EC 22 PHONE MESSAGE 
22$ 
PLAINTIFFS DC. 23 AND 24 PHOTOS 
227 
12 
PLAINTIFFS EX. 2$ PHo 
GE 
230 
PLABTTIFFSFX. 26MS. 
240 
13 
CELLINIONE LOG 
PLAINTIFF'S EC 27 LETTER DATED JULY 24, 241 
14 
2006 
PLAINTIFFS DC 28 INTELLIGENCE REPORT 243 
DATED maw 
01.1•1•11W*1 
CFA,
Page 136 
PROSE 
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COURT REPORTING 
Page 138 
1 
BY MR. KUVIN: 
2 
Q. What is that? 
3 
MR. PIKE: Form. 
4 
THE WITNESS: It is a synthetic penis, 
5 
double, double sided. 
6 
BY MR. KUVIN: 
7 
Q. Okay. Double sided meaning it has, what, 
8 
two heads on it? 
9 
A. Yes. 
MR. PIKE: Fonm. 
BY MR. KUVIN: 
Q. How big is this? 
A. About 12 inches, 10, 12 inches. 
MR. PIKE: Objection to the form of that 
question. 
BY MR KUVIN: 
Q. Do you know where it was taken from? 
MR. PIKE: Form. 
THE WITNESS: It was in one of the 
bedrooms. 
BY MR. KUVIN: 
Q. Do you know if any DNA analysis was done 
on that? 
MR. PIKE: Form. 
THEE WITNESS: Not that I am aware of. 
r.), 
1,1 
.f7 
3 (Pages 135 to 138 
AGENCY, INC. 
Electronically signed by cynthla hopkins (601 
Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
aa2Mddb-fal31-4116-b3b7-dcda51494142 
EFTA00298296

Page 139 
1 
(Mr. Epstein returned the deposition 
2 
mom.) 
3 
BY MR. KUVIN: 
4 
Q. All right. Let's take a look at the next 
5 
page. Item 27, what was that? 
6 
A. It was a high school transcript —
7 
MR. PIKE: Form. 
8 
THE WITNESS: 
that was located in the 
9 
master bedroom. 
10 ' 
BY MR. KUVIN: 
11 
Q. Appears to be something blacked out. What 
12 
is blacked out? 
13' 
. 
A. The name of Jane Doe No. 103. 
14 
MR. PIKE: Form. 
15 
BY MR. KUVIN: 
16 
Q. Okay. Did you actually see this? 
17 
A. Yes, I did. 
18 
Q. And can you describe for me what it was? 
19 
MR. PIKE: Form. 
20 
THE WITNE 
• 
was h hi 
school 
21 
transcript from 
High School. 
22 
BY MR. KUVIN: 
. . 
23 
Q. Now, it says "VALUE not" What does that • 
24. 
mean? 
25 
MR. PIKE: Form. 
Page 141 
1 
THE WITNESS: I believe so. 
MR. PIKE: Move to strike. 
BY MR. !MIN: 
4 
. Q. Where in the house was this transcript 
5 
kelt 
6 
MR. PIKE: Form. 
7 
THE WITNESS: In the desk, the desk drawer 
8 
of the — there was a desk in the master 
9 
bedroom. 
10 
BY MR. KUVIN: 
11 
Q. Okay; So, in the master bedroom? 
12 
MR. PUCE: Form. 
13 
THE WITNESS: Yes, sir. 
14 
BY MR. KUVIN: 
15 
Q. Was there an office downstairs as well? 
16 
A. Yes. 
17 
Q. It was not found in the office? 
18 
MR. PIKE: Form. 
19 
THE WITNESS: No.. 
20 
BY MR. KUVIN: 
21. 
. Q. The next thing, Item 28, what was that? 
22. 
A. That was a bottle of Joy Jelly. 
23 
Q Did you determine what that is? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: It's a lubricant 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18.
19. 
20 
21'. 
22 
23 
24 
25 
Page 140 
THE WITNESS: That was written by Greg 
Parkinson, our crime scene manager, who was 
filling the form as to, when we identified the 
object we wanted to take, you would put it on . 
the property receipt 
BY MR. KUVIN: 
Q. Okay. With respect to this particular
transcript, was this taken by the FBI when they took' 
all the evidence? 
A. Yes. 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. Did you ever determine why her high school 
transcript was found in Mr. Epstein's home? 
MR. PIKE: Form. 
ME WITNESS: During my interview with' , 
: het, she claimed that Mr. Epstein had said that 
he was going to help her get into a good 
• 
college and when she graduated to give him a 
copy of the transcript to assist her in getting 
into a college. 
BY MR. KUVIN: 
Q. Did the high school transcript show her 
date of birth? 
MR. PIKE: Form. 
Page 142 
1 
MR. KUVIN: Sexual lubricant? 
2 
MR. PUCE: Form. 
•3 
• 
THE WITNESS: That's correct 
4 
BY MR. KUVIN: 
5 
Q. Where was that found? 
6 
A. In the credenza in the master bedroom. 
7 
MR. PIKE Form. 
8 
BY MR. KUVIN: 
9 
Q. Item 29 appears to be a bunch of 
10 
videotapes? 
11 
A. Yes. 
12 
Q. There is one there called "I Love Lesbians 
13 
Four." Do you see that? 
14 
A. Yes. 
15 
Q. Where was that found? 
16 
MR. PUCE: Form. 
17 
THE WITNESS: The master bedroom. 
18 
BY MR. KUVIN: 
19 
Q. Did you find massage tables during the 
20 
search of the home? 
21 
MR. PIKE: Form. . 
22 
THE. WITNESS: Yes, we did. We found a 
23 
couple of massage tables. 
24 
BY MR. KUVIN: 
25 
Eyhere? 
(561) 832-7500 
832-7500 
PROSE COURT REPORTING 
4 (Pages 139 to 142) 
AGENCY, INC. 
Electronically signed by cynthia hopkins (601 
Electronically signed by Cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
ea2a6ddb-fa81.4lf6•b3b7•dcda51494142 
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Page 143 
MR. PIKE: Form. 
THE WITNESS: One was in the master 
3 
bedroom area. There was another one found in 
4 
another bedroom area. There were different 
colors. There was like a green one, a white 
one, a peach one but --
7 
BY MR. KUVIN: 
8 
Q. Okay. Did you, yourself, personally see 
9 
the massage tables in the home when you were-there 
10. 
for the warrant? 
11 
MR. PIKE: Form. 
12 
THE WITNESS: That is correct. 
13 
BY MR. KUVIN: 
14 
Q. It appears that Item 34 was a number of 
15 
CD's? 
16 
A. Correct. 
17 
Q. Did you ever determine what was on them? 
18 
A. Everything was viewed, some of the CD's were 
19 
empty. But at the time we didn't know, we just had to 
20 
take it and view it. 
21 
Q. Items 34 through 40 on the list appears to 
22 
be a bunch of different medias such as ZIP CD's and 
23 
eight millimeter video, flash cards, ZIP CD's and 
24 
CD's. Did you view all those materials? 
25 
A. That is correct. 
Page 145 
1 
in any format that you felt was useful evidence for 
2 
Mr. Epstein's prosecution that was currently being 
3 
investigated? 
. 4 
MR. PIKE: Form. 
' 5 
THE WITNESS: There was a CPU that was in 
6. 
an office like the assistant's office. 
7 
MR. KUVIN: Okay. 
8 
THE WITNESS: That was not connected. It 
9 
was an Older CPU which was taken to the 
10 
Sheriffs Office for — to be analyzed. 
11 
MR. KUVIN: Okay. 
12 
THE WITNESS: They were able to retrieve 
13 
some images off that computer from that covert 
14 
camera in the living room, in that office 
15 
living room area. 
16 
BY MR. KUVIN: 
17 
Q. And what did those images show? 
18 
MR. PIKE: Form. 
19. 
THE WITNESS: It showed Mr. Epstein 
20 
sitting at his desk. It was basically motion 
21 
activated. When there was motion, it would 
22 
start to record. So, there was, there were 
23 
images of Epstein at his desk. There was 
24 
images of his assistant with Mr. Epstein 
25 
sitting at the desk. There were images of what 
Page 144 
1 
MR. PIKE: Form. 
2 
BY MR. KUVIN: 
3 
Q. Was there anything on these materials that 
4 
are listed on here, 34 through 40, that showed any 
5 
girls that you determined to be underage? 
6 
MR. PIKE: Form. 
7 
THE WITNESS: Some of the items that we 
8 
took from the guesthouse area were determined 
9 
to be Janusz's, the houseman, live-in houseman, 
10 
items which was returned to him once we 
11. 
determined that it was his. 
12 
BY MR. KUVIN: 
13 
Q. Okay. Anything else that you found on 
14 
there that you felt was of value for the prosecution 
15 
of Mr. Epstein? 
16 
MR. PIKE: Form. 
17 
BY MR. KUVIN: 
18 
Q. That you can recall. 
19 
MR PIKE: Same. 
20 
THE WITNESS: From the guesthouse? 
21 
BY MR. KUVIN: 
22 
Q. Well let me ask it this way, a little bit 
23 
broader: Based on the information that you 
24 
confiscated from the home during the warrant, search 
25 
warrant, did you find any cons uterized nf
r
1. 
I believe to be 
2 
well. 
3 
Again, the lighting was poor so a, I 
4 
couldn't positively say 100 percent, okay, 
5 
that's so-and-so. I could say that was 
6 
Mr. Epstein because I have seen Mr. Epstein. I 
7 
know what he looks like. You know I can say 
the female did appear to be 
one 
9 
of the assistants appeared to be 
10 
You know, that kind of thing. 
11 
BY MR. KUVIN: 
12 
Q. All right. Did you see any other girls in 
13 
that video that was on the CPU? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: There was someone else but 
16 
just can't recall who it was. 
17 
BY MR. KUVIN: 
18 
Q. Where is that CPU now if you knovfl 
19 
A. With the FBI. 
20 
Q. Was there any other digital information 
21 
that was seized that you were able to see that you 
22 
felt was helpful in any way to the investigation? 
23 
MR. PIKE: Form. 
24 
THE WITNESS: Not off the computer. 
Page 14. 
also shown as 
5 (Pages 143 to 146) 
(561) 832-7500 
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Page 147 
Page 149 
1 
BY MR. KUVIN: 
2 
Q. What about on any of the CD's or 
3 
flashcards that were taken? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: There was a video. It 
6 
appears to be, it appears to be in the private 
7 
island of Mr. Epstein when you see a helicopter 
8 
coming in, and there was some females there 
9 
dancing 
10 
BY MR KUVIN: 
11 
Q. Was this on a computer format like a CD or 
12 
a flash drive or —
13 
A.. I believe it was an — 
14 
Q. — an eight millimeter? 
15 
A. I might have been an — 
16 
MR. PIKE: Form. 
17 
THE WITNESS: Eight millimeter. 
18 
BY MR. KUVIN: 
19 
Q. Okay. Any other media information that 
20 
you can recall after having reviewed all of the 
21 
things that you confiscated from the home that you 
22 
found was helpful in the investigation? 
23 
MR. PIKE: Form. 
24 
THE WITNESS: Not that I can recall. 
25 
1 
BY MR. KUVIN: 
2 
Q. I want to come back to that fora minute. 
3 
How many CPU's did it appear to you were missing? 
4 
MR. PIKE: Form and speculation. 
5 
THE WITNESS: There was one missing from 
6 
the desk area in the living room with the power 
7 
cords — all the cords were there. The CPU was 
gone. 
9 
MR KUVIN: Okay. 
10 
THE WITNESS: There was one from the pool 
11 
house where the cords were there, the monitor 
12 
was there, the keyboard, the mouse. The CPU 
13 
was gone. I would say two. 
14 
BY MR. KUVIN: 
15 
Q. Okay. Did you ever come to team during 
16 
the investigation where those CPU units were? 
17 
MR. PIKE: Form. 
18 
THE WITNESS: I believe I was told that 
19 
those CPUs were actually sitting in an 
20 
attorneys safe. 
21 
BY MR. KUVIN: 
22 
Q. Okay. Did you come to learn that they, 
23 
that Guy Fronstin had actually taken possession of 
24 
those? Does that refresh your recollection at all, 
25 
or was it another attorney? 
Page 148 
1 
BY MR. KUVIN: 
2 
Q. Now, it appears that you confiscated as 
3 
part of the search warrant a number of CPUs and 
4 
their power cords; is that correct? 
5 
A. Yes. 
6 
MR. PIKE: Form. What page are you on? 
7 
MR. KUVIN: It looks like 43 and 44. 
8 
Items 43 and 44 are the first power cords and 
' 9 
CPU. Items 54 and 55 are the second power cord 
10 
and CPU. 
11 
BY MR. KUVIN: 
12 
Q Do you recall how many CPUs you took into 
13 
custody? 
14 
• A. We took a couple but obviously one of them 
15 
was positive that it belonged to Janusz because it had 
16 
all his personal stuff; his personal photographs of he 
17 
and his wife. So those were returned to him. 
18 
Q. Okay. 
19 
MR. PIKE: Form to that question. 
20 
BY MR. KUVIN: 
21 
Q You mentioned at the beginning when you 
22 
executed the search warrant that you felt in your 
23. 
opinion the house had been sanitized because you 
24 
noticed things that appeared to be missing. 
25 
MR. PIKE: Form. 
Page 150 
1 
MR. PIKE: Forst 
2 
THE WITNESS: I was told it was Roy 
3 
Black's office that had them. 
4 
BY MR. KUVIN: 
5 
Q. Gotchat. All right. Let's keep going 
6 
here. Item 58 was another massage table that was 
7 
taken as evidence? 
8 
A. Correct. 
9 
MR_ PIKE: Form. 
10 
BY MR. KUVIN: 
11 
Q. You saw that massage table? 
12 
A. Yes, sir. 
13 
Q: Okay. La look at the next page, six of 
14 
six. It says a green photograph with a naked girl. 
15 
Do you recall where that was taken from? 
16 
A. That was taken out of the, I believe, master 
17 
bedroom. 
18 
MR. PIKE: Form. 
19 
BY MR. KUVIN: 
20 
' Q. Could you tell by looking at the 
21 
photograph whether it was an underage girl? 
22 
MR. PIKE: Form. 
23 
BY MR. KUVIN: 
24 
Q. I mean, was it a young girl, a mature 
25 
girl, old? 
•••••••••••sts•n
eV1---, 204aV
vie
lS4LS 
.o.,..., 
6 (Pages 147 to 150 ) 
PROSE COURT REPORTING AGENCY,' INC. 
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Page 151 
A. No, it was a young girl. 
MR. PIKE: Same objection. 
THE WITNESS: Very young girl. 
BY MR. KUVIN: 
Q. Could you tell the age from the photo? 
MR. PIKE: Form. 
THE WITNESS: Younger than ten. 
BY MR. KUVIN: 
Q. Could you find any photographs of girls 
that were victims during the investigation? Did you 
find any photographs of girls that were victims 
during the investigation? 
MR. PIKE: FOUR 
THE WITNESS: There were photographs taken 
during the search warrant, topless females that 
were taken. But no, I did not locate one of 
the victims in the photos. 
MR. KUVIN: Okay. If we look at what 
we'll mark as Exhibit 5, appears to be a 
supplement of the chain of custody log. two 
pages. Make sure I have got it. Ifs three 
pages actually. 
(Plaintiffs Exhibit No. 5 was marked for 
identification.) 
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10 
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Page 153 
touched on this briefly in the beginning, but what 
happened with the investigation once you filed the 
probable cause affidavit and got the warrant? At 
what point did you turn it over to the State 
Attorney's Office? 
A. Once I filed the arrest warrant for 
Mr. Epstein, there were actually three warrant requests 
to be honest with you. There was a warrant raLmt for 
Je 
in, I want to say 
=, 
and 
Q. Okay. What happened with those arrest 
warrants for all three of them? 
MR. PIKE: Form. 
THE WITNESS: Once they were turned over 
to the State Attorney's office, I was notified 
several days later that they were going to be 
requesting a grand jury to listen to the case. 
BY MR. KUVIN: 
Q. Okay. And did a grand jury hear the case 
as far as you know? 
A. Eventually they did. 
Q. And do you know what occurred after the 
grand jury heard the case? 
MR. PIKE: Form. 
THE WITNESS: It was true bill. 
Page 152 
1 
BY MR. KUVIN: 
2 
Q. We have got what appears to be a four-page 
3 
document which happens to be called a chain of 
4 
custody. I just have a couple quick questions about 
5 
this. 
If you would look at the last entry in the 
7 • 
chain of custody, I just wanted to coafum where all 
8 
the evidence went according to the documentation. 
9 
A. Everything went TOT, to the FBI. 
10 
Q. I am sorry, what were the initials? 
11 
A. TOT. 
12 
Q. What does that mean? 
13 
A. Given to the FBI. 
14 
Q Okay. So the chain of custody which we 
15 
have marked as Exhibit 5 shows that all the evidence 
16 
you had in this case was given over to the FBI; is 
17 
that correct? 
18 
MR. PIKE: Form. 
19 
THE WITNESS: The items that were returned 
20 
to Janusz were returned to Janusz (sic). The 
21 
items that were not returned were given to the 
22 
FBI. 
23 
BY MR. KUVIN: 
24 
Q. Okay. Great. All right. Ultimately what 
25 
happened with respect to the investigation, and I 
Page 154 
1 
BY MR. KUVIN: 
Against? 
3 
A. Mr. Epstein. 
4 
Q Just for people that may not know what a 
5 
true bill is, can you explain briefly what that 
6 
means? 
7 
A. Grand jury found sufficient evidence to charge 
8 
Mr. Epstein. 
9 
Q What was he charged with? 
10 
MR. PIKE: Form. 
THE WITNESS: I think it was, it was a 
12 
procurement for prosecution. 
13 
BY MR. KUVIN: 
' 
. 
14 
Q. Have to do with minors? 
15 
A. Yes. 
16 
MR. PIKE: Form. 
17 
BY MR. KUVIN: 
18 
Q All right. After the execution of the 
19 
search warrant, your investigation continued; is 
20 
that correct? 
21 
A. Correct 
22 
Q. And during the investigation, did you have 
23 
occasion to speak with or meet with a gentleman by 
24 
the name of Juan Alessi? 
25 
A. Juan Alessi, yes. 
7 (Pages 151 to 154) 
PROSE COURT REPORTING AGENCY, INC. 
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Q. Who was that? 
2 
A. He was the former houseman of Mr. Epstein. 
3 
MR. PIKE: Form. 
4 
BY MR. KUVIN: 
5 
Q. Did he give you information that you felt 
6 
was helpful in the prosecution of Mr. Epstein? 
7 
MR. PIKE: Form. 
8 
THE WITNESS: He described, he described 
9 
washing off the vibrator massagers after the 
10 
massage incidents. He recalled having young 
11. 
girls coming in to do the massages. 
12 
BY MR. KUVIN: 
13 
Q. Did he mention that he, whether he 
14 
witnessed that? 
15 
MR. PIKE: Move to strike witness's last 
16 
statement pending hearsay and form. 
17 
Mr. Kuvin, next question if he has 
18 
completed it. 
19 
BY MR KUVIN: 
20 
Q. Did he mention whether or not he had 
21 
witnessed young girls coming to the house? 
22 
MR. PIKE: Same objection. 
23 
THE WITNESS: Yes. 
24 
BY MR. KUVIN: 
25 
Q. If we look back at the incident report 
1 
THE W/TNESS: No. 
2 
BY MR. KUVIN: 
3 
Q. Narrative 18, it looks like you matte 
4 
telephone contact with another white, looks like WF, 
5 
I assume it means white female, on November 8. Do 
6 
you recall which girl that may have been? 
7 
MR. PIKE: Form. 
8 
BY MR. KUVIN: 
9 
Q. Let me ask it this way: Was this a 
10 
recounting of the incident with Ms. Jane Doe No. 
11 
103? 
12 
A. No. 
13 
Q. This is a different girl? 
14 
A. Ibis is a different girl. 
15 
MR. PACE: Form to both questions. 
16 
THE WITNESS: This was a different girl 
17 
and I am trying to remember who it was. 
18 
BY MR. KUVIN: 
19 
Q. Do you recall the name M? 
20 
A. Yes. 
21 
Q. Is that who this was? 
22 
MR. PIKE: Form. 
23 
THE WITNESS: Yes, it was. 
24 
BY MR. KUVIN: 
25 
Q. Okay. And apparently she had reported 
Page 156 
1 
Page 47 — got it there — it looks like you made 
2 
contact, telephone contact with another girl on 
3 
November 7 of 2005, and took another taped 
4 
statement, sworn taped statement. Can you determine 
by looking at your swnmary there in Narrative 16 of 
6 
November 7,2005, which girl that was? 
7 
MR. PIKE: Form. 
8 
THE WITNESS: I believe that was■ 
9 
MR. KUVIN: 
10 
THE WITNESS: 
1
1
 
BY MR. KUVIN: 
12 
Q. Do you recall wha.s state of mind or 
13 
emotional condition was when she spoke to you about 
14 
this event? 
15 
MR. PIKE: Form. 
16 
THE WITNESS: I can't recall. 
17 
BY MR. KUVIN: 
18 
Q. Let's take a look at Narrative 17. It 
19 
looks like you made contact with someone else, you 
20 
along with Detective Dawson made contact with 
21 
somebody and left a business card at the front door. 
22 
Do you see that? 
23 
A. Yes. Yes,' do see it. 
24 
Q. Do you recall which girl that was? 
25 
MR. PIKE: Form. 
1 
2 
3 
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5 
6 
7 
8 
9. 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
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Page 158 
sexual intercourse with Mr. Epstein? 
A. That is correct. 
MR. PIKE: Form, leading. 
BY MR. KUVIN: 
Q. Did she report any sexual contact with 
Mr. Epstein? 
A. Yes, she did. 
Q. What type? 
MR. PIKE: Form. 
THE WI NESS: She was paid to have vaginal 
intercourse. 
MR. PIKE: Form, move to strike. 
BY MR. KUVIN: 
Q. Did you determine how old she was when she 
reported having this vaginal intercourse with 
Mr. Epstein? 
MR. PIKE: Form. 
THE WITNESS: Sixteen years of age. 
MR. PIKE: Spencer, can you hold on? 
MR. KUVIN: Yes, sir. 
MR. PIKE: Letts go off the record for a 
second. 
(A discussion was held off the record.) 
MS. EZELL: If I could interject, I was 
fumblin on mute and I wanted to move to strike 
••••••••••••• 
8 (Pages 155 to 158) 
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Page 159 
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the witness's comment that she was paid to have 
2 
vaginal intercourse with Mr. Epstein. 
3 
MR. KUVIN: Okay. 
4 
BY MR. KUVIN: 
5 
Q. Do you recall the demeanor ofM 
when 
6 
she was recounting this for you? 
7 
MR. PIKE: Form. 
8 
BY MR. KUVIN: 
9 
Q. Was she upset, calm? How did she appear 
10 
to you? 
11 
MR. PIKE: Form. 
12 
THE WITNESS: She did — I recall her 
13 
being upset, talking to me. Occasionally 
14 
crying. It wasn't like a hysterical cry but 
15 
she was visibly upset 
16 
BY MR. KUVIN: 
17 
Q. Okay. Do you recall Ms. Ms date of 
18 
birth? 
19 
A. Not off the top of my head. 
20 
MR. KUVIN: All right. Let me see if I 
21 
can help you here. It looks like we have an 
22 
unredacted copy of the PC affidavit That will 
23 
help. This document will remain sealed 
24 
pursuant to all previous agreements in the case 
25 
with respect to any documents that we referred 
1 
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Page I(_ 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. Does she describe whether or not she had 
gone to Mr. Epstein's home? 
A. Yes. 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. Did she describe whether or not she 
brought anyone with her during that time? 
MR. PIKE: Form. 
THE WITNESS: If I can read —
MR. KUVIN: Yes. You can refer back to it 
if you need to. 
MR. PIKE: For the record you're referring 
back to Exhibit 1, correct? 
THE WITNESS: Correct. Yes, she did. 
BY MR. KUVIN: 
Q. Okay. Now, if we look at Page 16 of 22 
there with respect to Ms.■ it mentions 
something about a Christmas bonus. Do you see that? 
A. Yes. 
Q Can you explain to us what she told you 
about that? 
MR. PIKE: Form. 
THE WITNESS: She received a wire, a 
Page 160 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
Q. 14th, correct. Thank you. And her date 
:2she 
25 
. A. 
to. 
2 
THE WITNESS: That's Exhibit 1? 
3 
MIt KUVIN: Bingo. Do you have a copy? 
4 
MR. PIKE: Thank you. 
5 
MR. KUVIN: If you turn to Page 15 of 
22 — 
MR. EDWARDS: I have one thanks. 
BY MR. KUVIN: 
Q. Do you have Page 15? 
A. Uh-huh. 
Q. If we look there, what was Ms date of 
birth? 
A. 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. All right Let's go to, let's stay with 
this because it's unredacted because it will be a ' 
little
gasier. November 15 you apparently met 
withE is that correct? 
PIKE: Form. 
THE WITNESS: 14th I believe it was. 
BY MIt KUVIN: 
Page 162 
1 
Western Union wire to what she referred to as a 
2 
Christmas bonus. 
3 
Q. Who did it come from? 
4 
A. Mr. Epstein. 
5 
MR. PIKE: Form. 
6 
BY MR. KUVIN: 
7 
Q. All right. On November 15 you met with 
8 
someone with the initials= is that correct? 
5 
A. Correct. 
10 
Q. Do you agawho that was? 
11 
A. Yes, it's= 
12 
Q. . What was her date of birth? 
13 
MR. PUCE: Form. 
14 
THE WITNESS: 
15 • 
BY MR. KUVIN: 
16 
Q • Did she recall going to Mr. Epstein's 
17 
bony? 
18 
MR. PIKE: Form. 
19 • 
THE WITNESS: Yes. 
20 
BY 1ViR. KUVIN: 
21 
Q. What was her emotional state when you 
22 
'talked to her?
23 ' 
A. She was nervous, scared, and embarrassed. 
24 
Q Okay. Did she recount going to 
25 
Mr. E • tein's home? 
PROSE COURT REPORTING AGENCY, 
9 (Pages 159 to 1 62) 
INC. 
Electronically signed by cynthia Hopkins (601 
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i-age 163 
A. Yes. 
2 
MR. PUCE: Form. 
3 
BY MR. KUVIN: 
4 
Q. Was she underage? 
5 
MR. PIKE: Form. 
THE WITNESS: Yes. 
BY MR. KUVIN:
Q. Do you recall how old she was when she 
went there? 
MR. PIKE: Form. 
THE WITNESS: Sixteen. 
BY MR. KUVIN: 
Q. Okay. Much like all the other occasions 
that we have talked about today, was Mr. Epstein 
naked and received a massage from her? 
A. Correct. 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. She was given money like all the other 
girls for that massage? 
MR. PIKE: Form. 
THE WITNESS: Yes. 
BY MR. KUVIN: 
Q. And also much like all the other girls, 
was there also a massager and vibrator involved in 
Page 164 
1 
that incident? 
2 
MR. PIKE: Form. 
3 
THE WITNESS: I believe so. 
4 
BY MR. KUVIN: 
5 
Q. Next page, 18 — one thing I forgot to ask 
6 
is during the execution of the warrant, if we look 
7 
then at Line 4 it says: "Numerous photographs of 
8 
naked young females, some of which appeared to be 
9 
the girls I previously interviewed, were on display 
10 
throughout the house.' Do you see that? 
11 
A. Yes, 
12 
Q. Do you resell that? 
13 
MR. PIKE: Form. 
14 
THE WITNESS: That was on the photos 
15 
hanging on the way up the stairwell to the 
16 
second floor. Some appeared to be the girls 
17 
but under closer observation, no. 
18 
BY MR. KUVIN: 
19 
Q. But they were naked, or pictures of naked 
20 
girls leading up that stairwell? 
21 
MR. PIKE: Form, asked and answered. 
22 
THE WITNESS: Yes. 
23 
BY MR. KUVIN: 
24 
Q. And the stairwell, where was it located? 
25 
A. Off the kitchen. There was apassage door 
—ter® 
Page 165 
1 
that would swing open and it led you up a stairwell that 
2 
just went up and around. 
3 
Q. All right. And bottom paragraph on 
4 
December _ ?
 SI_Detective and I met within Do you 
5 
recall whonis? 
6 
A. Yes, Jane Doe No. 2. 
7 
Q. What was her date of birth? 
MR. PIKE: Form. 
9 
THE WITNESS: 
10 
BY MR. KUVIN: 
11 
Q. And it say.' made arrangements to take 
12 t o the house. Did that mean to Mr. Epstein's 
13 
14 
MR. PIKE: Form. 
15 
THE WITNESS: Correct. 
16 
BY MR. KUVIN: 
17 
Q. Who is 
18 
A. Jane Doet. 3. 
19 
. 
Q. Did you determine whether or not e, 
20 
Ms. Doe No. 2, was taken to Mr. Epstein's home when 
21 
she was minor, in other words under the age of 18? 
22 
MR. PIKE: FOrM. 
23 
THE WITNESS: Correct 
24 
BY MR. KUVIN: 
25 
Q. And once again didErecount a sexual 
Page 166 
1 
encounter with Mr. Epstein while at his home? 
2 
A. That's comet. 
3 
MR. PIKE: Form. 
4 
BY MR.. KUVIN: 
5 
Q. Once again encountered Mr. Epstein where a 
6 
massage took place? 
7 
MR. PIKE: Form. 
8 
THE WITNESS: Correct. 
9 
BY MR. KUVja 
10 
Q. When 
recounted her incident to you, 
11 
what was her demeanor? 
12 
MR. PIKE: Form. 
13 
THE WITNESS: Crying, upset, embarrassed. 
14 
BY MR. KUVIN: 
15 
Q. Did she mention whether or not she told 
16 
Mr. Epstein where she was attending school? 
17 
MR. PIKE: Form. 
18 
THE WITNESS: I believe she did. I 
19 
believe she did. 
20 
BY MR. KUVIN: 
23. 
Q. And Pm looking at Page 19 of 22. It 
22 
appears there is an encounter she describes where 
23 
Epstein rubbed her breasts and asked her if she 
24 
liked having her breasts rubbed. Do you recall 
25 
that? 
- I" aft' llis00..."..•4.1 
10 (Pages 163 to 166) 
PROSE COURT REPORTING AGENCY, INC. 
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Page 169 
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MR. PIKE: Form, move to strike. 
THE WITNESS: Yes. 
BY MR. KUVIN: 
Q. What did ML say to you with respect to 
that issue? 
MR. PIKE: RPM 
THE WITNESS: I believe she didn't, she 
didn't want to have her breasts touched, if I 
recall. 
BY MR. KUVIN: 
Q. It says here — well, let me ask you this: 
Was this interview recorded? 
A. Yes, 
Q. And during the entire interview was she 
upset, crying? 
MR. PIKE: Form. 
THE WITNESS: I wouldn't say the entire 
interview. There was times she would cry. She 
would regain her composure, continue. 
BY MR. KUVIN: 
Q. Okay. It says here that she told you 
Epstein had moved her thong panties to one side and 
began stroking her clitoris, andlEsaying he 
commented on how hard my cht was. Do you see that? 
MR. PIKE: Form 
1 
2 
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4 
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his fingers out. Pm trying to recall. 
MR. PIKE: Form, move to strike, 
nonresponsive. 
BY MR. KUVIN: 
Q. Do you recall anything else? 
A. No. That would be a no. I'm sony. 
MR. PIKE: I'm sony. I didn't hear the 
question. 
MR. KUVIN: You didn't recall anything 
else (sic)? 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. All right. Let's talk about the next 
entry in some detail here. The next entry is an 
interview that took place on January 9 of 2006; is 
that correct? 
A. Yes. 
Q. Was that a taped interview? 
A. Yes, taped. 
thsakay. 
And the initials• are used. Is 
MR. PIKE: Form. 
THE WITNESS: ThaVs correct. 
BY MR. KUVIN: 
Q. What wasins date of birth? 
Page 168 
1 
MR. KUVIN: Right in the center of the 
2 
paragraph. 
3 
THE WITNESS: Yes. 
4 
BY MR. KUVIN: 
5 
Q. Did she ten you that? 
6 
A. Yes, she did. 
7 
MR. PIKE: Form. 
8 
BY MR. KUVIN: 
9 
Q. Did she appear upset when she was 
10 
describing that to you? 
11 
MR. PIKE: Form. 
12. 
. 
THE WITNESS: Yes. 
13 
BY MR. KUVIN: 
14 
Q. Did she then describe whether or not 
15 
Mr. Epstein penetrates her with his fingers? 
16 
MR. PIKE: Form. 
17 
THE WITNESS: Digitally, yes. 
18 
BY MR. KUVIN: 
19 
Q. What was Mr. Epstein's response when she 
20 
voiced concern about that maneuver? 
21 
MR. PIKE: Form. 
22 
THE WITNESS: I think originally he told 
23 
her he was not going to go inside and began 
24 
touching her. Once his fingers were inside of 
25 
her I think she tried to back • to 
to net 
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Page 110 
A. 
Q. Okay. How did you identify her as a 
potential victim or witness? 
MR. PIKE: Form. 
THE WITNESS: It was during an interview 
of another, of another female that was 
interviewed. Told me thatM was brought to 
the house if I can recall. 
BY MR. KUVIN: 
Q. And do you recall where you initially 
interviewed her? 
A. I went to her school. She was attending a —
it was not like a regular school. It was a different 
school, as I recall. 
Q. And when you went to that school, describe 
for us what you saw. !don't vault to hear anything 
about statements, just what you witnessed when you 
first went there. 
MR. PIKE: Form. 
THE WITNESS: I identified who I was and 
my purpose for being there, and I wanted to 
talk to her about this ongoing investigation. 
She started to cry. She got visibly upset, 
shaking. 
11 (Pages 167 to 170) 
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Page 171 
1 
BY MR. KUVIN: 
2 
Q. Did you, in fact, conduct the interview on 
3 
that initial occasion? 
A. No, I did not. 
5 
Q. How come? 
6 
A. Because of the fact that she was a minor and I 
7 
was at the school. 1 wanted to inform her father or her 
9 
parents that I was going to be conducting an interview. 
9 
Q. Okay. Did she appear to you in a physical 
10 
or mental state capable of discussing anything with 
11 
you at that point based on just what you witnessed, 
12 
not what she may have said but just what you were 
13 
able to witness? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: No. 
16 
BY MR. KUVIN: 
17 
Q. Can you describe why? 
18 
MR. PIKE:. Same objection. 
19 
THE WITNESS: She was shaken. She was 
20 
physically upset. 
21. 
BY MR. KUVIN: 
22 
Q. Okay. Did you have to then follow-up? 
23 
A. Yes, I did. 
24 
Q. Tell me about that. 
25 
MR. PiKE: Form. 
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Page 173 
have asked, because you have literally objected 
to eves), question I have asked. 
MR. MICE: I have. 
MR. KUVIN: And if that's the standing for 
the objection, you can have a standing 
objection as to all of that And then what I 
would I like to know is with each individual 
question, if there is a way that I can fix the 
form of that question because of some reason 
that you think is objectionable, I would like 
to know that so Jean try to fix it 
MR. PIKE: Well, let me also say that the 
form elicits third-party testimony. Almost 
every one of your questions here today, every 
one of them elicit third-party testimony which 
is hearsay and opinion. 
And no, I will not agree, although I 
appreciate your offer to have a standing form 
objection, I think that each objection needs be 
to raised individually based upon the tenor and 
structure of your questions. 
Some of your questions I have not objected 
to form because the question is was there an 
investigation. Okay. I am not going to object 
to form. 
Page 172 
1 
MR. KUVIN: Hang on one second. Objection 
2 
to form to 'tell me about that"? 
3 
MR. PIKE: It's an investigation and jam 
4 
not going to waive anything I want to preserve. 
5 
MR. KUVIN: is there a particular form 
6 
that I can fix? 
7 
MR. PIKE: Quite frankly I am not quite 
sure you can fix any of this deposition today. 
9 
I believe that this deposition, once again, is 
10 
completely-
11 
MR. KUVIN: • The question. 
12 
MR. PiKE: -- completely fruitless because 
13 
it is involving an investigation. None of it, 
14 
in my research or understanding is admissible 
15 
in the civil cases.' So, there are various 
16 
things that while your questions in and of 
17 
themselves may seem correct, the background in 
18 
which you're eliciting them from is not 
19 
admissible, so as a result it makes the 
20 
form incorrect. 
21 
MR. KUVIN: Let's do this then, why don't 
22 
we do a standing objection as to all questions 
23. 
during the deposition as to the taking of 
24 
anything regarding statements, so that you 
24 
25 
don't hannio2liec........a
ct to every
 that I 
_,...a 
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Page 174 
But when you get into what occurred during 
that investigation, how he learned of it, who 
he spoke to, and how many third parties 
discussed it with the first person that he 
spoke to, and how those individuals learned the 
information, I must assert the form and 
preserve. 
MR. KUVIN: All right. Les talk about 
this though for a minute because this is 
• 
important And I'm sorry for taking up your 
time, Detective, but these questions — 
THE WITNESS: No. 
MR. KUVIN: — involve my client= so 
any statements that she made to this Officer 
• are admissions by a party opponent obviously 
are admissions by a party. So the hearsay
issue is frivolous.
With respect to anything that she said to 
him is completely admissible in this proceeding 
and clearly what he witnessed is admissible 
because that is eyewitness. He witnessed it 
himself.
So anything with respect to what he saw 
and what he witnessed, any objections regarding 
h
.......2Ljarsa
t
abo that is comletel  frivolous. 
12 (Pages 171 to 174) 
PROSE COURT REPORTING AGENCY, :INC. 
Electronically signed by synth's hopkins (601 
Electronically signed by cynthia hopkins (601 
Electronically signed by Cynthia hooklike (601 
aa2a5ddb.fa81-4H6-b3b7-dcda51494142 
EFTA00298305

Page 1', 
Page 177 
1 
What I need to know is when' 
2 
questions specifically with respect 
3 
which I am about to do, I need to know 
ether 
4 
or not there is a particular objection to the 
5 
form of my question that is specific to that 
6 
question as opposed to the structure of the 
7 
deposition, which if you want to object 
8 
generally, then that's fine. I need to know 
9 
that because if I ask a question specific to my 
10 
client, l want to know if there is a way that 
11 
you feel that it needs to be fixed that I can 
12 
take care of and fix presently with Detective 
13 
Recarey in the room. 
14 
MR. PIKE: Okay. As to your statements 
15 
regarding the frivolous hearsay objections, you 
16 
seem to forget that this deposition has been 
17 
cross-noticed by several attorneys who are 
18 
sitting here today. So, as a result you're 
19 
taking this deposition, but this is a 
20 
cross-noticed deposition. And as a result I 
21 
have to maintain the form assertions as well as 
22 
various privileges for these other individuals 
23 
who are representing several other alleged 
24 
Plaintiffs in these cases. That's Number 1. 
25 
So, just because you're asking the 
Page 176 
1 
questions here today, Mr. Kuvin, maybe you 
2 
should talk to your co-counsel about 
3 
cross-noticing these depositions because maybe, 
4 
in fact, it is prejudicing your case. That's 
5 
Number I. 
6 
As Number 2, with regard to his eyewitness 
7 
accounts, whether or not he observed someone's 
8 
mental state or whether or not they were in a 
9 
specific state when he spoke to them, he is not 
10 
an expert. So, you andllcnow, you and I try 
11 
several cases, and we know good and well that 
12 
police officers are not‘xpcilb when it comes 
13 
to the psychological state and mental condition 
14 
- 
of a particular person on a particular time or 
15 
a particular day, how did they feel, how did 
16 
they look, you know, layperson observations. 
17. 
But how did they feel, their mental state, I am 
18 
going to preserve the form. 
19 
MR. KUVIN: Okay. 
20 
MR. PIKE: Thanks. 
21 
BY MR. KUVIN: 
22 
Q. With respect to this July 9,2006, 
23 
interview that you took of C.I.. did she provide to 
24 
you the date of her birth? 
25 
MR. PIKE: Form. 
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THE WITNESS: Yes, she did. 
BY MR. KUVIN: 
Q. And did she tell you how old she was when 
she went to Mr. Epstein's home? 
MR. NICE: Form. 
THE WITNESS: Yes, she did. 
BY MR. KUVIN: 
Q. How old did she tell you that she was when 
she went to it. Epstein's home? 
MR. PIKE: Form. 
THE WITNESS: I believe she said she was 
15. 
BY MR. KUVIN: 
Q. Okay. And did she tell you who took her 
to Mr. Epstein's home? 
MR. PIKE: Form. 
THE WITNESS: I believe, `-I
think it was. 
BY MR. KUVIN: 
Q. Did she recount to you what-explained 
about this visit to Mr. Epstein's home? 
MR. PIKE: Form. 
MR. KUVIN: And if you can't recall, you 
can refer to the probable cause affidavit, 
Pages 19 and 20. 
Page 178 
MR. PIKE: Just for purposes of the record 
something else just came to mind is that you 
said 
s line of questioning is to your 
client 
h
ied case against 
Jeffrey Epstein, an 
has not provided any 
sort of information re anve to she being, her 
being your client 
So, in that regard I also have to assert 
form and preserve. 
MR. KUVIN: She will. 
MR. PIKE: I know. 
BY MR. KUVIN: 
• 
Q. Okay. Did she explain what Ms. 
old 
her about the visit to Mr. Epstein's home? 
k 
Ifl can refer to the —
Q. Please do. 
MR. PIKE: Form. 
THE WITNESS: She was to model lingerie 
. 
for a wealthy person in Palm Beach. 
BY MR. KUVIN: 
Q. Okay. Was there any notice given 
according to what Ms. 
told you that she would 
have to get naked or doing anything sexual? 
MR. PIKE: Form..
13 (Pages 175 to 178) 
PROSE COURT REPORTING AGENCY, INC; 
:(5'61) 832.7506 
Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
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EFTA00298306

Pagc: 
Page 181 
1 
BY MR. KUVIN: 
2 
Q. And you can refer to your tcpo, t if you 
3 
don't recall. 
4 
A. Ism going to have to refer. 
5 
Q. That's fine. 
6 
A. It was some time ago, so... 
7 
Q. When 
described what she was supposed 
8 
to do at the home of Mr. Epstein, was there any 
9 
discussion about being naked or having a massage or 
10 
anything like that? 
11 
MR. PIKE: One second becaace I don't 
12 
understand the question. When MI described 
13 
to
 or to Detective Recarey? 
14 
MR. KUVIN: Correa. 
15 
BY NIR. KUVIN: 
16 
Q. When= talked to. 
about what to 
17 
expect at Mr. Epstein's home, was there any 
18 
discussion about getting naked initially? 
19 
MR. PIKE: Form 
20 
THE WITNESS: Not initially. 
21 
BY MR. KUVIN: 
22 
Q. All right. What clic=tell you 
23 
happened when she got at the home, got to the home? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: I believe the private chef 
1 
THE WITNESS: Yes, he did. 
2 
BY MR. KUVIN: 
3 
Q. Where? 
4 
A. I believe he stroked her vagina. 
5 
Q. Do you recall whether she discussed if he 
6 
touched her breasts as well? 
7 
MR. PIKE: Form. 
8 
THE WITNESS: He may have. I'm trying to 
9 
recall. I believe so. 
10 
BY MR. KUVIN: 
11 
Q. Okay. What did she tell you Mr. Epstein 
12 
was doing during this massage? 
13 
MR. PIKE: Form. 
14 
ME WITNESS: Masturbated. 
15 
BY MR. KUVIN: 
16 
Q. Did he, did she tell you whether he 
17 
ejaculated eventually? 
18 
MR. PIKE: Form. 
19 
THE WITNESS: I believe he did. 
20 
MR. PIKE: And leading. 
21 
BY MR. K Silk: 
22 
Q. Did 
•'scuss anything with you about 
23 
threats made 
. Epstein to hell 
24 
MR. PIKE: Form. That would be double 
25 
hearsay. 
Page 180 
1 
prepared dinner for them. At the conclusion of 
2 
dinner, they went upstairs to do the massage. 
3 
(Mr. Epstein left the deposition room.) 
4 
S: And that was the time that I 
5 
believe 
anted of this massage. 
6 
BY MR. KUVIN: 
7 
Q. And how did-initially react to that? 
8 
MR. PIKE: Form. 
9 
THE WITNESS: She had ask 
why they 
10 
were going to do the massage instead
11 
modeling. 
12 
BY MR. KUVIN: 
13 
Q. . All right MIN have to get or did 
14 
she get undressed according to her? 
15 
A. Yes, she did. 
16 
MR. PIKE: Form. 
17 
BY MR. KUVIN: 
18 
Q. And did she tell you whether or not she 
19 
gave Mr. Epstein a massage while he was naked? 
20 
MR. PIKE: Form. 
21 
WE WITNESS: Yes. 
22 
BY MR. KUVIN: 
23 
Q. Did she explain to you whether Mr. Epstein 
24 
touched her? 
25 
MR. PIKE: Form. 
Page 182 
1. 
/vM. KUVIN: Actually double admission, so 
2 
it comes in. 
3 
MR. PIKE: Well, only now you bring up 
4 
another whole point which is why I keep 
5 
objecting to form, just so the record is clear 
6 
is only admissions against interest are 
7 
admissible, and you have been talking about 
8 
your client and other alleged victims. And I 
9 
haven't heard any admissions — or let me not 
10 
identify them — but I haven't heard you 
11 
specifically identify admissions against 
12 
interest to survive my form objection. So you 
13 
can proceed. 
14 
MR. KUVIN: It's actually a commonly 
15 
misinterpreted concept in the law. And it's 
16 
not admission against interest. It's actually 
17 
admission by a party opponent. Under the 
18 
Florida Rules it doesn't have to be against 
19 
interest, but we can research that later. 
20 
BY MR. KUVIN: 
21 
g 
All right With respect to Mr. Epstein's 
22 
threats did Mr. Epstein, did -- let me clarify. Did 
23 
say whether Mr. Epstein threatened her after 
24 
the massage took place? 
25 
MR. PIKE: Form. 
14 (Pages 179 to 182) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
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Page 183 
1 
THE WITNESS: She stated that if she spoke 
2 
of this to anyone, bad things could happen 
3 
BY MR. KUVIN: 
4 
Q. Did Ms.. tell you that she was afraid? 
5 
MR. PIKE: Form. 
o 
THE WITNESS: Yes. 
7 
BY MR. KUVIN: 
8 
Q. Did she explain why she was afraid? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: Yes, she did. She explained 
11 
that because he was very wealthy, you know, 
12 
that he could pay someone to hurt her or her 
13. 
family. 
14 
BY MR. KUVIN: 
15 
Q. Did Ms 
explain whether or not she 
16 
received any 
atonal contact from Mr. Epstein or 
17 
one of his agents? 
18 
MR. PIKE: Form. 
19 
THE WITNESS: I believe she went another 
20 
time to the house. 
21 
BY MR. KUVIN: 
22 
Q. All fight. If you wovulelice a look at 
23 
Page 20 of 22. It says here: 
stated that 
24 
sever 
he recei 
a telephone call 
25 
from MEM 
who coordinated for= to return 
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Page 184 
to, quote, work Do you see that? 
A. Yes. 
egjaii ever able to verify and document 
that
 actually contacted.by 
telephone records? 
Il
ranced joilt
ne 
lerds 
were obtained 
during the investigation. 
I believe that, yes, through the — I believe I remember 
seeing individual girls' cellphone numbers off 
cellphone record. 
Q. Okay. 
MR. PIKE: Form, move to strike. 
BY MR. KUVIN: 
Q. And did Ms.Mreturn, did she tell you 
that she returned to Mr. Epstein's home —
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. — a second time? 
A. Yes. I believe so. 
Q. The second time that she returned to the 
home, was she still a minor? In other words, how —
well, let me ask it this way: When she returned 
according to her to Mr. Epstein's home, how old was 
she? 
MR. PIKE: Form. 
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Page 185 
THE WITNESS: Well, she, when she went she 
was 15. 
BY MR. KUVIN: 
Q. Okay. The second time she went though, 
did she describe that it occurred, you know, a year 
later, weeks later, a month later? 
MR. PIKE: Form. 
THE WITNESS: I'm trying to recall. I 
don't believe it was hie a year later. It was 
more. lam trying to recall exactly. Could 
have been a week, two weeks, a month. I'm not 
100 percent certain but I know it wasn't a year 
later. 
BY MR. KUVIN: 
Q. All right. So, did you determine how old 
she was that second time she returned? 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. In other words was she still 15? Had she 
turned 16 by then? 
MR. PIKE: Form. 
THE WITNESS: I can't recall without 
looking at the report 
MR. KUVIN: Take a look if you would. 
MR. PIKE: And just so we're clear, while 
Page 186 
1 
he is looking, the other issue I have is that a 
2 
lot of these questions, for instance the first 
3 
time, the second time, the third time, it deals 
4 
with not onlyIII but in some of your 
5 
questions these deal with other third parties 
6 
and there is no predicate or foundation having 
7 
been laid relative to the dates these 
8 
individuals actually or allegedly came to the 
9 
home. 
10 
So, then the follow-up question of how did 
11 
you determine how old they are, ! don't believe 
12 
the proper predicate is there. So, that's 
13 
another basis. I mean, you asked, right? 
14 
MR. EDWARDS: Predicate is there to 
15 
detennine her age at the time; is that what you 
16 
are saying? 
17 
MR. PIKE: Yes, proper predicate had not 
18 
been laid. 
19 
BY MR. KUVIN: 
20 
Q. All right. With respect to the second 
21 
time she went to the home, let's talk about that: 
22 
Did you determine how old she was the second time 
23 
she came to the home? 
24 
A. It would have been several days later. 
25 
MR. PIKE: Form. 
(561) S32-7500 
PROSE COURT REPORTING 
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AGENCY, INC. 
Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
aa2a5cldb-fa81-4116.b3b7,dcda51494142 
EFTA00298308

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Page 189 
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BY MR. KUVIN: 
Q. And what occurred during this second time 
she was at the home —
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. —according to her? 
A. She returned to the home wittMand another 
massage was conducted. 
Q. All right. And did this massage involve 
Mr. Epstein again getting naked? 
A. Correct. 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. Did this massage, according to her, 
involve any touching by Mr. Epstein of ha? 
MR. PIKE: Form. 
THE WITNESS: Yes. 
BY MR. KUVIN: 
Q. Where did she tell you that Mr. Epstein 
touched her? 
MR. PIKE: Form. 
THE WITNESS: She informed me that her 
vagina was touched digitally while he was 
masturbating. 
1 
MR. PIKE: Form. 
2 
BY MR. KUVIN: 
3 
Q. What was her demeanor dining this 
4 
interview with you? 
5 
A. She was scared. She was nervous. Obviously 
6 
she was still crying. 
7 
Q. If we look at Page 21. You met with a 
8 
gentleman by the name of Alfredo Rodriguez --
9 
A. Yes. 
10 
Q. — who was the houseman? 
11 
A. Yes. 
12 
MR. PIKE: Form. 
13 
BY MR. KUVIN: 
14 
Q. Have you come to learn recently that he 
15 
was arrested by federal authorities? 
16 
A. Correct 
17 
Q. Did you also come to learn recently that 
18 
he has pled guilty? 
19 
A. I have not seat I heard it. It was in, I 
20 
guess, the news either last night or this morning. 
21 
Q. Do you know what he pled guilty to? 
22 
A. No. 
23 
Q. Are you aware that — well, when you met 
24 
with him, did he explain to you whether or not he 
25 
had any telephone books or telephone logs or any 
3 
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Page 188 
BY MR. KUVIN: 
Q. Okay. Did she describe during the second 
time whether or not Mr. Epstein climaxed? 
MR. PIKE: Form. 
THE WITNESS: Yes, she did. 
BY MR. KUVIN: 
Q. And did she recount for you whether or not 
Mr. Epstein made another threat to her at the 
conclusion of this massage? 
MR. PIKE: Form. Who are we talking 
about? 
MR. KUVIN: 
THE WITNESS: Yes. 
BY MR. KUVIN: 
Q. What did she tell you? 
MR. PIKE: Form. 
ME WITNESS: She said that she was not to 
speak of this to anyone; bad things could 
• haPPen. 
BY MR. KUVIN: 
• Q. When you talked to her, was she afraid, 
bless you, was she afraid that Mr. Epstein would do 
something to her or her family? 
A. Yes. She was afraid that someone would hurt 
either her or her family. 
Page 190 
1 
kind of information of girls that had come to the 
2 
home? 
3 
MR. PIKE: Form. 
4 
MR. KUVIN: Documents in other words. 
5 
THE WITNESS: When I spoke with him, he 
6 
had advised that he had a, originally he stated 
7 
journal. But what he provided me was a green 
8 
folder with different pieces of papers inside 
9 
the folder. 
10 
BY MR. KUVIN: 
11 
Q. Did he ever give you any kind of a journal 
12 
or binder of names? 
13 
A. No. 
14 
Q. Are you aware as you sit here today that, 
15 
in fact, he did possess such a journal of names? 
16 
A. Yes, I did. 
17 
MR. PIKE: Form. 
18 
BY MR. KUVIN: 
19 
Q. How did you team that? 
20 
MR. PIKE: Form. 
21 
THE WITNESS: I read it through the 
22 
newspapers. 
23 
BY MR. KUVIN: 
24 
Q. Did you ever see that journal? 
25 
A. No. 
16 (Pages 187 to 190) 
PROSE COURT REPORTING AGENCY, INC. 
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Page 193. 
Page 193 
1 
MR. PIKE: Form. 
2 
MR. KUVIN: Let me show you a stack of 
3 
message books that were apparently — well, let 
4 
me ask you about them. It's all of them. 
5 
(A discussion was held off the record.) 
6 
BY MR. KUVIN: 
7 
Q. Ni going to show you a stack first and 
8 
then what I'll do is I'm not going to mark the 
9 
entire stack, but I will pull out individual ones so 
10 
I'll ask you about them. Just take a look at the 
11 
stack of documents I am showing you. 
12 
Do you recognize what it is? And if you 
13 
do, then if you could just describe it for us. 
14 
A. These are copies of the, some of the phone 
15 
pads, of phone message pads taken from the home. 
16 
Q. Okay. Let me take it and I will just ask 
17 
you some individual questions. 
18 
MR. PIKE: One second. I want that entire 
19 
document marked as an exhibit And it's clear 
20 
that the witness just refreshed his 
21 
recollection based upon your past questioning 
22 
regarding trash pulls and documents that were 
23 
allegedly taken from the home. 
24 
So, I want that entire — he has looked at 
25 
it. Ifs in his possession. I want the entire 
Page 192 
1 
document, put a clip on it and have the court 
2 
reporter mark it. 
3 
MR. EDWARDS: Are you talking about the 
4 
Page I that he looked at? 
5 
MR. PUCE: He didn't just look at Page 1. 
6 
You should ask him that. He's flipping through 
7 
the documents. 
8 
MR. EDWARDS: Every single page? We had 
9 
this discussion in your client's deposition as 
10 
well. 
11 
MR. PIKE: Yeah, that was my 
12 
attorney-client work product for that witness. 
13 
So I just want the document marked. That's 
14 
all. 
15 
KUVIN: It's not going to be turned 
16 
over. It's my document. 
17 
MR. PIKE: The witness has just looked at 
18 
it. 
19 
MR. KUVIN: He looked at the first couple 
20 
pages, so I am not turning it over. I am 
21 
turning over the documents that I marked from 
22 
my stack of documents. 
23 
MR. PUCE: Thai I am going to move to 
24 
strike every question relative to the documents 
25 
that the witness looked at. The witness 
1 
2 
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has flipped through that document les not a 
big deal. You can mark it as an exhibit. It 
has none of your attorney notes on it, none of 
your work product on it. It's been in the 
witness's possession, and as a result, I am 
entitled to it pursuant to the law. 
MIL KUVIN: This is Mike Pike on the law. 
MR. PUCE: Well, then this is what I am 
going to instruct you to do, preserve that 
document in whole. 
MR. KUVIN: Sure. 
MR. PIKE: Mark it as an exhibit in whole, 
preserve it Okay. 
MR. KUVIN: Why don't you just do a 
request to produce the phone logs if you don't 
have these already? 
MR. PIKE: Why should I wait 30 days for 
something? I don't know exactly what's in 
there, Mr. Kuvin. There could be -- I could 
have all of that in full. I 'could be missing 
one document I don't know what it is that you 
have. So, if you just want to move forward, 
you can move forward and you can mark the 
document, or I am going to move to strike 
because you haven't marked it as an exhibit. 
Page 194 
MR. KUVIN: You do whatever you feel 
appapriate. 
BY MR. KUVIN: 
Q. Do you ver come to learn who a woman was 
by the name of 
A. No, I ' not 
Q. What about a Dr. Jarecki, J-a-r-e-c-k-i, 
did you ever learn who that was? 
A. No. 
Q. What about a Jane Doe, (Spells first 
name). 
A. No. Some people were not identified off those 
phone logs. 
Q. Okay. It appears that some of the phone 
logs are, the names of the individuals are whited 
out. Was that done at some point by the department? 
MR. PIKE: Form. 
THE WITNESS: No, nothing was ever whited 
out 
BY MR. KUVIN: 
Q. On the phone logs, no? 
A. No, not by me. 
Q. Okay. Did you ever come to learn who the 
gentleman by the name of Jean Luc was? 
A. Jean Luc had a modeling enc , I believe. 
17 (Pages 191 to 194) 
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Page 195 
Page 197 
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MC2. 
Q. Did you ever determine whether or not 
there was any connection between Mr. Epstein and 
that modeling agency of MC2? 
MR. PIKE: Form. 
THE WITNESS: I recall a phone message, 
duplicate phone message to Mr. Epstein from 
Jean Luc which said I have a girl for you and 
then it had two times eight. 
MR. KINN: Let me see if I can find that 
one. 
MR. PIKE: Form to that, the other 
question. 
MR. KUVIN: This one I will mark. 
MR. PIKE: Well, I just want it clear for 
the record that there is a difference between 
looking at a document and refreshing your 
recollection on a document. And it's clear 
under Florida Jur. 
So, what I would like you to do, 
Mr. ICuvin, before you categorize these 
documents, is I would like you to mark this 
document in full. You can keep it in your 
possession. All right And then we can talk 
about it later instead ot you know, marking 
1 
Q. Let me take a quick look. 
2 
A. 1 don't know if you saw this one. 
3 
Q. Let me take a quick look. All right. 
4 
Just so the record is clear, this message appears to 
5 
say: Ile has a teacher for you to teach you how to 
6 
speak Russian. She is two times eight years old. 
7 
Not blonde. Lessons are free, and you can have 
8 
first today if you call." Did I read that 
9 
correctly? 
10 
MR. PIKE: Form. 
11 
THE WITNESS: That is correct. 
12. 
BY MR. KUVIN: 
13 
Q. Okay.- Did you ever determine what that 
14 
meant? 
15 
MR. PIKE: Form. 
16 
THE WITNESS: I never spoke with Jean Luc 
17 
but it appears that two times eight is 16. 
18 
BY MR. KUVIN: 
19 
Q. Could it mean two 8-year-old girls? 
20 
MR. PIKE: Form, move to strike the 
21 
witness's testimony. 
• 
22 
. 
MR_ EDWARDS: He hasn't said anything yet 
23 
MR. PIKE: Two times eight equals 16. You 
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didn't hear him say that I don't thinlc you 
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did, and I move to strike it. 
Page 196 
1 
several different documents. 
2 
Maybe it would be easier if you just 
3 
marked it and we took it up with the cote 
4 
later. Otherwise you're going to, you're going 
5 
to kind of mess with the structure of the 
6 
document as the witness has utilized to refresh 
7 
his recollection. 
8 
MR. KUVIN: Okay. I appreciate your 
9 
objection. 
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(Plaintiffs Exhibit No. 6 was marked for 
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identification.) 
12. 
BY MR. KUVIN: 
13 
Q. Him going to give you what1marked as 
14 
Exhibit 6. Is that the message that you're 
15 
referring to? 
16 
A. Yes. 
17 
Q. And that message or that photocopy page 
18 
appears to have four messages in it; is that 
19 
correct? 
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MR. PIKE: Form. 
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 THE WITNESS: Correct. 
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BY MR. KUVIN: 
23 
Q. Where does the message you're referring to 
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appear on the document? 
25 
A. Top left. 
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Page 198 
Mr. Edwards, this is, if you, if you find 
something funny here, then maybe we can take a 
MR EDWARDS: You're striking things that 
were not said, funny. 
MR. PIKE: You didn't hear something said 
and it was said. I move to strike it. 
MR. EDWARDS: It was the previous 
' question. I get it. I'm with you. 
MR PIKE: Were going to take a break. 
Mr. Edwards needs a break, because there is, by 
no stretch of the imagination — lam not here 
all day to hear Mr. Edwards laugh over there in 
the corner trying to do a job. 
MR. KUVIN: To that extent I am not here 
to hear Mr. Epstein laugh about questions that 
I am asking either. But he is over here 
snickering, and I don't mention it every time 
he snickers at one of the sexual questions that 
I ask. 
MR. EDWARDS: I was laughing because I 
thought you were objecting to the witness's 
answer and he hadn't yet answered. I 
understand now. You're objecting to the 
vious answer then fine. 
18 (Pages 195 to 198) 
PROSE COURT REPORTING -AGENCY, INC. 
Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
aa2a6eldb.ta81-4H6-b3b7-dcda51494142 
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Page 199 
Page 201 
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MR. PIKE: Lets just take a break 
2 
MR. EDWARDS: I'm fine. 
3 
MR. PIKE: Let's take a break and everyone 
4 
can gather their senses and everyone can get 
5 
back to doing their job on each side of the 
6 
table: 
7 
(A brief recess was held.) 
8 
MR. KUVIN: Are you ready? 
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MR. PIKE: Let's go back on the record. 
3.0 
Mr. Kuvin, do you have any idea how much 
11 
longer? I am trying to get an idea as to 
12 
whether or not we want an opportunity to 
13. 
question the witness today. And there are 
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other lawyers. I know Mr. Edwards wants an 
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opportunity to go after you, Pm sure. 
. 
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I don't know if Ms. Finnigan is going to 
17 
be asking questions or Ms. Arbour. 
18 
So, I would like to get an idea as to how 
19 
much time you have and then Mr. Edwards and 
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Ms. Finnigan and Ms. Arbour. 
21 
MR. KUVIN: I'm almost done. I'm going to 
22. 
go through some of the messages and then I have 
23 
got some probation violation stuff I want to 
24 
talk about. So, once I am done with that, I 
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should be about done. 
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Page 200 
And then I don't know, we can talk about 
this, whether or not you-all can go before the 
rest Of the Plaintiffs go. I don't know their 
feelings on that, but we'll leave it up to 
them. 
MR. PIKE: We're fine with letting them 
go. 
MR. EDWARDS: I am going to try to make 
this easy for you. I think we talked earlier 
that the deposition has to end today at 5. And 
given those parameters, there is no way that I 
can get through my questions. We're going to 
need a second day for this deposition anyway. 
I am assuming that it's because 
lit Weinberg is down from Massachusetts today 
and he wants to ask questions. I don't care 
what order I go in. 
So, if you want to ask questions next, 
that's perfectly fine with me. It doesn't 
really matter. Whatever is easiest. I am 
amenable to whatever your suggestion is. That 
really is fine. 
MR. PIKE: hut for the record when you 
say you spoke to, when you said you spoke 
recarxiine the deposition ending at 5, just to 
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C 
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make the record clear you spoke to 
Ms. O'Connor, correct, at the beginning of 
today? 
MR. KUVIN: It was actually a discussion 
with Kathy Ezell as to whether or not they 
would get to her, and that's where the 
discussion went 
MR. PIKE: I just want to make sure that 
discussion wasn't with me, because I am here 
for as long as it takes to get everyone done. 
But it's clear that I guess Ms. O'Connor and 
the witness need to be done at 5. So, 5 is 5. 
MR. EDWARDS: Right And given that it's 
already pretty late, I know that we're not 
going to get it done, so that's why —
MR. PIKE: Understand. 
MR. EDWARDS: Do you want to ask 
questions, that's fine, whatever. 
MR. PIKE: Can I speak with my client for 
a minute? 
MR. EDWARDS: Let's take two minutes. 
MR. PIKE: Just while we're still on the 
record, Mr. Kuvin, you have agreed not 
necessarily today but with regard to the 
message pads, you have agreed to go ahead and 
Page 202 
1 
flip through them. I don't know —
2 
MR. KUVIN: I have agreed, you're going to 
3 
get a copy of them all. 
4 
MR. PIKE: I am going to get a copy of 
5 
them all? 
6 
MR. KUVIN: Yes. 
7 
MR. PIKE: Thank you. 
8 
(A discussion was held off the record.) 
9 
MR. PIKE: We are going to go back on the 
10 
record.
11 
MR. KUVIN: Okay. 
12 
MR. PIKE: We're going to just go ahead 
13 
and follow foam with regard to the Plaintiffs 
14 
finishing, and we'll come back later on. 
15 
MIL KUVIN: Okay. 
16 
MIL PIKE: That way you guys can keep that 
17 
order going. 
• 
' 
18 
MIL KUVIN: All light. Just keep the 
19 
phone stuff separate because I only have one 
20 
copy of that and I just want to make sure I 
21 
-don't lose it. 
22 
THE WITNESS: Okay. 
23 
MR. KUVIN: Lefinext Mark this one as 7. 
24 
That's the next one I am going to ask him 
about. 
?ROSE COURT REPORTING AGENCY, 
—4
19 Rages 199 to 202 
INC. 
•
 
Electronically signed by cynthia hopkins (601 
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