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Page 400 
1 
A. She got money for providing a massage while 
2 
Mr. Epstein touched her breasts and fondled her vagina 
3 
Q. Would you consider that this fans within the 
4 
broad ambit of prostitution? 
5 
MS. ARBOUR: Form 
6 
THE WETNESS: Prostitution would be for sex 
7 
for money. 
8 
BY MR. WEINBERG: 
9 
Q. So Ms. M. did not engage in prostitution, 
10 
but others did, during the course of the investigation? 
11 
MS. ARBOUR: Form 
12 
• 
THE WITNESS: I wouldn't say others did. Ifs 
13 
a negotiation. If you're paying for a sex act, 
14 
it's a negotiation. You get X for Y. 
15 
BY MR. WEINBERG: 
16 
Q. So that if the negotiation was purely for a 
17 
topless massage, then there was no prostitution? 
18 
MS. ARBOUR: Form. 
19 
THE WITNESS: Not in my eyes, no. 
20 
BY MR. WEINBERG: 
21 
Q. So in your eyes, were any of the so-called 
22 
victim/witnesses, did any of them engage in 
23 
prostitution? 
24 
MS. ARBOUR: Form. 
25 
THE WITNESS: Do you mean since that time, 
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Page 402 
BY MR. WEINBERG: 
Q. Correct? 
MS. ARBOUR: Same objection. 
THE WITNESS: The negotiation part, X for Y. 
BY MR. WEINBERG: 
Q. So absent the negotiation, there is no 
prostitution? 
MS. ARBOUR: Fonn. 
THE WITNESS: No. 
BY MR. WEINBERG: 
Q. And therefore, in your opinion, the women 
going to see Mr. Epstein were not going there pursuant 
to a prostitution agreement, correct? 
A. Coned. 
Q. They were going there as consenting adults or 
even consenting minors to do something other than 
prostitution? 
MS. ARBOUR: Form. 
THE WITNESS: They were going there to provide 
the manage but, you're right, it wasn't 
prostitution. 
BY MR. WEINBERG: 
Q. And in fact, had some of these girls that went 
there who were under 18, had they been over 18, then 
this entire case would have been a consenting massage 
Page 401 
or — 
2 
BY MR. WEINBERG: 
3 
Q. Well, let's start with that time, when 
4 
Mr. Epstein was the customer. Were any of the women 
5 
going to his house engaging in prostitution, in your 
6 
opinion? 
7 
MS. ARBOUR: Form 
8 
THE WITNESS: In my opinion? 
BY MR. WEINBERG: 
Q. Yes. 
A. No. 
Q. And that included those who were going to his 
house who were above 18 as well as below 18, correct? 
MS. ARBOUR: Form. 
THE WITNESS: Like I was told, people that I 
interviewed that were above 18, what happened 
between them were between two consenting adults. 
BY MR. WEINBIRO: 
Q. And so to your mind, it's not the giving of 
money, it's the negotiated agreement that constitutes 
the essential element that distinguishes prostitution 
from simply a consensual act as long as the people who 
engaged in it were both over 18? 
MS. ARBOUR: Form. 
1 
2 
3 
4 
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10 
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Page 403 
case, correct? 
MS. ARBOUR: Form. 
MS. FINNIGAN: Form. 
THE WITNESS: If they axle over 18? 
BY MR. WEINBERG: 
Q. Yes. 
A. That it would have just been what, a massage 
ease, you mid? 
Q. It would have been a case between two 
consenting adults, other than prostitution. 
MS. ARBOUR: Form. 
THE WITNESS: Unless we got a complaint. 
BY MR. WEINBERG 
Which you didn't get in this case, other than 
the 
parent Mmeh '05 complaint as a result of 
overhearing a discussion? 
MS. FINNIGAN: Form. 
THE WITNESS: Right. 
BY MR. WEINBERG: 
Q. Ms... certainly, although emotional during 
her interview, never said that anybody forced her to 
return to Mr. Epstein's house on the second occasion 
when she gave a second massage, correct? 
A. Coned. 
Q. And she never said anybody forced her to bring 
22 (Pages 400 to 403) 
.( 561) 832-750.0 
• PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricclull (601 
Electronically signed by Jeana Ricciutf (601 
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Page 404 
a friend over fora third visit, correct? 
A. Correct. .
Q. And at most, your evidence reflected that 
there were many young women that, in fact, called 
Mr. Epstein's house seeking to come over to give him 
massages, correct? 
1 
2 
3 
4 
5 
. 6 
7 
A. Yes, there were messages from various people 
7 
8 
that called. 
8 
9 
Q. And that when someone in Mr. Epstein's 
9 
10 
residence called out to any of these young people, it 
10 
11 
was, at most, to schedule a visit, correct? 
• 
11 
12. 
MS. ARBOUR: Form. 
12 
13 
THE WITNESS: Correct. 
13 
14 
BY MR. WEINBERG: 
14 
15 
S 
None of these girls complained that MI 
15 
16 
or anyone else threatened them to come over? 
16 
17 
A. No, there was no threats to come over, no. 
17 
18 
Q. No coercion to come over? 
• 
18 
19 
MS. ARBOUR: Form. 
19 
20 
MS. FINNIGAN: Form. 
20 
21 
BY MR. WEINBERG: 
21 
22 
Q. Is that correct? 
22 
23 
A. Not thatim aware of. 
23 
24 
Q. None of the As ever told you that their 
24 
25 
calls with 
were anything more than an 
25 
Page 405 
1 
visitation to come over? 
1 
2 
MS. ARBOUR: Form. 
2 
3 
BY MR. WEINBERG: 
3 
4 
Q. A scheduling call? 
4 
5 
MS. ARBOUR: Same objection. 
5 
6 
BY MR. WEINBERG: 
6 
7 
Q. Correct? 
7 
8 
A. As far as l know, yes. 
8 
9 
Q. And the same with anyone else in Mr. Epstein's 
9 
10 
household, no one ever said they got a phone call from 
10 
11 
anyone who lived at El Brillo doing anything roore than 
11 
12 
seeing if they wanted to schedule a visit, correct? 
12 
13 
MS. ARBOUR: Form. 
13 
14 
THE WITNESS: I believe so. 
14 
15 
BY MR. WEINBERG: 
15 
16 
Q. No one ever said they negotiated amounts of 
16 
17 
money on the phone; is that correct? 
17 
18 
A. Not that I recall, no. 
18 
19 
Q. No one ever said that they were required to . 
19 
20 
make promises of sexual performance on the phone as a .20 
21 
condition of being invited to come over? 
21 
22 
MS. ARBOUR: Form.
• 
22. 
23 
. 
THE WITNESS: No, I don't believe so. 
23 
24 
' 
BY MR. WEINBERG: 
24 
25 
so thophone part of it was simply a 
25 
Page 406 
scheduling communication, to the best of your knowledge, 
based on all of your many conversations with your many 
witnesses? 
MS. ARBOUR: Form. 
THE WITNESS: Right 
BY MR. WEINBERG:. 
Q. And once they are at his house, none of the 
girls claimed that he violently forced them to do 
anything they didn't want; is that correct? 
MS. ARBOUR Form. 
MS. FINNIGAN: Form. 
THE WITNESS: There was an instance where 
that was a vaginal penetration. 
BY MR. WEINBERG: 
Q. And you recall, as soon as the person 
protested, Mr. Epstein apologized and stopped that act; 
is that right? 
MS. ARBOUR: Form. 
THE WITNESS: I believe so, yes. 
BY MR. WEINBERG: 
Q. And that was Ms. Jane Doe 103? 
A. Yes. 
Q. And she was — turned 18 in December of 2004, 
correct? 
MS. FINNIGAN: Form. 
Page 407 
THE WITNESS: I'm not sure of the time frame 
where she turned la. 
BY MR. WEINBERG: 
Q. Let me see if I can find this for you. At the 
bottom of page 10 of that affidavit, on September I1, 
2005, WFAH, DOB, 12/30/1986 was arrested by the Palm 
Beach Police Department That's the same Jane Doe 103 
that we're talking about, correct? It's the very last 
line. I'm only pointing out the date of birth. 
A. Yes. 
Q. So she was 18 as of 
correct? 
• 
A. What page was that, I'm sorry? 
Q. This is the bottom of page 10. 
A. She would have been 18, yes, in 2004. 
Q. And she didn't • 
you a date on this one. 
• 
A. 
Q. 2004. And when you interviewed Ms. Jane Doe 
103 on October 10th and October 11th, and she told you 
about this one event where there was momentary 
penetration, she protested, Mr. Epstein immediately 
apologized and ended that sex act, that she didn't give 
you a date that that occurred, did she? 
A. I can't recall if she did or she didn't. 
Q. If she gave you a date, it would be in the 
(561) 832-7500 
PROSE COURT. REPORTING .AGENCY
INC. 
23 (Pages 404 to 407) 
: 
..(561) 832-75OS. 
Electronically signed by Jeanie Ricciutl (601 
Electronically signed by Jeans Ricciutl (601 
a0828374ball-4112o-e8364:614.3
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• • 
EFTA00298235

Page 408 
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report -
2 
A. Yes, sir. 
3 
Q. -- and if she didn't, either the didn't 
4 
remember or she wasn't asked; is that right? 
5 
MS. ARBOUR: Form. 
6 
THE WITNESS: No, I know that I would have 
7 
asked ha.. 
8 
BY MR. WEINBERG: 
9 
Q. So if we don't have a date in the report as to 
10 
how long before October 10 and 11, 2005 that single 
11 
event occurred, then she didn't remember; is that right? 
12 
MS. ARBOUR: Form. 
13 
THE WITNESS: Can you ask that question one 
14 
more time? 
15 
BY MR. WEINBERG: 
16 
Q. Sure If there's no date for that — 
17 
A. Then she did not recall that specific date. 
18 
Q. And therefore, since she was seeing 
19 
Mr. Epstein, according to what she told you, over some 
. 
20 
extensive period of tiro it could have occurred while 
21 
she was — before 
or it could have 
22 
occurred after 
we just have no way of 
23 
knowing? 
24 
A. It would have been before because one of the 
25 
last times that she met with him was when she provided 
Page 410 
1 
about five or six-month period after she turned 18 on 
2 
3 
A. I'm trying to recall, because I do remember 
4 
her stating that she was going less and less. I'm 
5 
trying to recall, because I know she was going less and 
6 
less to his residence. 
7 
Q. Do you recall writing in this probable cause 
8 
affidavit that events that Jane Doe 103 advised you 
9 . 
that her relationship continued to escalate during the 
10 . 
period she saw Mr. Epstein? 
11 
A. From the beginning, yes. 
12 
Q. Yes, and we can — and this event where she 
13 
said no and Epstein stopped, was an escalation of their 
14 
contact in an earlier appearance, correct? 
A. I'm trying to recall. She had gone to his 
16 
house — she had been going to his house for several 
17 
years, and I think that was the escalation, what you . 
18 
meant. 
19 
Q. And it's fair to say that some subset of those • 
20 
couple of years occurred after she turned IS, and a 
21 
significant part of it was before she turned 18, 
22 
coned? 
23 
A. The significant part, I would say --
24 
Q. If there was two years and she graduated high 
25 
school in the spring of 2005, then she saw him — part 
Page 409 
1 
her high school transcript because he was going to 
2 
assist her in getting her into a college. 
3 
Q. And when was that; a high school transcript? 
4 
The high school year ends in the spring? 
5 
A. It would have been, yes. 
6 
Q. And not in December? 
7 
A. Cornet 
8 
Q. And so if she turned 18 in December, that 
9 
would have been in the middle of her senior year in high 
10 
school? 
11 
A. Correct 
12 
Q. And therefore, she continued to see 
13 
Mr. Epstein after she was 18 and up to the period 
14 
immediately before her graduation in the spring of 2005, 
15 
cornea? 
16 
Let me date it another way. She was a 
• 
17 
freshman at college when you went to see her in October 
18 
of 2005? 
19 
A. Correct. 
' • 
20 
• 
. Q. Therefore, she was a senior in high school up • • 
21 
through the spring of 2005? 
22 
A. Correct. 
23 
Q. And therefore, since she gave Mr. Epstein her 
24 
transcript, shortly before or at the time of her.
25 
graduation, she was still seeing Mr. Epstein for this 
Page 411 
1 
of it when she was 18, after she tamed 18 on 
2 
and part of it was before she walla, 
3 
correct? 
4 
A. I would assume so. 
5 
Q. And she didn't give you a date when the single 
6 
act, where she said no and Mr. Epstein stopped occurred, 
7. 
it's not in your report and you don't have an 
8 
independent memory, correct? 
9 
A. Correct.
' 
1.0 
Q. How many times have you personally interviewed 
11 
Ms. Jane Doe 103? 
12 
A. !vane to say two. 
13 
Q. October in Tallahassee and then again in the 
14 
March period in Tallahassee again? 
15 
A. One was in Jacksonville, one was in 
16 ' 
Tallahassee. 
1.7 
Q. And you have not personally seen her or 
18 
interviewed her since 2006? 
19 
A. I delivered a grand jury subpoena. 
.20 
Q. To her in April 2006? 
21 • 
A, I believe so. 
22 
Q. And have you ever seen her since then? 
23 
_. , 
A. • No. 
24 
Q. Have you ever spoken to her since the grand 
25 
jury returned an indictment against Mr. Epstein?
.(561).832-7;500 
PROSE COURT 
Electronically signed by Jeana Ricclutl (601 
Electronically signed by Jeans 'Melon (601 
24 (Pages 408 to 411) 
REPORTING AGENCY,...INC. 
..(561). 832-7506. 
e15062687-abe1-452c-a834143c8140314d7a 
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Page 412 
1 
A. I don't believe so. 
2 
Q. Have you had any e-mails or text messages or 
3 
any communication with Ms. Jane Doe 103 in the last 
4 
three and a half years? 
. 
5 
A. No. 
6 
Q. So with Ms. M., just so I'm clear, there was 
7 
no intercourse between her and Mr. Epstein, correct? 
8 
A. I don't believe so. 
9 
Q. No oral sex that she complained of to you? 
10 
A. No. 
11 
Q. No forced sex she complained of to you? 
12 
A. • No. 
13 
Q. She never said that she had seen Mr. Epstein 
14 
anywhere outside of his residence, correct? 
15 
A. What do you mean? 
16 
Q. She never claimed that Mr. Epstein took her on 
17 
his airplane awhere? 
18 
A. Ms. IS? 
19 
Q. Yes. 
20 
A. Not that I'm aware of. 
21 
Q. And she never claimed that Mr. Epstein took 
22 
her on any trips outside of his private residence, 
23 
correct? 
24 
A. Not that I'm aware of. 
25 
Q. So the three or four times she and Mr. Epstein 
Page 414 
1 
Q. In other words, Mr. Epstein in now way 
2 
generated personal profits from any of his massages or 
3. 
contacts with any of the witnesses that were involved in 
4 
your case, correct? 
5 
MS. ARBOUR; Form. 
6 
• THE WITNESS: Not that Fm aware of. 
7 
BY MR. WEINBERG: 
8 
Q. You have no evidence that M. ever gave 
9 
Mr. Epstein money or that ■ 
ever gave Mr. Epstein 
10 
money as part of his share of these incidents, correct? 
11 
MS. ARBOUR: Form. 
12 
THE WITNESS: Not that I'm aware of. 
13 
BY MR. WEINBERG: 
14 
Q. M. told you that she had met Mr. Epstein 
15 
about a year before pa 
2005 interview; do 
16 
you remember that? 
17 
A. Uh-huh. 
18 
Q. And her birth dater 
on 
19 
page 15 of your affidavit, 
20 
A. Yes, sit 
21 
' Q. So therefore, she was 18 in 
of 200s, 
22 
correct? 
23 
A. Yes. 
24 
Q. So there 
she was 18 when you interviewed 
25 
her on 
2005; is that right? 
Page 413 
/ 
were physically in the same location, according to her, 
2 
occurred exclusively on El Drilla; is that right? 
3 
A. Yes. 
4 
Q. Let me switch to another person
5 
interviewed, M.  Do you remember 
6 
A. Yes. 
7 
And do you remember interviewing her in 
8 
of 2005? 
9 
A. That would have been around that time. 
10 
Q. By the way, just let me step back one second. 
11 
When Ms... brought another girl to Mr. Epstein's 
12 
home, she told you she, Ms. 
was paid for that; is 
13 
that right? She was paid — 
14 
A. Yes. 
15 
Q. You have no evidence in this case that any of 
16 
the girls who gave Mr. Epstein massages ever paid money 
17 
to Mr. Epstein? 
18 
A. What do you mean? 
19 
Q. There is no money flowing back to Mr. Epstein, 
20 
or to any of the people employed by Mr. Epstein, from 
21. 
any of the young women that gave him massages at his 
• 
22 
house, correct? 
23 
A. That money went back to Mr. Epstein? 
24 
Q. Yes. 
25 
A. Not that fm aware of. 
Page 415 
1 
• • A. Yes. 
2 
Q. And if she met Mr. Epstein one year before 
3 
your interview, then she met him when she was 17? 
4 
A. Or depending on the date when she met him, she 
5 
could have been on the edge of 16, beginning of 17. 
6 
Q. And do you recall who introduced her to 
7 
Mr. Epstein? 
8 
A. 1 believe it was 
9 
Q. And if your report reflects 
10 
lime Doe 103? 
11 
A. Yes. 
12 
Q. And she, like the others, was introduced to 
13 
Mr. Epstein by a third party, one of their friends; is 
14 
that right? 
15 
MS. ARBOUR: Form. 
16 . 
• 
THE WITNESS: rm sorry? 
17. 
BY MR. WEINBERG: 
18 
Q. Like others, she, 
M. was introduced to 
19 
Mr. 
ein by another young girl that was friends with 
20.. 
Ms. M., correct? 
21 
A. Yes. 
22 . 
Q. And that, in this case, was Ms. Jane Doe 103, 
23 
correct? 
24 
A. Yes. 
25. 
Q. And Ms. Jane Doe 103 took her to Mr. Epstein's 
, maybe. 
would that be 
25 (Pages 
412 to 415) 
PROSE COURT REPORTING AGENCY,".INC.. : 
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Electronically signed by Jeana Rlcciuti (601 
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Page 416 
house, correct? 
A. Yes. 
Q. And does your report affidavit reflect 
a
 
had heard that several girls were making money by 
providing massages to Epstein and she agreed and was 
taken to the house by Ms. Jane Doe 103? 
A. Yes. 
Q. So Ms. Jane Doe 103, like Ms. 
would tell 
1 
2 
3 
4 
5 
6 
7 
8 
Page 418 
THE WITNESS: What do you mean "profited"? 
BYMR. WEINBERG: 
Q. He didn't make any money by seeing., 
correct? 
MS. ARBOUR: Same objection. 
THE WITNESS: Not that Tin aware of. 
BY MR. WEINBERG: 
Q. He, at most, paid for the massages he 
9 
people, you know, that if they went to see Mr. Epstein, 
9 
received, correct? 
10 
they were expected to give him a massage, correct? 
10 
MS. ARBOUR. Form. 
11 
MS. ARBOUR Form. 
11 
BY MR. WEINBERG: 
12 
THE WITNESS: Possibly, yes. 
12 
Q. That's what Ms... represented to you? 
13 
BY MR. WEINBERG: 
13 
A. Yes. 
14 
Q. And in this case, at least, Ms. a. 
went 
14 
Q. And on one occasion, she said when she was 17, 
15 
there with her eyes open? In other words, she 
15 
she consensually agreed to engage in sex with 
16 
volunteered to go there and try to make money by giving 16 
Mr. Epstein, correct? 
17 
Mr. Epstein a massage just like she understood several 
17 
A. Yes. 
18 
other girls in her community had done? 
18 
Q. Nobody threatened her, right? 
19 
A. Correct. 
19 
A. Not that I'm aware of. 
20 
MS. ARBOUR: Form. 
20 
Q. She seemed like a relatively mature 
21 
BYMR. WEINBERG: 
21 
18-year-old when you spoke to her? 
22 
Q. And Ms. 
like others, never complained to 
22 
A. Yes. 
23 
you, she never wont to you herself before you went to 
23 
Q. And this occurred just shortly before her 
24 
her; is that right? 
24 
interview with you, correct? 
25 
A. Correct. 
25 
A. What do you mean "shortly before"? 
Page 417 
Page 419 
1 
Q. And she didn't initiate any complaints through 
1 
Q. Meaning that her recollection that on one 
2 
any parent, teacher, medical professional, law 
2' 
occasion she had had sex with Mr. Epstein, consensual 
3 
enforcement officer or anybody else to your knowledge? 
3 
sex occurred shortly before she was interviewed by you 
.4 
A. Not to my knowledge. 
4 
in 
of 2005, correct? . 
5 
Q. And be went directly to her because she was 
S 
A. Right. 
6 
18 in 
correct? 
6 
Q. She, too, introduced others to Mr. Epstein. 
7 
A. Correct 
7 
did she not? . 
8 
Q. And she told you that she, in fact, during the 
8.
A. Yes, I believe so. 
9 
first time, wearing thong panties, gave Mr. Epstein a 
Q. And do you ranentber interviewing her — within 
10 
massage, coual? 
10 
a week of your interview with Ms. a., you interviewed 
11 
A. Yes. 
11 
someone with the initials.? We can find this on 
12 
Q. And that she received money for that, correct? 
12 
page 16? 
13 
A. Yes. 
13 
A. Yes. 
14 
Q. And there was no prior arrangement of money 
14 
Q. At the bottom of page 16 of the affidavit, 
15 
for sex, so this, too, was not prostitution, correct? 
15 
Detective Samut (phonetic) and you on November 15th, met 
16 
A. Correct. 
16 
and during the sworn statement said she had met 
17 
Q. And she returned 15 times to Mr. Epstein's 
17 
Mr. Epstein a year 
. And she was — her date of 
18 
residence, correct? 
18 
birth on this report i 
Do you see that 
19 
A. A total of, yes, that's what she recalled. 
19 
four lines up on the bottom of
 16? 
20 
Q. On at least one of the occasions, she was with 
20 
A. It would have been M. 
Is that the one 
21 
Ms. Jane Doe 103 who was also was paid $200, correct? 
21 
you're talking about?
22 
A. Correa. 
22 
Q. This is on the bottom of page 16, 
23 
Q. And Mr. Epstein, in no way financially 
23 
. "November 15th, Detective Samut and I met with a. 
24 
profited from his relationship with 
correct? 
24 
A. You're on — yeah. 
25 
MS. ARBOUR: Form. 
25 
Q. I'm probably on a different-page than you. Do 
(561) 832-7500. 
26 (Pages 
416 to 419) 
PROSE COURT-REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciull (601 
Electronically signed by Jeana Ricciutl (601 
c6062637-abe1-452c-a836-bc614e314d7a 
EFTA00298238

Page 420 
1 
you see the four lines from the bottom, short paragraph? 
2 
A. Yeah, right. 
3 
Q. "f, date of birth, n 
4 
Correct? 
5 
A. Right. 
6 
Q. So she said she met Mr. Epstein though 
• 
7 
correct? 
8 
A. I believe so. 
9 
Q. And Ms.. was accurate with her in saying 
10 
to her that she could make 5200 giving Mr. Epstein a 
11 
massage? 
12 
A. Yes. 
13 
Q. And Ms... said the massage would have to be 
14 
topless, correct? 
15 
A. I believe so, yes. 
16 
Q. And.. returned several times to 
17 
Mr. Epstein's horn; voluntarily, correct? 
18 
A. I believe so. 
19 
Q. Meaning, she agreed to go with Ms.. the 
20 
first time and meet Mr. Epstein and give him what she 
21 
knew would be a topless massage? 
22 
A. I don't know if the word "topless" came in, 
23 
but I know it was a massage. 
24 
Q. Take a look at the second — top of the 
25 
sentence of the next page. Ifs at the very top, the 
1 
2 
3 
4 
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6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
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Page 422 
BY MR. WEINBERG: 
Q. Well, it could even be M.? 
A. It could have been the person who actually 
brought than. 
Q. And that any massage that occurred always 
occurred on the second floor of Mr. Epstein's El Brillo 
residence, correct? 
MS. ARBOUR: Earn. 
TILE WITNESS: I believe so. 
BY MR. WEINBERG: 
Q. By *always,' I mean of all of the witnesses 
that were interviewed by them, they told you that they 
went upstairs with someone and entered a room where 
there was a massage table when Mr. Epstein came into the 
room, correct? 
MS. ARBOUR: Form. 
THE WITNESS: Correct. 
BY MR. WEINBERG: 
Q. Now, in 2003 you conducted a very different 
kind of criminal investigation that related to the same 
residence at El Brillo on Palm Beach, correct? 
A. Arc you talking about the burglary case? 
Q. Yes. 
A. That wasn't my case, but I assisted. 
Page 421 
1 
top two words. 
2 
A. "Massage topless," okay. 
3 
Q. And again, she was, like WI of the other 
4 
girls had no prior communication with Mr. Epstein, 
5 
Ms. 
or anyone at the El Brillo home before she 
6 
arrived there physically the first time, correct? 
7 
A. Correct. 
8 
Q. And there were no negotiations that you knew 
9 
of, you know, where prices were discussed, correct? 
10 
MS. ARBOUR: Form. 
11 
THE WITNESS: Not that I'm aware ot yes. 
12 
BY MR. WEINBERG: 
13 
Q. And what these girls repeatedly told you is 
14 
that they went to Mr. Epstein's home, invited by one of 
15 
their friends? 
16 
MS. ARBOUR: Form. 
17 
THE WITNESS: They were invited by one of 
18 
their friends or associates. 
19 
BY MR. WEINBERG: 
20. 
Q. Came into the first floor and were taken by 
21 
somebody up to the second floor, correct? 
22 
A. Correct 
23 
Q. And that somebody was usually-? 
24 
MS. ARBOUR: Form. 
25. 
THE. WITNESS: 
or, on occasion, it was a 
Page 423 
1 
Q. You were a participant in the investigation 
2 
burglary when Mr. Epstein was the victim, correct? 
3 
A. Correct. 
4 
Q. As part of your assistance, you brought 
5 
certain cameras into Mr. Epstein's home; is that 
6 
correct? 
7 
A- Correct 
8 
Q. And do you recall that Mr. Epstein shared with 
9 
you that he, himself, attempting to identify who was 
10 
stealing money from him, had gone out and for the 
11 
purpose of making that identification, had purchased 
12 
certain cameras himself? 
13 
A. I believe so, yes. 
14 
Q. And that he installed them so that the camera 
15 
was poking out of a camera on the first floor of his 
16 
residence, directed towards his desk area where he left 
17 
a bag that commonly had United States currency, correct? 
18 
A. I wasn't sure if it was the bag or the drawer, 
19 
but it was focused on the desk area. 
20 
Q. Camera, first floor directed to the desk area? 
21 
A. Yes. It was a bookshelf behind. It was like 
22 
an L bookshelf. 
23 
Q. And that you came in and supplemented those 
24 
cameras to try to help Mr. Epstein identify this thief, 
25 
correct? 
PROSE COURT REPORTING AGENCY, 
27 (Pages 420 to 423) 
INC. 
Electronically signed by Jeana Medal (601.280.428-9381) 
Electronically signed by Jeans RIccluti (601-280428.9381) 
O5062637-abel-452c-a8364x614e314d7a 
EFTA00298239

Page 424 
1 
A. Correct. 
2 
Q. And you, thereafter, took out your cameras 
3 
when the thief was identified by Mr. Epstein, correct? 
4 
A. Correct. 
5 
Q. And the thief was identified through 
6 
photographs of this desk area on the first floor of 
7 
Mr. Epstein's residence, correct? 
8 
A. I believe so, yes. 
9 
Q. And you never saw a camera in the massage room 
10 
on the second floor of Mr. Epstein's residence during 
11 
this 2003 period, correct? 
12 
A. I never went upstairs. 
13 
Q. None of the girls said that the massages was a 
14 
videoed or a photographed event, did they? 
15 
A. One of the girls recalled having their 
16 
photograph taken while in a tub. 
17 
But no, I never went upstairs during that 
18 
investigation, so I don't know if there was any covert 
19 
cameras up there, so... 
20 
Q. You don't know that there was one, correct? 
21 
A. Correct 
22 
Q. And the only covert camera you knew of was the 
23 
one that Mr. Epstein disclosed to you, correct? 
24 
A. Correct 
25 
Q. And he disclosed it to you in saying he 
Pogo 426 
1 
A. I know that was some of their concerns, but I 
2 
don't believe anyone specifically came out and said, "I 
3 
was videotaped". 
4 
Q. Right. Nobody told you that the massage was 
5 
videoed, to their knowledge? 
6 
A. To their knowledge, no. 
7 
Q. And nobody told you that they had seen a 
8 
camera in the massage room on the second floor of 
9 
Mr. Epstein's residence. 
10 
A. I don't recall, because like I said, I know 
11. 
that was one of the concerns. 
12 
Q. I want to separate out a concern from what 
13 
they told you they saw. No one ever told you they saw a 
14 
camera on the second floor of Mr. Epstein's residence? 
15 
A. I don't recall. I don't recall someone saying 
16 
that they saw a camera. I know that there was concerns 
17 
that the incident was videotaped. 
18 
Q. And they expressed to you that was just a 
19 
speculative subjective concern, but that they did not 
20 
see a camera videotaping any massage; is that correct? 
21 
MS. ARBOUR: Fonn. 
22 
THE WITNESS: Not that I can recall. 
23 
BY MR. WEINBERG: 
24 
Q. You interviewed roughly 30 different women 
25 
that had been to Mr. Epstein's home, correct? 
Page 425 
• 1 
purchased it, correct? 
. 2 
A. Yes. 
3 
Q. And he purchased it from a spy store, a store 
4 
that sold such covert cameras, correct? 
5 
A. Yes. 
6 
Q. And he told you, you as a law enforcement 
7 
officer, that he had done so for a specific purpose, 
8 
correct? 
9 
A. It was for that case, yes. 
10 
Q. Right. To identify someone who was 
11 
responsible for the theft of currency from the desk area 
12 
on the first floor? 
13 
A. I believe it was currency and a gun, if Fm 
14 
not mistaken. 
15 
Q. And he neva told you he had ever, on any 
16 
other occasion, purchased a covert camera, correct? 
17 
A. Not that I'm aware og no. 
18 
Q. And with the exception of this one girl who 
19 
said she was photographed in a tub, no other girl told 
20 
you that they were photographed, correct? 
21 
A. I don't believe so. 
22 
Q. No girl told you that they were videoed, 
23 
correct? And by "no girl," I mean none of the girls 
24 
that you interviewed in connection to your 2005 
25 
investigation of Mr. Epstein. 
Page 427 
1 
A. Yes. 
2 
Q. Some over 18 and some under 18, correct? 
3 
A. Yes. 
4 
Q Some over 18 when you interviewed than, some 
5 
said that they had been there when they were under 18, 
6 
correct? 
7 
MS. ARBOUR: Form. 
8 
THE WITNESS: Correct. 
9 
13Y MR. WEINBERG: 
10 
Q. And not a single one of those 30 people told 
11 
you that they saw a camera on the second floor of 
12 
Mr. Epstein's residence, correct? 
13 
MS. ARBOUR Form, asked and answered. 
14 
THE WITNESS: I can't recall if anybody 
15 
specifically crime out and said that they saw a 
16 
camera or not 
17 
BY MR. WEINBERG: 
18 
Q. Nobody, to your current recollection, told you 
19 
that they saw videotaping of any massage that occurred 
20 
in Mr. Epstein's residence or any sexual contact that 
21 
occurred in Mr. Epstein's residence, cored? 
22 
MS. ARBOUR: Form. . 
23 
THE WITNESS: Not that I can recall. 
24 
BY MR. WEINBERG: 
25 
Q. And nobody said that they had ever seen a 
28 (Pages 
424 to 427) 
' 
PROSE COURT REPORTING AGENCY 
INC.. 
(561) 832-7506 
' 
Bectronlcally signed by Jeans RIcclutl (601 
. 
Electronically signed by Jeans RIcclud (601 
c6062637-abel-452c-a836-bc614e31467a 
EFTA00298240

Page 428 
1 
photograph of themselves in Mr. Epstein's residence with 
2 
one exception, that being Jane Doe 103, who claimed that 
3 
a photo was taken of ha in a tub, correct? 
4 
A. I believe it was just Jane Doe 103. 
5 
Q. Right. Not any of the other 29 or so 
6 
witnesses that you interviewed, correct? 
7 
MS. ARBOUR: Form. 
8 
THE WITNESS: Right. 
9 
BY MR. WEINBERG: 
10 
Q. And when you enteral Mr. Epstein's home, 
11 
pursuant to judicial authorization on October 20th, you 
12 
were looking for photographs, were you not? 
13 
A. Yes. 
14 
Q. And you did not fmd the photo of Ms. Jane Doe 
15 
103 that she said was taken of her in a tub, correct? 
16 
A. Carat. 
17 
Q. And Ms. Jane Doe 103 didn't tell you how many 
18 
months before October 10 and 11, 2005, the dates of your 
19 
interview with her, that photo was taken, correct? 
20 
A. She did not give a specific date, no. 
21 
. So once a in remembering back, she turned 18 
22 
on 
The photo could have been taken 
23 
after she was 18, before she was 18, correct? 
24 
A. It could have been either one. 
25 
Q. And she never claimed that Mr. Epstein was in 
1 
MS. ARBOUR: Form. 
2 
THE WITNESS: Yeah Yes. 
3 
BY MR. WEINBERG: 
4 
Q. Jennifer Doe 4, do you recall her? 
5 
A. Do you mean Jane Doe 4? 
6 
Q. I'm sorry, Jane Doe 4. 
A. Yes. 
8 
Q. Do you recall interviewing her in or around 
9 
October 6, 2005? 
10 
A. Yes. 
11 
Q. And do you recall reciting to a judge in a 
12 
probable cause affidavit certain statements that 
13 
Ms. Jane Doe 4 made to you? 
14 
A. 'recall! put in — I put in a lot of 
15 
information that had been gathered during the 
16 
investigation for the search warrant. 
17 
Q. And is it fair to say that — and I want to 
18 
focus you on the probable cause affidavit rather than 
19 
the search warrant affidavit, because that's the one 
20 
that's in evidence as Exhibit 1, that you said 
21 
therein — it's on page 9 if you want to work through 
22 
Ms. Jane Doe 4 with me — that you interviewed her on 
23 
October 6, 2005? That's the bottom paragraph. 
24 
A. Yes. 
25 
Q. And that her date of birth was 
Page 429 
1 
the tub with ha, did she? 
2 
A. No. I believe 
was with her. 
3 
Q. At the time of the photo? 
4 
A. Yes. 
5 
Q. You're certain she said that? 
6 
A. I believe so. 
7 
Q. Is there any reason that you didn't say that 
8 
in your report? 
9 
MS. ARBOUR; Form. 
10 
THE WITNESS: Again, I'm going off 
11. 
recollection. 
12 
BY MR. WEINBERG: 
13 
• Q. Okay. 
14 
A. I believe that's what she said tome. 
15 
Q. And I'll go back. Is them any reason —1 
16 
represent to you that's not in your 87-page incident 
17 
report Is there any reason you would have omitted such 
18 
a description of the type of photo that Ms. Jane Doe 103 
19 
was claiming to you was taken of her in the tub? 
20 
A. No, I would have not omitted anything from the 
21 
report. 
22 
Q. So, therefore, that would have been the kind 
23 
of detail that you would have included in the report if, 
24 • 
in fact, you recalled it happening at or around the time 
25 
you wrote the report, correct? 
Page 431 
1 
is that correct? 
2 
A. Yes. 
3 
Q. So at the time you interviewed her, she was 
4 
over 18, correct? 
S 
MS. ARBOUR: Fonn. 
6 
THE WITNESS: I believe so, yes. 
7 
BY MR. WEINBERG: 
8 
Q. And you interviewed her at 
University? 
9 
A. Yes. 
10 
• Q. And you explained to her why you were there, 
11 
cared? 
12 
A. Yes. 
13 
Q. Which is, that you were conducting a criminal 
14 
investigation of Jeffrey Epstein? 
15 
A. That is correct. 
16 
Q. And that's a practice you used when you were 
17 
introducing yourself to either the adult witnesses who 
18 
had turned 18 or the parents of the minor witnesses, 
19 
correct? • 
20 
MS. ARBOUR: Form. 
• 
21 
THE WITNESS. Correct. 
22 
BY MR. WEINBERG: 
23 
Q. And Ms. Jane Doe 4 told you that she was aware 
24 
of the ongoing investigation; is that correct? 
25 
A. Yes. 
• 
29 (Pages 428 Lo 43].}
PROSE COURT REPORTING. AGENCY, INC. 
Electronically signed by Jeana Ricciuti (601 
Electronically signed by Jeann Ricciuti (601 
c5062637-abo1-452c-a836-hc614e314d7a 
EFTA00298241

1 
Page 432 
Q. And neverthelms, she agreed that she would 
Page 434 
1 
Q. And she told you that she was comfortable with 
2 
Speak to you; is that right? 
2 
what she was doing? 
3 
A. Correct 
3 
MS. ARBOUR: Form. 
• 4 
Q. And she told you that she had known..? 
4 
BY MR. WEINBERG: 
5 
A. Yes. ' . 
5 
Q. Let me put it another way: That if she was 
6.. 
Q. And that IMI. was the person who introduced 
6 
uncomfortable, she would not do what she was 
7 
her to Jeffrey Epstein? 
7 
uncomfortable in doing, correct? 
MS. ARBOUR: Form 
• 
8 
MS. ARBOUR: Same objection. 
9 
THE WITNESS: I believe so. 
9 
THE WITNESS: • Right. 
10. 
BY MR. WEINBERG: 
10 
BY MR. WEINBERG: 
11. 
Q. And again, this was not a meeting that was — 
11 
Q. In other words —
12 . 
the introduction of Jane Doe 4 to Epstein by IMI. was 
12 
A. It was actually even stated in the — that if 
13 
not preceded by — 
13 
she felt uncomfortable, to say so and Mr. Epstein would 
14 ' 
(Ms. O'Connor exits the proceedings.) 
14 
stop pushing the issue. 
15. 
MR. PIKE: Go ahead and finish the question, 
15 
Q. And she wasn't the tint person that told you 
16 • 
but then don't answer until your attorney returns, 
16 
this; is that correct? 
17 
okay? 
17 
MS. ARBOUR: Fenn. 
18 
MR. WEINBERG: Well, we can withdraw that 
18 
THE WITNESS: I believe so. I believe she 
19 
question and take a five-minute break. Let's take 
19 
wasn't the only one. 
20 
a break. 
20 
BY MR. WEINBERG: 
21 
(A brief recess was taken.) 
21 
Q. And you interviewed a number of people that 
22 
(Ms. O'Connor re-joins the proceedings.) 
22 
told you that Mr. Epstein would ask them to take off all 
23 
BY MR. WEINBERG: 
• 
23 
thek clothes, and they would take off as much clothes 
24 • 
Q. Page 9 on 
So 
Ms. 
Jane 
Doe 
4's 
24 
as 
they 
felt 
comfortable 
with 
and 
we
re not forced to 
25 . 
aaffidavit. 
date of birth is
and she was 18 at the time of 
25 
take off any remaining clothes, correct? 
Page 433 
Page 435 
1 
your interview, correct? 
1. 
A. I know that there were, I believe., one or two 
2 
A. I believe so. 
2 
that went down to their bra and panties when he told 
3 
Q. And since your interview was in October and 
3 . 
them to get comfortable. And during the interviews, 
4 
her birthday was in 
she had been 18 for 
4 
Mr. Epstein stated to take off either their bra and/or 
5 
months? 
5 
panties. 
is 
A. (Non-verbal response). 
6 
Q. And they would either do it or not do it, 
7 
Q. Is that correct? 
7 
depending on their choice, correct? 
8 
. 
MS. ARBOUR Form. 
8 
MS. ARBOUR: Fon. 
9 
THE WITNESS: I believe so. 
9 
THE WITNESS: Correct 
10 
. BY MR. WEINBERG: 
10 
BY MR. WEINBERG: 
11 
Q. And she toldott that she had been introduced 
11 
Q. I mean, none of them said Mr. Epstein tore 
12 
to Jeff Epstein by M., correct? 
12. 
their clothes off —
13. 
A. Correct. 
• 
13 
A. No. 
14 
Q. And that she, like others who Ms... brought 
14 
Q. — over their objection? 
15 
to Mr. Epstein's house, knew that the purpose for which 
15 
A. No. 
16 
she was going was to give a massage and receive some 
16 
MS. ARBOUR: Form. 
.17 . money, correct? 
17 
BY MR. WEINBERG: 
18 
MS. ARBOUR: Form. 
18 
Q. And all of them told you that he respected the 
19 
THE WITNESS: I believe so, yes. 
19 
limits that they set; he didn't physically overcome 
20 
BY MR. WEINBERG: 
20 
their limits, correct? 
21 
Q. • And she told you that she had been there lots 
21 . 
MS. ARBOUR: Form: 
22 
of times over two years, correct? 
22 
THE WITNESS: There was one girl in 
23 .. 
MS: ARBOUR: Form. . 
23 
.particular, I can recall, where he was massaging 
24 
THE WITNESS: Yes. Yes. 
24 
her vagina and told her to relax, I'm not going 
25 
BY MR. WEINBERG: 
25 
inside. And she claimed that during the massage, 
30 (Pages 432 to 435) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciutl (601 
Electronically signed by Jeans Riccluti (601 
c5662637-abet-452c-a836-bc614e314d7a 
EFTA00298242

Page 436 
Page 438 
1 
he did go inside digitally, but — not force 
2 
himself it was just the incident we talked about. 
3 
BY 'MR. WEINBERG: 
4 
Q. And then she said no and he stopped, coned? 
5 
MS. ARBOUR: Form. ' 
6 
THE WITNESS: i think she pulled back. 
7 
BY MR. WEINBERG: 
8 
• 
Q. And he didn't try it again? 
9 
• MS. ARBOUR: Fonn. 
10 
THE WITNESS: He withdrew his forgers, yes. 
.11 . 
BY MR. WEINBERG: 
12 
Q. And with the exception of that girl, you 
13 
interviewed girl after girl after girl that said that 
14 
limits were set and respected? 
15 - 
MS. ARBOUR: Form. 
16 
THE WITNESS: Aside from the — Ms. Jane Doe 
17 
103's. 
18 
BY MR. WEINBERG: 
19. 
Q. Yes, taking aside Ms. Jane Doe 103 and the one 
20 
other girl you just mentioned, you interviewed 20 or 30 
21 
others who made no similar complaint to you, correct? 
22 
MS. ARBOUR: Form. 
23 
THE WITNESS: Correct. 
24 
BY MR. WEINBERG: 
25 
Q. And they instead said that limits were set by 
2 
3 
4, 
5 
6 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
make similar allegations, correct —
MS. ARBOUR: Form. 
THE WITNESS: Right 
BY MR. WEINBERG: 
Q. — who told you that Mr. Epstein deferred to 
.the limits they set, to the massage and to whatever 
occurred in connection with the massage? 
MS. ARBOUR: Form. 
THE WITNESS: Yes. 
BY Mk W13INBERG: 
Q. Ms. Jane Doe 4 was one of those people who 
told you that she told Mr. Epstein she had a boyfriend 
and would not go beyond certain limits, correct? 
MS. ARBOUR: Form. 
-THE WITNESS: I believe so. 
BY MR. WEINBERG: 
Q. And that she told you that she went to 
Mr. Epstein's house on a number of occasions and that 
she provided massages to Mr. Epstein, correct? 
A. Yes. 
Q. And that when she expressed feeling 
uncomfortable, Mr. Epstein would stop pushing whatever 
was the issue that caused her to say she felt 
uncomfortable, correct? 
MS. ARBOUR: Form. 
Page 437 
1 
themselves and then Mr. Epstein deferred to those 
2 
limits? 
3 
MS: ARBOUR Form. 
4 
THE WITNESS: As I recall -- see, I recall, 
. 
5 
like, interviewing Ms. Jane Doe 103 where she said 
.6 
things became escalating, so I don't know what 
limits you're referring to. 
8 
BY MR. WEINBERG: 
9 
Q. With the limit set by It Jane Doe 103 wherein 
10 
on one occasion you said Ms. Jane Doe 103 objected and 
11 
Mr. Epstein stopped. There was no other indication from 
12 
Ms. Jane Doe 103 that she objected, correct? 
13 
A. That was the time where — 
14 
Q. Right. But for that time, Ms. Jane Doe 103 
15 
never told you that she told Mr. Epstein, don't do that, . 
16 
and he did anyway? 
17 
A.- And that other incident involving the other 
18 
girl, which I believe was Jane Doe 2, where the 
19 
insertion of the fingers. 
20 
Q. And she pulled away and that ended the 
•. 
• 
21 
incident, correct? 
22 
. MS. ARBOUR: Form. 
23 
THE WITNESS: Yeaklbelieve that was — 
24 
BY MR. WEINBERG: 
25 
Q. 'You interviewed 28 Other people who didn't 
itv=est 
1. 
2 
3 
. 4 
5 
6 
7 
10 
11 
12 
13 
14 
15 
16. 
17 
18: • 
19 
20 
21 
22 : 
23 
24 • 
25 
Page 439 
THE WITNESS: I believe that's what Ms.. 
told her. 
• BY MR. WEINBERG: 
Q, And that's what she said was her experience, 
too? 
MS. ARBOUR: Form. 
THE WITNESS: Yeah.' 
BY MR. WEINBERG: 
Q. In other words, Ms... told her, you set the 
limits, you know, and those limits were being respected, 
correct? 
MS. ARBOUR: Form. 
THE WITNESS: I believe so. 
'BY MR. WEINBERG: 
• 
Q. And that Ms. Jane Doc 4 corroborated that, in 
fact, when she set limits, Mr. Epstein respected them? 
MS. ARBOUR: Form. 
. 
THE WITNESS: I believe so. 
BY MR. WEINBERG:
Q. And Ms. Jane Doe 4.said that during the period 
that she was going there, that it was not until, quote, 
recently, that Jane Doe 4 even began removing her 
• 
clothes and staying in her thong underwear to provide a 
massage, correct? 
A. Correct. 
31 (Pages 436 to 439) 
PROSE. COURT REPORTING 'AGENCY, 
('561)"832-75O.6 
Electronically signed by Jeana Rlcciutl (601 
Electronically signed by Jeana RicciutI (601 
00526.37413•1452e-s836-be614•314d7a 
EFTA00298243

Page 440 
1 
Q. In other worth, through the vast majority of 
2 
the period she was seeing Mr. Epstein, she was giving 
3 
Mr. Epstein massages that she represented to you were 
4 
given with most of her clothes on? 
5 
MS. ARBOUR: Form. 
6 
THE WITNESS: That's what 1— that's what she 
7 
claimed, yes. 
8 
BY MR. WEINBERG: 
9 
Q. And that Ms. Jane Doe 4, like others, said 
10 
that she was driven over by the person that introduced 
11 
her, in this case, Ms. M.? 
12 
MS. ARBOUR: Form. 
13. 
THE WITNESS: Right. 
14 
BY MR. WEINBERG: 
15 
!,I ; That she would be met on the first floor by 
16 
= 
correct? 
17 
A. Correct. 
18 
Q. That she would voluntarily accompany 
19 
upstairs, correct? 
20 
MS. ARBOUR: Foam. 
21 
THE WITNESS: Correct. 
22 
BY MR. WEINBERG: 
23 
Q. And that the massage was always in the 
24 
upstairs area, correct? 
25 
MS. ARBOUR: Form. 
1 
2.
3 
4 
5 
6 
7 
8" 
9 
10 
11 
12 
13. 
14 
15 
16 
17. 
18 
19 
20 
21 
22 
23 
24 
25 
Page 442 
Q. So certainly, with Ms. Jane Doe 4, that was 
• no indication that Mr. Epstein ever did anything except 
defer to the limits that she set on her massage, 
correct? 
MS. ARBOUR: Fenn. 
THE WITI•IFSS: She did state that he would try 
to get away with more and more on each massage, 
which was quoted in the PC, but... 
BY MR. WEINBERG: 
Q. Right. All sbe had to do was say no, and he 
stopped. 
•
• 
MS. ARBOUR: Form. ' 
THE WITNESS: That's pretty much what she 
stated. 
BY MR. WEINBERG: 
Q. With all of the women you interviewed, they 
were brought to the house by somebody else who was one 
of their friends: is that correct? 
MS. ARBOUR: Form. 
BY MR. WEINBERG: 
. Q. Or associates? 
MS. ARBOUR: Same objection. 
THE WITNESS: Pretty much. 
BY MR. WEINBERG: 
Q. And it was common practice during these events 
Page 441 
1 
THE WITNESS: Correct. 
2 
BY MR. WEINBERG: 
3 
Q. And nobody ever told you that they had engaged 
4 
in any sexual activity with Mr. Epstein in his lust 
5 
floor office, did they? 
6 
A. Not that I can recall, no. 
7 
Q. Or that he ever received a massage in his 
8, 
first floor office, cornea? And by "office," I mean 
9 
that area that that theft of money from his bag a 
10 • 
drawer occurred two years before. 
• . 
11 
A. Not that I can recall. 
• 
. 
12 
Q. And Ms. Jane Doe 4 continued to tell you that 
13 
as she described her massages, that on one occasion, 
14 
Mr. Epstein grabbed her buttocks and when he tried to 
15 
touch her breasts, she would pull away, tell him to stop 
16 
and he would stop, correct? 
17 
MS. ARBOUR: Form. 
18 
Tim WITNESS: Yes. 
19 
BY MR. WEINBERG: 
20 
Q. And that, likewise, she said that she set 
. 
20 
21'. 
limits and would not permit Mr. Epstein to in any way 
21 
22 
we a vibrator, correct? 
22 
23 . 
MS. ARBOUR: Form. 
23 
24 
WITNESS: Correct 
24 
25 
BY MR. WEINBERG: 
25 
1. 
2 
'3 
4 
5 
6 
7 
8 
10 
11 
12 
13' 
14 
15 • 
16 
17 
18 
19 
Page 443 
for the person who brought them to stay at the house 
during at least the first of the massages, correct? 
MS. ARBOUR: Form. 
THE WITNESS: Correct. 
BY MR. WEINBERG: 
Q. So that, for instance, Ms. M. stayed at the 
house while Ms Jane Doe 4gave Mr. Epstein a massage 
for the first time, correct?
MS. ARBOUR: Font 
INE.WITNESS. 'believe so. 
BY MR. WEINBERG: . 
er
And Ms. 
M
.
 
stayed at the house while 
Ms. M. gave Mr. Epstein a massage for the first time, 
correct? 
A. Correct. 
Q. When you interviewed Ms. M., she never told 
you that she heard anybody scream or complain or object 
or protest the massage while she was in the house, 
correa? 
MS. ARBOUR: Form. 
THE WITNESS: I did recall an incident 
involving a girl by the name of U. - 
BY MR. WEINBERG: • 
• 
Q. Risk. 
A., 
where.r think the* was a disagreement 
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1 
between Mr. Epstein and Ms. M. and there was --
2 
Q. She was upset —
3 
A. — she was upset, and I think she left and no 
4 
moneys were paid. 
5 
Q. Right. And didn't she come back a second time 
6 
even though she was upset the first time? 
7 
MS. ARBOUR: Form. 
8 
THE WITNESS: Yes, she did. 
9 
BY MR. WEINBERG: 
10 
Q. And with that exception, there was no other 
11 
representation made to you by any of the friends of the 
12 
masseuses or the people that introduced them to 
13 
Mr. Epstein, that any of the people that gave him a 
14 
massage ever had a conflict that they complained about 
15 
verbally or screamed or yelled in the house, correct? 
16 
MS. ARBOUR: Form. 
17 
THE WITNESS: Not that fm aware of, no. 
18 
BY MR. WEINBERG: 
19 
Q. And there were occasions, were there not, 
20 
where some of these girls that went to Mr. Epstein's 
21 
house to give massages had boyfriends? 
22 
MS. ARBOUR: Form. 
23 
THE WITNESS: I believe so. 
24 
BY MR. WEINBERG: 
25 
Q. And on occasion, the guys took the girds to 
Page 446 
1 
A. Yes. 
2 
Q. How long before the prior deposition was that 
3 
meeting? 
4 
A. It was actually documented in the report. I 
5 
did a supplement to that nature. I want to say a month, 
6 
a month before, a month and a half prior. 
7 
Q. So this is in 2010? 
8 
A. Yes. 
9 
Q. And this was shortly before the fu•st day of 
10 
the current deposition? 
11 
A. Yes. 
12 
Q. And you wrote a report about meeting with 
13 
Mr. Kuvin? 
19 
A. Ult•hult 
15 
Q. And that tt.po. t is available to us as a public 
16 
record? 
17 
A. Yes. It's with the case number. 
18 
Q. And the case number being the '06 number or 
19 
the '05 number? 
20 
A. Thc '05 — well, ifs cross referenced back 
21 
and forth, so... 
22 
Q. And do you recall what the content of the 
23 
conversation between you and Mr. Kuvin were? 
24 
A. It really wasn't much. I mean, I told him —
25 
he asked about certain things within the report; I 
Page 445 
1 
the house —
2 
MS. ARBOUR: Form. 
3 
BY MR. WEINBERG: 
4 
Q. — since someof them didn't drive? 
5 
A. I'm trying to think. I know some took taxis, 
6 
I know — I wouldn't know if the boyfriends took them (): 
7 
not. 
8 
Q. Let me ask you some different kind of 
questions as we work our way to the lunch break. 
• 
Have you discussed your testimony with any of 
the Plaintiffs' lawyers before corning to the first 
deposition last month? 
A. I spoke with Mr. KUVI11. 
Q. Yes. 
A. I met with him at Starbueks in West Palm prior 
to the depo. 
Q. And did he ask you to meet with him or did you 
ask to meet with him? 
A. He had called me and asked to meet with me. 
Q. And did he tell you the purpose of meeting 
with you was to try to talk to you about the Epstein 
case? 
A. I believe so. 
Q. And you agreed and went and met with him, 
correct? 
Page 44"/ 
1 
referred him to the report That was basically it. 
2 
Q. Was there any discussion of the subjects that 
3 
he intended to ask you about during the deposition? 
4 
A. No. He bad asked me some certain things 
regarding the report, and I just referred him to the 
6 
report. I was like, no, it's documented. 
7 
Q. Did he al you whether there was any current 
8 
investigation ongoing regarding Mr. Epstein? 
9 
A. I don't believe so. 
10 
Q. Did he tell you that he was aware of an 
11 
ongoing investigation being conducted by another agency? 
12 
A. I daft believe so. 
13 
Q. Did he discuss with you any knowledge that he 
14 
possessed regarding any ongoing Federal investigation? 
15 
A. No, not that i was aware of. 
1.6 
Q. Did he try to motivate you to recommence a 
17 
criminal investigation of Mr. Epstein? 
18 
A. No. 
19 
Q. Are you engaged in any ongoing criminal 
20 
investigation of Mr. Epstein? 
21 
A. No, I am not, and... 
22 
Q. Do you know whether anyone else in your 
23 • 
department is? 
24 
A. Nopc. 
25 
Q. Same questions for Mr. Edwards: Did you ever 
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1 
have any communications with Mr. Edwards prior to the 
2 
start of the deposition that was on March 19, 2010? 
3 
A. I did speak with Mr. Edwards by telephone some 
4 
time ago. It might even bo documented in the report us 
5 
well. 
6 
Q. What's your memory of that conversation? Who 
7 
called who? 
8 
A. He called me. There was some reference to a 
9 
girl that was, what he claimed, was not on the part of 
10 
the original investigation; that he has a client. I 
11 
referred him to the FBI, because everything had been 
12 
turned over to the FBI, so... 
13 
Q. So he called you to see whether or not his 
14 
client was in any way included in your prior 
15 
investigation? What exactly do you recall him saying? 
16 
A. It was 
he has or had a client, I'm not 
17 
really sum. 
18 
Q. Did he name the client? 
19 
A. No. 
20 
Q. How would you know whether or not his client 
21 
was included? 
22 
A. We have nothing at the police department. 
23 
Everything was referred over to the FBI, so it was easy 
24 
for me to say contact the FBI because we have nothing 
25 
here. 
150 
1 
Q. And Mr. Garcia? 
2 
A. No. 
3 
Q. And anyone from Mr. Josefsberg or anybody fro 
4 
his law firm? 
5 
A. No. 
6 
Q. How about investigators, did you know a man 
7 
nano listen? 
8 
A. No. 
9. 
Q. Fandrey? 
10 
A. No. 
11 
Q. Jenne? 
12 
A. No. 
13 
Q.' Has any private investigator ever attempted to 
14 
interview you regarding Jeffrey Epstein? 
15 
A. No. 
16 
Q. Has any private investigator ever informed you 
17 
that they were conducting surveillance on Jeffrey 
18 
Epstein's residence? 
19 
A. No. 
20 
Q. Did you have occasion to learn that any 
21 
private investigator was ever conducting a nighttime 
22 
surveillance of Jeffrey Epstein's residence during the 
23. 
past 12 months? 
24 
A. No. My — no. My only involvement with 
25 
private investigators were the ones that were following 
Page 449 
1 
Q. And do you have any other recollection of the 
2 
conversation with Mr. Edwards? 
3 
A. Not that I'm aware of, no. 
4 
Q. Do you recall what in the incident report 
5 
Mr. Kevin was asking you about? 
6 
A. No. I know I documented it, but... 
Q. So whatever the report that you documented 
would be your best memory of your conversation with him? 
A. Yes. 
Q. Now, after the start of the deposition, did 
you have any further conversations with Mr. Kuvin or 
Mr. Edwards regarding Mr. Epstein or regarding these 
proceedings other than the ones that were on the record 
during the deposition? 
A. Since the dopers started? 
Q. Yes. 
A. No. 
Q. And during the deposition, during any of the 
breaks in the deposition, did either of the two 
Plaintiffs' lawyers have any conversations with you of 
A. Nothing case-related. It was just... 
Q. Same questions regarding Mr. Mermelsteln and 
24 
Mr. Horowitz flaw you ever spoken to them? 
25 
A. No. 
Page 451 
1 
me and pulling my trash. But other than that, that's 
2 
it. 
3 
Q. Whoever they were, whatever they did, let's 
4 
put that aside. You've had no direct communication with 
5 
any person who represented themselves to be working with 
6 
any of the Plaintiffs' lawyers in this case? 
7 
A. No. 
8 
Q. And do you know whether or not Chief Reiter 
9, 
had any communications with any investigator working on 
10 
the Epstein investigation? 
11 
A. Not that I'm aware of. 
12 
Q. Did he ever tell you that he had any 
13 
communications with Mr. Jenne, or Mr. Fandrey or 
14 
Mr. Fisten? 
15 
A. Not that fin aware of. 
16 
Q. And have you ever seen any note, report, 
17 
document, memorandum, e-mail or log entry in the Palm 
18 
Beach records that anyone had been observed 
19 
surveillance — surveying Mr. Epstein's residence in the 
20 
past 24 months? 
21 
A. Not that I'm aware of. 
22 
Q. Would investigators, in a normal course of 
23 
business, if they were conducting an investigation in a 
24 
private area of Palm Beath, notify the police that they 
25 
intended to be parked in a certain area and watching a 
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certain residence? 
1 
regarding investigations. I mean, I usually 
2 
MS. ARBOUR: Form. 
2' 
forward e-mails to the woman who inputted the 
3 
THE.WITNESS: Some do, some don't In my 
3 
supplements into the report. I utilin'd the 
• 4 
years of experience, I've encountered private 
4 
e-mails for communication with other agencies, 
s 
investigators that informed the police department, 
5 
researching information. 
6' 
and there's investigators that don't. 
6 
BY MR. WEINBERG:
7 
BY MR. WEINBERG: 
7 
Q. Were there any other agencies involved in the 
8 
Q. Media. The media: Have you, yourself, ever 
8 
investigation of Jeffrey Epstein when you began it in 
9 
talked to a media representative/reporter named Connolly 
9 
the fall of 2005? 
10 
who was doing an article for Vanity Fair? 
10 
MS. ARBOUR: Form. 
11 . 
A. He did telephone me several times and left me 
11 
THE WITNESS: Not that I'm — no, not that I'm 
12 
voice mails. I believe I called him once and referred 
12 
aware of. 
13 
him to our media person, which was Janet Consuelo. I 
13 
BY MR. WEINBERG: 
14 
said, you know, if you have — want anything media 
14 
Q. And with the exception of Federal agencies, 
15 
related, dst's the person you need to speak to. I 
15 
were there any other agencies involved at any time in 
16 
don't speak to media. But other than that... 
16 
the investigation of Jeffrey Epstein? Putting aside the 
17 
Q. Any other media representative attempt to 
17 
FBI and the Federal authorities. 
18 
speak to you? 
18 
A. Not that I'm aware of. 
19 
A. Local reporters, they sent me e-mails, but 1 
19 
Q. And did you use your e-mail to communicate 
20 
just referred those to Janet. 
20 
with any Federal authority regarding Jeffrey Epstein? 
21 
Q. Sure. And how would they — did you have 
21 
A. I don't believe so. 
22 
e-mail addresses that are ace assible to members of the 
22 
Q. Do you have the e-mail addresses of the 
23 
media and the public? 
23. 
various FBI agents who was involved in the Federal 
24 
A. I mean, they're on my business card, you know, 
24 
investigation of Mr. Epstein? 
25 
my e-mail address, so... 
25 
MS. ARBOUR: Form.. 
Page 453 
Page 455 
Q. What e-mail address is that on your business 
1 
BY MR. WEINBERG: 
2 
card? 
2 
Q. For instance, Ms. Kizitendahl is the case 
3 
A. 
3
Cent-
4 
Q. And is that an e-mail that you would use to 
4 
MS. ARBOUR: Same objection. 
5 
conduct electronic communications with other police 
5 
TIE WITNESS: I don't believe so. I don't 
6 
offiects on an investigation? 
6 
believe so. 
7 
A. It's the e-mail that I use for work, yeah. 
7 
BY MR. WEINBERG: 
8 
Q. When did you start using that e-mail? 
8 
Q. Do you know Whellwr or not you ever sent a 
9 
A. When we rust got it. I mean... 
9 
communication to the FBI from your office in jrecarey 
10 
Q. How many years ago? Do you recall when you 
10 
e-mail? 
11 
first got an e-mail system or a personal e-mail for 
11 
A. I can't recall, but I don't believe so. 
12 
yourself? 
12 
Q. How about the media? 
13 
A. I don't know. I would venture to say back in 
13 
A. I don't speak to the media, so... 
14 
like 2003,2002. 
14 
Q. How about Chief Reiter? 
15 
Q. So before the beginning of the investigation 
15 
A. Within the agency, yeah, I sent e-mails all 
16 
of Mr. Epstein? 
16 
the time within the agency to different detectives, 
17 
A. (Igen-verbal response). 
17 
secretarial staff, Chief. 
18 
Q. And before the beginning of Ms. Pagan's 
18 
Q. Was there a decision that was discussed 
19 
investigation of Mr. Epstein; is that correct? 
19 
between you and Chief Reiter as to whether or not to 
20 
A. I believe so. 
20 
make available the incident report to the media, the 
21 
Q. And what is your practice in terms of using 
21 
Epstein 87-page incident report? 
22 
e-mail to communicate with other officers or other 
22 
A. I know I wasn't consulted with that. I mean, 
23 
detectives engaged in a common investigation? 
23 
that was decisions made. 
24 
MS. ARBOUR: Form. 
24 
Q. Who made that decision? 
25 
THE WITNESS: Generally, I don't send e-mails 
25 
MS. ARBOUR: Form. 
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BY MR. WEINBERG: 
2 
Q. To the best of your knowledge. 
3 
A. You'd have to ask Chief Reiter on that one. 
4 
Q. Is it ordinary practice of the Palm Beach 
5 
Police to disseminate incident reports to the media? 
6 
MS. ARBOUR Form. 
7 
THE WITNESS: Once they're filed, they become 
8 
public record, so you can go into the police agency 
9 
and ask for any report. 
10 
BY MR. WEINBERG: 
11 
Q. And the media has access to the incident 
12 
reports? 
13 
A. That's correct. 
14 
MS. ARBOUR Fortn. 
15 
BY MR. WEINBERG: 
16 
Q. And was there anything unusual, from your 
17 
perspective, regarding how this incident report was 
18 
handled vis-a-vis the media? 
19 
A. I don't believe so. 
20 
Q. But if there was, that would have been a 
21 
decision made by Chief Reiter and not yourself, correct? 
22 
MS. ARBOUR: Form. 
23 
THE WITNESS: Correct. 
24 
BY MR. WEINBERG: 
25 
Q. This case, this investigation began in March 
Page 458 
1 
interviewed by the Palm Beach Police between March of 
2 
2005 and your beginnings of the investigation in late 
3 
September of 2005? 
. 4 
A. That would have been documented in the report. 
5 
Q. Do you recall any other woman interviewed 
6 
during that six-month period? 
7 
A. I can't recall. 
8 
Q. Do you recall that trash pulls were occurring 
9 
during this March and April of 2005 period? 
10 
A. I did read that, yes. 
11 
Q. Do you recall that within the trash pulls, 
12 
there was some references to a belief amongst the 
13 
officers that there were sex utensils or sex objects 
14 
that were being identified and pulled out of the trash? 
15 
A. Yes. 
16 
MS. ARBOUR Form. 
17 
THE WITNESS: I recall the incident, the thing 
18 
you're talking about, which was later turned out to 
19 
be a handle of a — utensils. 
20 
BY MR. WEINBERG: 
21 
Q. Of an eating utensil? 
22 
A. Yeah. 
23 
Q. And do you recall within the incident report 
24 
there was a reference to this so-called object as one 
25 
that was consistent with use of anal sex? 
Page 457 
1 
of 2005, correct? 
2 
A. Correct. 
3 
Q. With a phone call from someone connected to 
4 
..'s family into the police department? 
MS. ARBOUR: Form. 
6 
BY MR. WEINBERG: 
Q. Is that right? 
8 
A. I believe so. 
9 
And you read n report regarding a debriefing 
10 
of M., correct? 
11 
MS. ARBOUR: Form. 
12 
THE WITNESS: I believe so, yes. 
13 
BY MR. WEN:BERG: 
14 
Q. But you had no ability to reach your own 
15 
aulibility determinations because you, yourself, never 
16 
reinterviewed Ms. M., correct? 
17 
MS. ARBOUR: Form. 
18 
THE WITNESS: Correct. 
19 . 
BY MR. WEINBERG: 
20 
Q. And those interviews were exclusively done by 
21 
others; is that right? 
22 
MS. ARBOUR: Form. 
23 
THE WITNESS: Correct. 
24 
BY MR. WEINBERG: 
25 
O. And Were there any other young women who were 
Page 459 
1 
A. Yes. They thought originally it was an anal • 
2 
wand. 
3 
(Mr. Garcia entered the room.) 
4 
BY MR. WEINBERG: 
5 
• 
Q. And do you recall that, even after your search 
6 
on October 20. 2005, wherein you saw lots of similar 
7 
utensils in the kitchen that clearly were designed for 
8 
eating; that there was no amendment to the Incident 
9 
report that reflected the discoveries of October 20 in 
10 
that the believed sex toys were, in fact, kitchen 
11 
Menai? 
12 
MS. ARBOUR: Form. 
13 
(Ms. Finnigan exits the proceedings.) 
14 
BY MR. WEINBERG: 
15 
Q. That was a terribly-worded question. 
16 
A. I was just going to say. 
17 
Q. Let me reword it. 
18 
The incident report contained the beliefs of 
19 
the officers, that what they were picking out of the 
20 
garbage were sexual mechanisms that --
21 
A. Right, they thought they were anal wands. 
22 
Q. — they thought were anal wands. 
23 
A. Right 
24 
Q. That on October 20th, when you went to 
25 
Mr. Epstein's residence, you realized as a professional 
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law enforcement officer that that conclusion was 
2 
mistaken. 
3 
A. Correct. 
4 
Q. Putt these objects taken out of the garbage 
5 
were, in fact, pans of eating utensils, correct? 
6 
A. Correct. 
7 
Q. Was there ever an amendment to the incident 
8 
report that reflected the knowledge that what had 
9 
previously believed to have been a sex utensil was, in 
10 
fact, an eating utensil? 
11 
MS. ARBOUR: Form. 
12 
THE WITNESS: It might have been referenced in 
13 
the report I'm net 100 percent certain on that. 
14 
BY MR. WEINBERG: 
15 
Q. If it wasn't in the 'two t, then there wasn't 
16 
an amendment to the report, fair to say? 
17. 
MS. ARBOUR: Form. 
18 
THE WITNESS: Fair to say. 
19 
BY MR. WEINBERG: 
20 
Q. I want to go back to September, when you first 
21 
got involved. You asked Ms. Pagan and others to send 
22 
you any tape recordings that had been conducted during 
23 
the beginning days of the investigation; is that 
24 
correct? 
25 
A. Correct 
Page 462 
A. l wanted to familiarize myself completely with 
2 
the case. 
3 
Q. And the best way to do it, you concluded as a 
4 
professional officer, was to listen to the verbatim tape 
5 
recordings? 
6 
MS. ARBOUR: Fort. 
7 
THE WITNI3SS: As I would on any other case. 
• 8 
BY MR. WEINBERG: 
9 
Q. And you wrote a report, an incident report 
10 
that is dated September 26, 2005. Let Inc just show you 
11 
this and ask you then to give it back because it's full 
12 
of notes, but I want to ask you a couple of questions 
13 
from there. Do you recognize this kind of document? 
14 
A. Yes. That was a supplement that I had 
15 
submitted to the secretary to be inputted into the 
16 
report. 
17 
Q. And in that supplement, you had referenced in 
18 
this middle paragraph, "On September 22, I was informed 
19 
by Sergeant Szarszewski —
20 
A. Szarszcwski, yes. 
21 
Q. — that there would be no trash pickup as it 
22 
was recycled pickup day." And then you sent a request 
23 
for copies of the micro and standard-sized cassettes, 
24 
were requested from Crime Scene to familiarize myself 
25. 
with the interviews conducted. 
Page 461 
1 
Q. And you wanted to hear the tape recordings, 
2 
did you not? 
3 
A. Yes.' 
4 
Q. And even one of the tapes was kind of — it 
5 
was broken during the copying for you, correct? 
6 
A. Correct 
7 
Q. And you wanted to hear the tapes because you 
8 
knew that listening to the tapes would give you the best 
9 
source of knowledge as to whth witnesses were telling 
10 
police officers in your absence, correct? 
11 
MS. ARBOUR: Form. 
12 
' 
THE WITNESS: I wanted to get the perspective 
13 
of the victim, yes. 
14 
BY MR. WEINBERG: 
15 
Q. And the perspective of the victim is more 
16 
accurately disclosed through a contemporaneous tape
17 
recording than through note taking, correct? 
18 
MS. ARBOUR: Form. 
19 
THE WITNESS: I believe so. 
20 
BY MR. WEINBERG: 
. 
21 
Q. And therefore, the source that you wanted to 
22 
got was the tape recordings, correct? 
23 
A. Correct. 
24 
Q. Rather than just relying on the narrative that 
25 
was incorporated into an incident report, correct? 
1 
2 
3 
4 
S 
7 
8
10 
11 
12 
13 
14 
15 
16 
17. 
'18 
19 
20 
21 
22 
24 
25. 
Page 463 
And the crime scene, the crime scene in this 
investigation was Mr. Epstein's residence, correct? 
A. No, from the Crime Scene Unit 
Q. From the Crime Scene Unit? 
A. Yes, who holds all evidence from the Palm 
Beach Police Department. 
Q. So the word "Crime Scene" refers to a unit 
within the Palm Beach Police Department? 
A. The Crime Scene Unit, yes. 
Q. And they're the evidence custodians? 
A. Yes. 
Q. And they have logs of evidence going in and 
out? 
A. Correct. 
Q. Just like you kept logs when different items 
. seized on October 20th were reviewed by you, correct? 
A. What logs are you referring to? 
Q. You kept different property logs. 
A. Oh, the property receipts? Yes. That's done 
with every piece of evidence Nat gets submitted into 
Crime Scene. 
Q. So therefore, the Crime Scene has a log that 
would contain an identification of each item of evidence 
that was maintained by the Palm Beach Police as of 
September 22,2005, correct? ' 
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23 
24 
25 
Page 464 
A. They have property receipts, yes, copies of 
the property receipts. 
. 
Q. So they would have the receipts for the videos 
that reflected surveillance before September 22nd, 
correct? 
A- Correct. 
Q. They would have property receipts for the 
results of the bash pulls before September 22nd. 
• 
A. Correct. 
Q. And the had the tape recording of their 
debriefing ofM., correct? 
. 
A. Correct. 
Q. Wherein M. said that she went to 
Mr. Epstein's house on one occasion, correct? 
A. I believe so, yes. 
Q. With M., correct? 
A. Yes. 
Q. Knew what she was going there for? 
MS. ARBOUR: Form. 
THE WITNESS: So she claims, yes. 
BY MR. WEINBERG: 
Q. Represented herself to be 18 to Mr. Epstein? 
MS. ARBOUR: Form. 
THE WITNESS: That, I don't recall. 
• 
Page 466 
1 
Q. Now, 
also told you that immediately after 
2 • 
leaving Mr. Epstein's house with the $200 or $300 she 
3 
received that day, she and.. went shopping, correct? 
4 
A. She told Detective Pagan. 
5. 
Q. Right. And she was inolthe only 
different 
6 
women told you that they went shopping with the money 
7 
they got from Mr. Epstein following their massages, 
8 
correct? 
9 
MR. GARCIA: Object to the form. 
10 
THE WITNESS: I can't recall if they told me 
11 
they weat specifically shopping, but.: 
12 
BY MR. WEINBERG: 
• 
13 
Q. Did you ever ask them what they did with the 
14 
$200 they received? 
15 
A. I might have. I can't recall at this time if 
16 
I did or didn't. 
17 
Q. Did you ever ask lane Doe 103 — strike that. 
18 
• 
• 
Jane Doe I.03 told you that she had received a 
19 
significant amount of money because she said she bad 
20 
• gone to Mr. Epstein's home on many occasions, correct? 
21. 
MS. ARBOUR: Form. 
22 
• 
THE WITNESS: Yes. 
n 
BY MR. WEINBERG: 
• 
24 
Q. And that it totaled thousands, rather than 
25 
hundreds, correct? 
Page 465 
BY MR. WEINBERG: 
2 
Q. If it's in the incident report, you wouldn't 
3 
believe that's inconsistent with your memory, correct? 
4 
MS. ARBOUR: Form. 
5 
BY MR. WEINBERG: 
6 
Q. In other words, if it's in your incident 
7. 
report, you have no reason to doubt that she said that? 
8 
A. Correct. 
9 
• 
Q. If it was said, it was said to someone else, 
10 
correct? 
11 
MS. ARBOUR: Font 
12 . 
THE WITNESS: Correct. 
13 
BY MR. WEINBERG: 
14 
Q. Your recollection is that, as you testified to 
15 
last time, that 
took her upstairs, correct? 
16 . 
A. Who, 
? 
17. 
18 
A. She is the ono who was interviewed by 
19 
Detective Paw, but... 
20 
Q. . Right. But she described it that some other 
21: 
woman took hefupstairs, correct? 
22 
A. Some other woman, yes. 
23 
Q. But she didn't give the name 
or 
or 
24 
any third party, correct? 
25 
A. I believe so. 
Page 467 
1 
A. I would believe so. 
. 
2 
Q. And did you ever ask her what she did with her 
3 
money? 
4 
A. I can't recall if I did or didn't. 
5 
Q. Do you recall ha declining or reflising to 
6 
tell you what happened to the money that she made with 
7 
Mr. Epstein? 
8 
• 
A. I can't recall. 
9 
Q. When you drafted the search warrant 
10 
affidavit —
11 
A. Yes, sir. 
12 
Q. — this was less than a month into the 
13 
investigation that was being led by you, correct? 
14 
MS. ARBOUR: Form. 
15 
THE WITNESS. Uh-huh. 
16- 
. BY MR. WEINBERG: 
It 
Q. You took it over in the third week of 
18 
September of 2005? 
19 
A. Towards the end of September, yes. 
20 
Q. There had — and you one of the first things 
21 
you did was to interview 
correct? 
22 
A. That was in October. 
23 . 
Q. The first week in October, correct? 
24 
A. Yes. 
25 
Q. And you went to Ms...'s house, did you not? 
PROSE COURT 
38 (Pages 
464 to 467) 
REPORTING. AGENCY, INC.• 
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Electronically signed by Jeans Ricciuti (601 
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Page 468 
Page 470 
1 
A. Yes, I did. 
2 
• Q. Ms... lived out of Palm Beach, did she not? 
3 
A. Yes. 
4 
Q. And the decision was made that you could 
5 
interview her without the presence of an officer from a 
6 
different department if she elected to come back to the 
7 
headquarters, correct? 
8 
A. Correct. 
9 
Q. And you asked her to come back to the 
10 
headquarters, correct? 
11 
A. Yes, I did. 
12 
Q. And she agreed to corns back to the 
13 
headquarters, did she not? 
14 
A. Yes, she did 
15 
Q. And at that point in time, when she was at her 
16 
house and you were asking her to be cooperative, she 
17 
agreed to be cooperative; is that right? 
18 
A. Well, she agreed to come back to the Police 
19' 
Department for further questioning. 
20 
Q. And she agreed essentially to cooperate with 
21 
your investigation of the interview, right? 
22 
MS. ARBOUR: Form. 
23 
THE 
S: Correct. I mean, she answered 
24 
the questions, if that's what you mean. 
25 
BY MR. WEINBERG: 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18-
.19 
20 
21 
22 
23 
24 
25 
telephones that you use to call out, correct? 
A. Yes. 
Q. And are tape recorders which would permit you 
to tape record an outgoing phone call, correct? 
A. Yes. 
Q. And Ms... certainly told ou that she had 
spoken on occasion on the phone to 
A. Yea 
Q. And that she had spoken to 
for the 
purpose of scheduling certain visits to Mr. Epstein's 
home, correct? 
A. Yes. 
Q. And that she had Ms. 
phone number? 
A. Uh-huh. 
Q. And that she could have called Ms. 
while she was at the Police headquarters, correct? 
A. Yes. 
Q. And did you decide whether or not you would 
ask her to make such a call? 
A. It was within her statement where she claimed 
she wanted nothing to do with 
or Mr. Epstein, that 
she had stopped communicating with 
so it would 
have been out of the norm for her to call. 
Q. You have asked cooperating witnesses to place 
tape recorded telephone calls to targets of your 
Page 469 
1 
Q. And she answered them by identifying to you at 
2 
least six other people that she had brought and 
3 
introduced to Mr. Epstein, correct? 
4 
A. Correct. 
5 
Q. And she agreed to talk to you abort.; is 
6 
that right? 
7 
A. I believe so, yes. 
8 
Q. And she answered any questions you asked her; 
9 
is that right? 
10 
A. Yes. 
• 
11 
Q. Mr. Epstein was in town at the time; is that 
12 
right? 
13 
MS. ARBOUR: Form. 
14 
BY MR. WEINBERG: 
15 
Q. 'Do you recall that your incident report 
16 
reflects that his — 
17 
A. Yes, that his plane was in town, yes. 
18 
Q. And that Ms 
is at the Police Department 
19 
with you; is that right? 
20 
A. Ub-huh. 
21 
Q. She is being interviewed behind a one-way 
22 
glass so that the content of the interview was being 
.23 
observed by others? 
24 
A. Yes. 
25 
Q. And within the Police Department are 
Page 471 
1 
investigation on other occasions, have you not? 
2 
A. Yes. 
3 
Q. And that was certainly an investigative 
4 
technique that you considered employing in this case? 
5 
A. Considered it. 
6 
Q. And then you made a decision as the case agent 
7 
not to request that Ms... lace a recorded phone call 
8 
to either Mr. Epstein or Ms. =, 
correct? 
'9 
A. Correct. 
• 
10 
Q. And not to ref= to Mr. Epstein's house 
11 . 
wearing a recorder wherein the events that transpired 
12 • 
there and the conversations that occulted there could be 
13 
recorded and transmitted to some — to law enforcement, 
14 
correct? 
15 
A. Correct. 
16 
Q. Back to the search warrant affidavit. You've 
17 
authored other search warrant affidavits, have you not? 
18 
A. Uh-huh. 
19 
Q. And your goal when you authored them is to be 
20 
complete and accurate, is it not? 
21 
A. Yes. 
22 
Q. You understand that the magistrate — strike 
23 
that — that the judge that's going to review the 
. 
24 
al£davit ordinarily has no other independent bases to 
25 
know whether or not to authorize a search of a residence 
39 (Pages 468 to 471 ) 
. 
PROSE COURT REPORTING AGENCY,. INC. 
Electronically signed by Jeana RIcciutl (601 
Electronically signed by Jeana RIcciuti (601 
c5062637-abel-452c-a836-bc614.314d7a 
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Page 472 
1 
.crept the information that's being provided to him by 
2 
the affiant, correct? 
3 
MS. ARBOUR: Form. 
4 
'THE WITNESS: Correct. 
5 
BY MR. WEINBERG: 
6 
Q. And these affidavits are under oath, correct? 
7 
A. Yes. 
8 
Q. And they're designed to be accurate and 
9 
complete, are they not? 
10 
A. Yes. 
11 
Q. Because you understand that omissions can be 
12. 
as deceiving as misrepresentations, correct?
13 
A. Correct. 
14 
Q. In this case, you were seeking authority to 
15 
conduct a search of Mr. Epstein's private residence, 
16 
coil 
17 
A. Correct. 
18 
Q. And you sought that permission based on an 
19 
affidavit that reported to the judge the results of 
20 
certain interviews you conducted? 
21 
A. Uh-huh. 
22 
Q. And certain blowup investigations, such as 
23 
the results of trash pulls and phone records; is that 
24 
right? 
25 
A. Correa 
Page 474 
1 
BY MR. WEINBERG: 
2 
Q. When you searched the Dell computer taken from 
3 
the second residence, did you conduct the search or did 
4 
a forensic expert conduct it? 
5 
A. It was sent to the Sheriffs office for 
6 
imaging, and then the imaging itself was looked at. 
7 
Q. Not one of your witnesses ever said that they 
8 
saw Mr. Epstein use a computer; is that correct? 
9 
A. I'm trying to recall. Not that I can recall. 
10 
Q. Not one of your witnesses said they ever 
11 
received an e-mail from Mr. Epstein, correct? 
12 
A. I can't recall at fills time. 
13 
Q. Not one of your witnesses ever said that when 
14 
they were at Mr. Epstein's house, they had ever looked 
15 
at anything on a computer at Mr. Epstein's house or ever 
16 
seen anything on a computer at Mr. Epstein's house? 
17 
A. I ain't recall. 
18 
Q. Not one of your witnesses ever said that they 
19 
had received an e-mail from anyone other than 
20 
Mr: Epstein who resided at Mr. Epstein's house, coned? 
21 
A. I can't recall if.. claimed that she got an 
22. 
e-mail. That's why I'm not 100 percent certain on the 
23 
email. 
24 
Q. If it's not in the incident report, you have 
25 
no independent memory of anyone telling you that they 
Page 473 
1 
Q. Within the affidavit, you asked for permission 
2 
to search any DVDs, any CDs, any computer discs, any 
3 
media that you could find in Mr. Epstein's residence; is 
4 
that correct? 
5 
A. Correct. 
6 
Q. And in het, you did seize such CDs, DVDs and 
7 
various media discs, did you not? 
A. We seized some. 
9 
Q. And you searched them --
10 
A. Yes. 
11 
Q. — not knowing what was on them? 
12 
A. Correct. 
13 
Q. And likewise, you seized a Dell computer from 
14 
a guest house that was a separate and detached residence 
15 
on the Epstein property, is that correct? 
16 
A. Correct 
17 
Q. And you ultimately gave back anything seized 
18 
from that separate residence, understanding that it, in 
19 
essence, was the home of another individual, correct? 
20 
A. Because it was returned back to the innocent 
21 
party who had no evidence on his computer us to the 
22 
items that we were searching, yes. 
23 
Q. And when you searched these computers, you 
24 
were looking for anything; is that correct? 
25 
MS. ARBOUR: Form. 
Page 475 
1 
ever received an e-mail from 
or 
2 
anyone else that resided at Mr. Epstein's home, caret 
3 
A. Fin trying to recall. I can't recall. 
4 
Q. You do recall that the scheduling was done as 
5 
a routine practice by phone, correct? 
6 
A. Yes. 
7 
Q. And that largely, the conversations, to the 
8 
extent they were explained to you, were simply phone 
9 
calls to and from 
picking a time, picking a date 
10 . 
when they would go to Mr. Epstein's home, correct? 
11 
. MS. ARBOUR: Form 
12 
THE WITNESS' I believe so. 
13 
BY MR. WEINBERG: 
14 . 
Q. And you saw message pads that confirmed El 
15 
the message was generally limited to, Pm availalco. 
16 
call me, Icon come, messages that were reflective of 
17 
scheduling and an openness to going to Mr. Epstein's 
18 
home, correct? 
19 
MS. ARBOUR: Form. 
20 
BY MR. WEINBERG: 
21 
Q. We can go through a lot of the messages this 
22 . 
afternoon, but... 
23 
A. I believe so. 
24 
Q. The investigation you conducted, that included 
25 
the search on October 20th, continued into November and 
or 
40 (Pages 472 to 475) 
• PROSE COURT REPORTING .AGENCY,' INC. 
Electronically aligned by Joana Fticclutt (601 
Electronically signed by Joana Rlcciuti (601 
c5062637-abol-462c-a836-bc614e314d7a 
EFTA00298252

Page 476 
Page 478 
1 
December of 2005, correct? 
1 
it a fivocount charge against Mr. Epstein, two counts 
2 
' A. Uh-huh. 
2 
with five allegations, if you recall? 
3 
Q. So it began in Much and it continued through 
3 
A. I can't recall. 
4 
December of 2005, correct? 
4 
• 
Q. There was ono count for lewd and lascivious, 
5 
A. Yes. 
5 
and one count for unlawful sex act that was returned by 
6 
Q. The first time you formalized a probable cause 
6 
a Palm Beach grand jury in and around June of 2006. 
7 
affidavit was May 1, 2006, correct? 
7 
MS. ARBOUR: Form. 
8 
A. Uh-huh. 
8 
BY MR. WEINBERG: 
9 
Q. And that probable cause affidavit resulted 
9 
Q. Let me go back. There was a grand jury 
10 
several months later when the State Attorney was 
10 
indictment, correct? 
11 
presenting a case to the grand jury? 
11 
A. Yes. 
12 
A. That was — that whole fiasco with the State 
12 
Q. Thereafter, there was information? 
13 
Attorney's office where originally we were going to go 
13 
A. Yes. 
14 
to the grand jury, then we postponed it, and then we 
14 
Q. The grand jury indictment charged 
15 
were going to go back to the grand jury, then we 
15 
solicitation, correct? 
16 
postponed it, and then they said no, we want a probable 
16 
A. I believe so. 
17 
cause affidavit. So I submitted it as a probable cause 
17 
Q. And that came about on either the end of Juno 
18 
affidavit, and they came back and said no, we want to go 18 
or July of 2006, correct? And we can go back —
19 
back to the grand jury — 
19 
A. I believe you're right I'm not 100 percent 
20 
Q. To cut through it, there was some, to put it 
20 
certain, but I believe you're right. 
21 
mildly, niscommunication between the State Attorneys 
21 
Q. And before the grand jury acted, did you and 
22 
office and the Palm Beach Police Department? 
22 
Chief Reiter discuss going to the Federal authorities 
23 
MR. GARCIA: Object to the form. 
23 
and bypassing the State Attorney? 
24 
MS. ARBOUR: Form. 
24 
A. I can't recall. I believe it might have been 
25 
MR. GARCIA: Mischaracterizes his testimony. 
25 
after, but I'm not 100 percent certain. 
Page 477 
Page 479 
1 
BY MR. WEINBERG: 
1 
Q. Do you have any records, notes, reports that 
2 
Q. Let me go back and start again. In April, 
2 
would refresh your memory as to the first time that 
3 
they told you they were going to conduct a grand jury 
3 
either you or Chief— or to your knowledge, 
4. 
and subpoenas went out to certain people, okay? 
4 
Chief Reiter communicated with the Federal authorities 
5 
A. It was prior to April, I believe. I think we 
5 
and asked them to commence or initiate an investigation 
6 
were in March. 
6 
of Mr. Epstein? 
7 
Q. So in March, the grand jury subpoenas were 
7. 
MS. ARBOUR: Form. 
8 
served for an April appearance. Does that chronology 
8 
THE WITNESS: No, Ideal have any records. 
9 
make sense? 
9 
BY MR. WEINBERG: 
10 
A. I think that's when the discussions were back 
143• 
Q. And do you know whether or not — was it you 
11 
and forth about grand jury. 
11 
that made that initiation to the Federal government? 
12 
Q. And Ms. Jane Doe 103 was served with a gland 
12 
A. I believe so. 
13 
jury subpoena? 
13 
' Q. And do you recall just how you did that? Did 
14 
A. I drove up and I served her with a grand jury 
14 
you drive over to the Federal — to the US Attorneys 
15 
subpoena. 
15 
office? Did you call the FBI? How was the initiation? 
16 
Q. And that grand jury was postponed or canceled; 
16 
A. I am also assigned to the Joint Terrorism Task 
17 
correct? 
17 
Force, so I have daily communication with people at the 
18 
A. Yes. 
18 
FBI, if not every other day. Iliad the clearance, you 
19 
Q. And a second grand jury was thereafter 
3 9 
to
 in and out of the office. But Fm trying to 
20 
convened during the summer of 2006, correct, months 
20 
recall. I believe it might have been me. 
21 
after the first one? 
21 
Q. And what's your best recollection as to how 
22 
A. Yes. 
22 
this occurred as to, did you go to the FBI, were you 
23. 
Q. And taking that timeline, between the grand 
23 
talking to them in any way at a Joint Task Force 
24 
jury for which you subpoenaed Ms. Jane Doe 103 the first 
24 
meeting? Did you make it a point to bring this matter 
25 
time and the grand jury that ultimately returned — was 
25 
to their attention? What's your best recollection of 
41 (Pages 
476 to 479) 
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