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how the dialogue commenced? 
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A. I don't recall. I can't recall. 
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Q. But you do recall at least one conversation 
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with the Federal authorities regarding Mr. Epstein? 
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A. Yes. 
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Q. Do you recall more than one conversation with 
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them? 
A. I recall a meeting with Junior Ortiz, who was 
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the supervisor, the local supervisor. He was present, 
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Chief Reiter was present, 'was present. That would 
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have been in the summer. 
12 
Q. Do you recall where that meeting occurred? 
• 
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A. It was at the FBI office because it was in 
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Junior's office. 
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Q. Was this before or after the Federal subpoena 
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went out to the Palm Beach P1) for the production of 
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their records regarding the State investigation? 
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A. This would have been before.
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Q. And this is the first meeting you recall 
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wherein Mr. Epstein was discussed with the Federal 
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authorities in your presence? 
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A. Yes, I believe so. 
23 
Q. And do you recall whether it was you or 
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Chief Reiter that invited —that initiated this 
25 
meeting? 
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Page 482 
A. -- that they wanted everything pertaining to 
the case, and everything that was pertaining to the case 
went with them. 
Q. Do you have any logs, diaries, calendars, 
notes that would provide you with the basis to know the 
date of this meeting? 
A. Of the Federal subpoena, or —
Q. No, of the meeting between you and Chief —
A. No, there were no logs. 
Q. 
— Reiter that met with the special agents. 
Was there any follovrup that you engaged in? 
A. Not that I can recall. !mean, once they came 
in and took over the stag that was it. 
Q. How long did this meeting occur? 
A. About an hour or so. I wouldn't — I believe. 
Q. And do you recall questions that were asked of 
you during this hour? 
A. No. 
Q. And do you recall information that you 
cornmtmicated during this hour? 
A. No. 
Q. And do you recall any questions asked of 
Chief Reiter during this hour? 
A. No. 
Q. Do you recall anything said by Chief Reiter to 
Page 481 
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A. I can't recall. I'm trying to think back. 
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Q. So, who else was at this meeting? 
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A. I know Junior was there, I believe the Chief 
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was there, I was there. 
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Q. And do you recall whether or not you took any 
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notes that were memorialized in any report regarding the 
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content of this meeting? 
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A. No. 
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Q. And was the purpose of you and Chief Reiter 
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going to the FBI and having this meeting to request that 
11. 
they take over the criminal investigation of 
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Mr. Epstein? 
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MS. ARBOUR: Form. 
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THE WITNESS: It wasn't to take over. I 
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believe it was to determine if there was any 
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Federal nexus or any Federal violation, but it 
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wasn't to take over, although subsequently that's 
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what happened, but... 
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BY MR. WEINBERG: 
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Q. And did you and Chief Reiter provide the 
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Federal authorities with whatever information was 
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available to you? 
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A. We didn't have a choice. They came in with a 
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Federal subpoena --
25 
Q. Following this meeting? 
Page 483 
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the FBI? 
2 
A. No, I'm sorry. 
3 
Q. Who first raised the issue of nexus, of 
4 
whether there was any Federal nexus to what had been, up 
5 
to this day, a purely local investigation of activities 
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being conducted of Mr. Epstein's private residence? 
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MS. ARBOUR: Form. 
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THE WITNESS: I can't recall whether it was me 
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or former Chief Reiter. 
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BY MR. WEINBERG: 
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Q. And those conversations occurred before this 
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meeting? 
13 
A. Either at the meeting or just before the 
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meeting. 
15 
Q. And did this meeting occur at or around the 
16 
time that Chief Reiter was writing letters expressing 
17 
his displeasure with the State and State Attorney's 
18 
investigation? 
19 
MS. ARBOUR: Object to f01111. 
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ME WITNESS: I believe it was after the 
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letters. 
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BY MR. WEINBERG: 
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Q. Do you remember those letters? 
24 
A. Yea 
25 
Q. And those letters were written or drafted and 
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PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana RitrJult (801 
Electronically signed by Jeana Ricciuti (601 
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1 written by Chief Reiter and sent to whom? 
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MS. ARBOUR: Form. 
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A. They were sent to some of the parents of the 
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THE WITNESS: I wouldn't consider what she did 
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victims. 
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her investigation. I think she just looked at 
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Q. If I represent to you that at least some of 
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these girls' MySpace accounts. I wouldn't consider 
- 5 , - - those letters were dated in May of 2006, would that jog 
s 
that an investigation. 
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your memory as to when this meeting.with Special Agent 
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BY MR. WEINBERG: 
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Ortiz occurred? 
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Q. But she had in her possession at this time 
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A. I believe it would have been after those 
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your incident report? 
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letters. 
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MS. ARBOUR: Fenn. 
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Q. But before the return of the State grand jury 
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THE WITNESS: Yes. 
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indictment? 
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BY MR. WEINBERG: 
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A. I don't believe it was before the grand jury. 
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• Q. Your probable cause affidavit? 
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I believe it was after the sand jury. 
13 
• 
MS. ARBOUR: Form. 
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Q. So your best memory, therefore, would be that 
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THE WITNESS: I don't know if it was drafted 
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it would be after both the letters and the grand jury? 
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yet. 
16 
A. Comet. 
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BY MR. WEINBERG: 
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Q. You had different conversations with the State 
17 
Q. But she had the raw materials of your many 
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Attorney during this period, with one or more of the 
18 
interviews over many months, correct? 
19 
State attorneys? 
19 
MS. ARBOUR: Fenn. 
20 
A. Yeah, Assistant State attorneys. 
20 
THE WITNESS: Yes. 
21 
Q. Which Assistant State attorney do you recall 
21 
BY MR. WEINBERG: 
22 
talking to? 
22 
Q. She had the results of the search, did she 
23 
A. 
23 
not? 
24 
Q.64 
recall any conversation with 
24 
A. Yes. 
25 
Ms. 
wherein you discussed whether or not your 25 
Q. She had the message pads available to her, did 
Page 485 
Page 487 
1 
witnesses were or were not victims? 
1 
she not? 
2 
MS. ARBOUR: Form. 
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MS. ARBOUR: Form. 
3 
THE WITNESS. I recall her picking and 
3 
THE WITNESS: I don't believe she had the 
4 
choosing who she wanted to refer to as a victim. 
4 
message pads. They were in our evidence. 
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Most of my conversations with her I know were 
5 
BY MR. WEINBERG: 
6 
documented in the report. 
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Q. But she could if - 
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BY MR. WEINBERG: 
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A. She had, I think, certain copies of certain 
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Q. 13o you recall words to the effect that you 
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pages of than. 
• 
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were frustrated with her because one of ha opinions 
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Q. She had a file as an Assistant State Attorney 
10 
were that there was no victims in this case? 
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in charge of a criminal' investigation of Mr. Epstein 
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MS. ARBOUR: Fonn. 
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that was being conducted by your department, correct? 
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THE WITNESS: I did recall that conversation, 
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MS. ARBOUR: Form. 
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' 
Yes- 
' 
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THE YoTINESS: I believe she did have a file, 
14 
BY MR. WEINBERG: 
14 
yes, of items that were given to ha by us. 
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Q. And what do you recall of that conversation? 
15 
BY MR. WEINEIF.RO: 
16 
A. I recall her, after viewing some of the 
16 
Q. She didn't only have that which was provided 
17 
materials that were supplied to her by Dershowitz, she 
'17 
by the Defense, 
18 
started to claim that the victims were not victims based 
18 
MS. ARBOUR; No. 
19 
on the materials that were supplied by the MySpaces. 
19 
THE WITNESS: No. She had items that we had 
20 
Q. The victims were not victims? 
20 
provided. 
21 
A. That's what she was claiming. 
21 
BY MR. WEINBERG: 
22 
Q. And this is the State Attorney's statements to 
22 
Q. And putting aside what you believe was the 
23 
you based on her investigation which included her review 
23 
more important evidence to her, which was her review of 
24 
of materials provided to her by Defense Counsel 
24 
the MySpace pages of certain of your witnesses, she did 
.25 
Professor Alan Dersb3witr2 
25 . 
communicate to you, the case agent, ha belief that 
43 (Pages 484 to 487) 
' . PROSE COURT REPORTING AGENCY; INC. 
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Electronically signed by Jeana Ricciuti (601 
c5062637-abel-462c-a836-bc614e314d7a 
EFTA00298255

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Page 488 
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there was no victims i n this case? 
A. Based on what she was observing on those 
3. 
pages. At least that's my opinion: 
4 
Q. But what her statement to you was: There are 
5 
no victims in this case? 
MS. ARBOUR: Forni 
THE WITNESS: I believe so. 
BY MR. WEINBERG: 
Q. And that was made after she reviewed the 
MySpace pages, comet? 
MS. ARBOUR: Form ..
• 
114E WITNESS: I believe so. 
BY MR. WEINBERG: 
O. But also after she had in her possession a 
very substantial investigative incident report that 
. 
reflected many interviews with many witnesses conducted 
both by you and others working with you and by others 
before you, correct? 
MS. ARBOUR: Form. 
ME WITNESS: In my opinion, once 
Mr. Dershowitz became involved, her demeanor on 
this case was completely different. 
BY MR. WEINBERG: 
Q. And let me go back to square one so we can 
finish this area and then have lunch. 
. ff
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Page 49C 
Q. And she was the proseCutor in charge of the 
case? • 
MS. ARBOUR: Form. 
THE WITNESS: She was one of the prosecutors 
that was assisting in this case. 
-BY MR. WEINBERG: 
Q. AM when did she make the statement to you, 
. "There are no victims here"? 
A. This is when we were debating we go to the 
grand jury, not to go to the grand jury, write me a PC, 
don't write me a PC, we're going back to the grand jury. 
Q. Late spring of 2006? 
A. Like I said, this was ongoing from in the 
investigative stage. This was prior to the arrest 
. Q. And she was talking to you about going to the 
grand jury, correct? 
A. Whether we were going to go to the grand jury, 
then we weren't going to go to the grand jury. 
Q. But the first grand jury, which was scheduled 
in March or April, different witnesses were subpoenaed 
to that grand jury, correct? 
A. Correct. 
Q. Amongst them was Ms. Jane Doe 103, correct? 
A. Yes. 
Q. Amongst them was Ms. M., correct? 
Page 489 
1 
A. Okay. 
2 
Q. Okay? Before Mr. Dershowitz got involved, she 
3 
had an incident report, did she not? 
4 
A. IJh-hub. 
5 
Q. She had a probable cause — a search 
6 
warrant -
7 
A. I take that back. Prior to Mr. Dershowitz 
8 
being involved, I don't believe she had the incident 
9 
report as of yet. It was still in the investigative 
10 
stage. The search had been conducted, interviews bad 
11 
been conducted, I had been providing her with copies of 
12 
the interviews, but I don't believe that she had a copy 
13 
of the incident report as of yet: 
14 
Q. Right. And she had copies of certain portions: 
15 
of what ultimately was incorporated into the incident 
' 
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report, correct? 
17 
MS. ARBOUR: Form. . 
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THE WITNESS. I don't believe so. 
19 
BY MR. WEINBERG:. 
20 
Q. She had — did she not have copies of mulls 
21 
of- 
22- 
A. When the case is under investigation, were 
23 
not going to release the incident report. She may have 
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had the face sheet and the — involving Mr. Epstein's 
25 
name on it,.but that's basically it. 
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Page 491 
A. Yes. 
Q. Was amongst them Ms. M.? 
A. Yes. 
Q. Who else? 
A. I believe this was it. I think that was the 
initial — they were going to do it in sections, and 
they were going to pick those girls to go first. 
Q. And the criminal offense that she was 
investigating at the time was felony solicitation? 
MS. ARBOUR: Form. 
THE WITNESS: I don't know what she was 
looking into. I know what f was seeking. 
•
BY MR. WEINBERG: 
Q. You and her had disagreements about witnesses 
and charges, correct? 
A. Yes. 
Q. -And you had disagreements about whether or not 
the witnesses that you denominated victims and she said 
weren't victims, you had disagreements over their 
credibility, did you not? 
A. Not over their credibility. It Was over, 
like, the MySpace pages I bad the feeling that she was 
1134118 to — 
• Q. I don't mean to interrupt, but I want to stick 
to conversations and evidence and not feelings, so
44 (Pages 488 to 491) 
PROSE COURT 'REPORTING AGENCY, 
':.:.•: :":(561)' -832-7506 
Electronically signed by Jeana RIccluti (601M( 
Electronically signed by Jeana Rlccluti (601 
c15062637-abe14620-68364x:614•314d7a 
EFTA00298256

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Page 492 
MR. GARCIA: Cm ahead and finish your answer, 
sir. Don't let him interrupt you. You can finish 
your answer. 
THE WITNESS: I had the feeling that she was 
trying to brush this case under the carpet. That 
was my —
BY MR. WEINBERG: 
Q. You believed that she was minimizing the CIL% 
correct? 
. 
A. (Non-vabal response). 
Q. And you believed that one of the reasons she 
was minimizing the case was her review of the MySpace
pages of some of your witnesses, correct? 
A. I know that the attitude of the State 
Attorney's office was very pro-assisting us from the 
very beginning. Once Mr. Dersbowitz became involved in 
the investigative stage, everything changed. 
Q. So let's talk about these MySpace pages for a
minute. MySpace pages are an Internet site where the 
witnesses herself would put information out there that 
was available to whoever accessed the site, correct? 
MS. ARBOUR: Form. 
TIIE WITNESS: MySpacc is a social network that 
you can basically create anything that you want to 
create on a MySpace page. 
Page 494 
1 
BY MR. WEINBERG: 
2 
Q. And the State Attorney was weighing the 
3 
-.MySpace information with the information that they were 
4 ,. receiving from the Palm Beach Police Department; is that 
5 
correct? 
6 
MS. ARBOUR: Form. 
7 . 
. THE WITNESS: Well, the information and the 
8 
meetings that Mr. Dershowitz had with Barry 
9 
Krisher. 
10 
BY MR. WEINBERG: 
11 - 
Q. And you were not present at some of these 
12 
meetings? 
13 - 
A. Correct. 
14 
Q. So you don't know the full scope of the 
15'• 
presentation being made by attorneys, including 
16 
Professor Dershowitt, on Mr. Epstein's behalf, correct? 
17 
A. I just found it odd that during the 
18 
investigative stage, we were already discussing 
19 
strategies on whether to prosecute or not to prosecute, 
20 
and this was still in the investigative stage of it. 
21 
• Q. Putting aside your feeltngs, you were not 
22 
present at these presentations? 
23 
A. Some I were. 
24 
Q. Some you were. You don't know the full scope 
25 
of the arguments and the evidence that was being 
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Page 493 
BY MR. WEINBERG: 
Q. And you understood that certain of your 
witnesses created their own MySpace page, correct? 
A. It's possible. 
Q. And did you ever, in order to determine any of 
the background of your witnesses, go on their MySpace 
Pages? 
A. I did view some of their MySpace pages, and I 
did view sane of the items that Mr. Dersbowitz provided 
to Mr. Krisher, but we're talking about teenagers who 
put -- this is information that's put on a site that's 
not checked for any validity. I can create a site using 
your information. 
. Q. Did you ever ask Ms. lane Doe 103 in any 
followup interview, is there anything on your site that 
doesn't depict you? 
A. Actually, I never spoke to any of the victims 
• 
about — . 
Q. Did you ever do an independent investigation 
to determine whether any of the information provided by 
Professor Dershowilz to the State Attorney was 
fabricated or falsified or externally placed there by ' 
• . 
some third party? 
MS. ARBOUR: Pam. 
THE WITNESS. No 
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Page 495 
provided to the State Attorney by the Defense lawyers, 
correct? 
MS. ARBOUR: Form. 
THE WITNESS: The ones that I chose to go to, 
'just — I was privy to some of the information 
but not all. 
BY MR. WEINBERG: 
Q. And the fact is that 
A. .Yesh.: 
. 
Q. — came to separate conclusions from case 
chief Detective Joe Recarey, regarding the gravity of 
Mr. Epstein's conduct, correct? 
• . 
MS. ARBOUR: Form. • 
. 
-THE WITNESS: Pm sorry? 
BY MR. WEINBERG: 
• 
Q. You and the State Attorney's office came to 
different conclusions in this case, correct? 
MS. ARBOUR: Porni. 
THE WITNESS: We had our disagreements, yes. 
• BY MR WEINBERG: 
Q. And those disagrectrients led to you and 
Chief Reiter inviting the FBI agent intothis 
investigation, correct? 
• . • 
•MS. ARBOUR: Pam. • 
• 
THE WITNESS: Not the disagreements. The faet 
45 (Pages 492 to 495) 
PROSE COURT REPORTING -AGENCY, INC.. 
'4561) $32-7506 . 
Electronically signed by Jeana Rlectutl (601 
Electronically signed by Joana Rlcciull (601 
c5062637-abo1452c-a836-bc8146.314d7a 
EFTA00298257

Page 496 
Page 4981
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that the case wasn't— it wasn't-- in my eyes, it 
1 
CERTIFICAT3 
2 
SIATROP FLORIDA 
2 
wasn't any justice served. 
3 
COUN1Y OF PALM REACH 
3 
BY MR. WEINBERG: 
' 
4 
4 
Q. Your disagreanents with the State Attorneys 
$ 
LkamRieciuri. Registered Professional 
Reporter and Notary Public in and for the State of 
5 
charge decision led you to go outside the State law 
6 
Florida a Lana, do hereby certify that the 
6 
enforcement community and transmit information about 
aforemanional witness was by me lint duly mom to 
7 
testify the whole truth; that I was unbolt() to and 
7 
Mr. Epstein to Federal authorities? 
did moon said deposition in stenotype; and that the 
0 
MS. ARBOUR: Form, asked and answered. 
8 
foregoing pages numbered 319 to 495 are a true and 
cartel transcription of my shorthand into of said 
9 
THE WITNESS: And also to see if there was any 
a 
deposition. 
10 
Federal nexus pertaining to the case. 
10 
I further certify that aid deposition vein 
taken at the time and place hereinabove set forth and 
1 1 
BY MR. WEINBERG:
it 
that the taking of sad deposition was commenced and 
12 
Q. But you sought to determine if there was a 
completed as haeinabove set out. 
13 
Federal nexus relating to this case as a result of your 
12 
1 further certify that I am not an attorney or 
14 
disagreements with the charge decisions that were being 
13 
counsel crony of the parties, nee am I a relative a 
15 
made by.your State Attorney, correct? 
employee of any attorney a counsel of party connected 
14 
with the action, nor an I &mei* interested in the 
16 
MS. ARBOUR: Form. 
action. 
17 
• THE WITNESS: I believe so. 
15 
The 
icaton of this transcript 
Lanny 
18 
MR WEINBERG: Why don't we Igo a break and 
16 
does not apply to 
reproduction of die same by any 
19 
have lunch. 
means unless under the direct °retro] and/or direction 
20 
17 
:u 
of the catifying reporter. 
21 
MR. WEINBERG: 
as 
Dated this lath ft , of May, 2010. 
22 
(A luncheon recess was taken.) 
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Page 497 
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CERTIFICATE OF OATH 
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STATE OF FLORIDA 
3 
COUNTY OF PALM BEACH 
4 
5 
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I, the undersigned authority, certify that 
7 
JOSEPH RECAREY pctsonally appeared before Inc and was 
8 
duly sworn on the 27th day of April, 2010. 
9 
10 
Witness my hand and official seal this 27th 
11 
day of April, 2010. 
12 
13. 
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15 
C --j..40 
16
Jeana Ricciuti, RPR, PPR,ter
17 
Notary Public - State of Florida 
My Commission Expires: 2/17/2013 
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My Commission Na: DD 854778 
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496 to 498) 
PROSE COURT REPORTING 'AGENCY, INC. 
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Electronically signed by Jeans Ricciuti(601M) 
Electronically signed by Jeana RIcclutl (601 
c5062637-abel-452c-a836-bc614e31447a 
EFTA00298258