EFTA00298293

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Page 205 
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BY MR. KUVIN: 
Q. And while they are looking at that one, 
let me ask you about the last one we were talking 
about which is Exhibit 6. Jean Luc Brunel, did you 
ever establish any, or did you ever determine 
whether there was any connection between Mr. Brunel 
and John Casablancas? Did that name ever ring a 
bell? 
A. No. I have heard of the modeling firm. 
Q. Eight. 
A. But, no, no connection. 
Q. That you were able to determine? 
A. Right. 
Q. Okay. With respect to Mr. Brunel, did you 
ever determine whether or not Mr. Brunel had ever 
stayed at Mr. Epstein's home on occasion? 
A. I can't recall. 
Q. Did you ever determine whether or not 
Mr. Brunel was present when any underage girls were 
performing sexual acts for Mr. Epstein? 
MR. PIKE: Form. 
THE WITNESS: Not that I'm aware of. 
BY MR. KUVIN: 
Q. Did you ever determine whether or not 
Mr. Brunel was, in fact, providing underage girls to 
Page 204 
1 
Mr. Epstein —
2 
MR. PIKE: Form. 
3 
BY MR. KUVIN: 
4 
Q. - for sexual activities? 
5 
MR. PIKE: Same objection. 
6 
THE WTINESS: Based on the phone message 
7 
it appears that it may be someone. 
8 
BY MR. KUVIN: 
9 
Q. Anything else other than Exhibit 6? 
10 
MR. PIKE: Wait one second. Move to 
11 
strike witness's last testimony as 
12 
nonresponsive, and then form to Mr. Kuvin's 
13 
follow-up question. 
14 
MR. KUVIN: You can answer. 
15 
'IRE WITNESS: Outside of the phone 
16 
message, no. 
17 
(Plaintiffs Exhibit No. 7 was marked for 
18 
identification.) 
19 
BY MIt KUVIN: 
20 
Q. All right. Let me show you what we have 
21 
marked as Exhibit 7. There appears to be three 
22 
messages regarding someone with the last name 
23 
Meister. Do you see those? 
24 
A. Yes. 
25Sfinesvho 
that was? 
PROSE COURT 
1 
A. No. 
2 
MR. KUVIN: This is what we'll mark as 8. 
3 
(Plaintiffs Exhibit No. 8 was marked for 
4 
identification.) 
5 
BY MR. KUVIN: 
6 
Q. All right. Take a look at what I've 
7 
marked as Exhibit 8 with two messages on the 
8 
right-hand side. Let me ask you about those for a 
9 
moment. Do you see one there from David 
10 
Copperfield? 
11 
A. Yes. 
12 
Q. What does it say in the text of the 
13 
message? 
14 
A. "Magic David called." 
15 
Q. Did you come to learn that this was, in 
16 
fact, David Copperfield the magician? 
17 
A. Yes. 
18 
Q. When you went through the phone message 
19 
pads did you find a number of messages from 
20 
Mr. Copperfield to Mr. Epstein? 
21 
A. Yes. 
22 
MR. PIKE: Form. 
23 
BY MR. KUVIN: 
24 
Q. Did you become aware during the 
25 
investigation that Mr. Copperfield was, in fact, 
Page 206 
1 
charged with raping a girl? 
2 
MIt PIKE: Form. 
3 
THE WITNESS: I recall reading through the 
4 
media that I know that they executed search 
5 
warrants either at his home or hotel room, one 
6 
or the other. 
7 
BY MR. KUVIN: 
8 
Q. Okay. Did you learn that prior to this 
9 
investigation or did that, is that something you 
10 
learned subsequent to this pending investigation? 
11 
MR. PIKE: Form. 
12 
THE WITNESS: It was during the 
13 
investigation. 
14 
BY MR. ICUVRsl: 
15 
Q. Did you ever have conversations with the 
16 
federal authorities about Mr. Copperfield that you 
17 
can recall? 
18 
A. Not that I can recall. 
19 
Q. Okay. Do you recall whether or not you 
20 
learned about the federal investigation regarding 
21 
Mr. Copperfield before or after the Feds took your 
22 
information of Mr. Epstein's investigation? 
23 
(Mr. Goldberger entered the deposition 
24 
room) 
25 
THE WITNESS: I want to saz it was just 
20 (Pages 203 to 206) 
REPORTING AGENCY, INC.. 
Electronically signed by cynthia hopkins (801 
Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
sa2a5ddb•fa81-41f6-b3b7-dcda51494142 
EFTA00298313

Page 207 
Page 209 
after. 
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MR. KUVIN: Okay. 
3 
THE WITNESS: Just after everything was 
4 
given to the FBI. 
5 
BY MR. KfJViN: 
6 
Q. Do you know whether or not the FBI 
7 
utilized any of the information that they may have 
8 
obtained from your investigation such as message 
9 
pads in the prosecution of Magician David 
10 
Copperfield? 
11 
A. I have no idea. 
12 
Q. Do you know whether or not Mr. Epstein and 
13 
Mr. Cooperfield were, in fact, sharing underage 
14 
girls for sexual acts? 
• 
15 
MR. PiKE: Form. 
16 
THE WITNESS: I do not know. 
17 
BY MR. KUVIN: 
18 
Q. Do you know whether or not Mr. Epstein and 
19 
Mr. Copperfield were, in fact, sharing information 
20 
about girls for sexual acts? 
21 
MR. PIKE: Form. 
22 
THE WITNESS: That 1 don't know. 
23 
BY MR. KUVIN: 
24 
Q. Did you ever interview Mr. Copperfield? 
25 
A. No. 
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MR. PIKE: Form. 
THE WITNESS: Not really. i didn't get 
involved in any of the political aspects of 
that. 
BY MR. KUVIN: 
Q. Okay. Do you recall ever having any 
conversations directly with Mr. Goldsmith about the 
Epstein case? 
.. 
A. No. 
MR. KUVIN: Okay. This is 10. 
(Plaintiffs Exhibit No. 10 was marked Ihr 
identification.) 
BY MR. KUVIN: 
Q. All right. Let me show you what we marked 
as Exhibit 10. There mars to be a message there 
from someone named 
Do you see that? 
A. Yes. 
Q. What's the date of that message? 
A. March, it looks Bice 19th of '05. 
MR. PIKE: Form. 
MR. KUVIN: What is wrong with the form? 
MR. PIKE: That's what the message pad 
says. Whether or not it came through or not, 
I'm not sure. 
MR. KUVIN: Okay. 
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Page 208 
Q. All right. 
MR. PiKE: May I see Exhibit 7? Just give 
me one second, Spencer, before you start. 
MR. KUVIN: Sure. 
MR. PiKE: Can i see 6? Thank you. 
MR. KUVIN: No problem. 
(Plaintiffs Exhibit No. 9 was marked for 
identification.) 
BY MR. KUVIN: 
Q. Here is 9. All right. Take a look at 
Exhibit 9. It appears to be a message there from 
Jerry Goldsmith. Do you see that? 
A. Yes. 
Q. Do you know who that is? 
A. He is a town resident. 
• Q. Do you know whether he ran for office in 
the Town of Palm Beach. 
• 
A. Yes, he did. He ran for mayor. 
Q. And during the deposition with Chief 
Reiter in this case, Chief Reiter testified that he 
had some communications with Mr. Goldsmith about 
Mr. Epstein. 
And my question to you is do you know 
anything about those conversations that may have 
taken lace? 
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Page 210 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. Okay. Could you take a look for me at 
Exhibit 1 which is the PC affidavit. 
A. Yes. 
Q. And tell us, if you would remind us again 
what was the date that the investigation of 
Mr. Epstein began? 
A. -March 15th. 
Q. Of? 
A 2005. 
Q. This message from 
occurred according 
to the document, occurred when? 
A. March 19th, 2005. 
Q. All right. And what was the message that 
was taken down and written on that phone message 
pad? 
A "She will be here at 4:00 p.m. but she needs 
to talk to you before that. Please call her back." 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. Did you ever come to learn what-
wanted to talk to Mr. Epstein about just days after 
the investigation began of him? 
A. No. 
21 (Pages 207 to 210) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (801 
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Page 213 
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MR_ KUVIN: This one is II. 
2 
(Plaintiffs Exhibit No. 11 was marked for 
3 
identification.) 
4 
BY MR. KUVIN: 
5 
Q. While they are looking at that, were these 
6 
message pads taken from Mr. Epstein's home during 
7 
the search warrant? 
8 
A. Correct. 
9 
MR. PIKE: Form. 
10 
BY MR. KUVIN: 
11 
Q. And what was done with them when they were 
12 
taken from his home? In other words once they were 
13 
taken into custody, what did you-all do with them? 
14 
A. We reviewed them for evidentiary purposes. 
15 
Q. Okay. 
16 
A. Provided the State Attorney's Office with a 
1.7 
copy; obviously, with the filing packet for the arrest 
18 
warrants, and eventually turned over to the FBI. 
19 
Q. Okay. All right. Take a lookat Exhibit 
20 
11. It appears to be a message from Jean Luc again. 
21 
Take a look at that message. 
22 
A. Okay. 
23 
Q. Did you ever determine whether or not 
24 
Mr. Epstein ever had any sexually transmitted 
25 
diseases? 
1 
A. April 1st, 2005. 
2 
Q. Had the investigation begun against 
3 
Mr. Epstein at that time? 
4 
A. Yes. 
5 
Q. Do you know why Mr. Goldsmith, did you 
6 
ever learn why Mr. Goldsmith was contacting 
7 
Mr. Epstein about a month after the investigation 
8 
began? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: No, I did not. 
11 
BY MR. KUVIN: 
12 
Q. .Did you ever get a chance to talk to 
13 
Mr. Goldsmith about the Epstein investigation at 
14 
all? 
15 
A. No, I did not. 
16 
MR. KUVIN: Exhibit 13. 
17 
(Plaintiffs Exhibit No. 13 was marked for 
18 
identification.) 
19 
BY MR. KUVIN: 
20 
Q. Let me show you Exhibit 13. Does that 
21 
appear to be another message by Mr. Goldsmith on 
22 
that message pad? 
23 
A. Correct. 
24 
Q. What is the date of that message? 
25 
MR. PIKE: Form. 
Page 212 
1 
MR. PIKE: Form. 
2 
THE WITNESS: I was not aware. 
3 
BY MR. KUVIN: 
4 
Q. Okay. Let me take a look real quick at 
5 
Exhibit 11. There was something in this note that 
6 
talks about Mr. Jean Luc speaking to a doctor about 
7 
symptoms which can shorten your sex life. Did you 
8 
see that in the message? 
9 
A. Yes, I did. 
10 
MR. PIKE: Form. 
11 
BY MR. KUVIN: 
12 
Q. Were you ever able to determine what he 
13 
was talking about in that. message? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: No. 
16 
MR. KUVIN: All right. Exhibit 12. 
17 
(Plaintiff's Exhibit No. 12 was marked for 
18 
identification.) 
19 
BY MR KUM: 
20 
Q. Does this appear to be more messages from 
21 
Mr. Goldsmith? 
22 
A. Correct 
23 
Q. Are those dated at all? 
24 
A. One is and one is not. 
25 
O. What was the date of the one that is? 
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16. 
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Page 214 
THE WITNESS: 12/4/04. 
BY MR. KUVIN: 
Q. This was before the investigation began? 
A. Coffees. 
Q. And Exhibit 14, while they are looking at 
that, did you also find that them were messages 
from Mr. Leslie Wexner contained within the message 
pad at Mr. Epstein's home? 
A. Yes. 
Q. Did you come to learn who that was? 
A. Yes 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. Who? 
MR. PIKE: Form. 
THE WITNESS: He is the CEO of Express, 
Victoria Secrets. 
BY MR. KUVIN: 
Q. Okay. Did you ever get a chance to 
interview Mr. Wexner? 
A. No. 
MR. KUVIN: Exhibit 14. 
(Plaintiffs Exhibit No. 14 was marked for 
identification.) 
22 (Pages 211 to 214 
(561) 83277500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
Electronically signed by cynthia hopkins (601 
ea2a5ddb-fa81.4n6-b3b7-dcda51494142 
EFTA00298315

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1 
BY MTh KUVIN: 
2 
Q. Take a look at 14. Okay. Does that 
3 
appear to be a another message from Mr. Goldsmith? 
4 
A. Correct. 
5 
Q What is the date of that message? 
6 
A. The date of the message is 12/14/04. 
7 
Q. Prior to the beginning of the 
8 
investigation? 
9 
A. Correct. 
10 
(Plaintiffs Exhibit No. 15 was marked for 
11 
identification.) 
12 
BY MR. KUVIN: 
13 
Q. Let me take a look at that real quick. I 
14 
would like you to take a look at what we have marked 
15 
as Exhibit 15 at the top right message. Do you see 
16 
that? 
17 
A. Yes, sir. 
18 
Q. AU right. Who does that message purport 
19 
to be from? 
20 
A. Jean Luc. 
21 
Q. And we talked before about Jean Luc. Did 
22 
you come to learn during your investigation whether 
23 
or not he had or worked with a modeling agency? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: I believe so, ma which was 
Page 216 
1 
the modeling agency. 
2 
BY MR KUVIN: 
3 
Q. Okay. Did you ever learn why the name . 
4 
?Apr 
5 
MR. PIKE: Form. 
6 
THE WITNESS: No. 
7 
:BY MR. KUVIN: 
8 
Q. Okay. Mr. Epstein's initials are 
9 
• obviously E, right? 
10: 
A. Yes. 
13. 
Q. Okay. Do you know what E equal ma means? 
12 
Did you ever hear that phrase before? 
13 
A. Yes. 
14 
Q. Okay. Now, with respect to the message in 
15 
the top-right corner of Exhibit 15, what is the 
16 
content of the message there? 
17 
MR. PIKE: Form. 
18 
THE WITNESS: It says LC2models.com; 
19 . 
MC2models can was already taken. 
20 
BY MR.1CUVIN: 
21 
Q. Okay. Do you know whether or not Jean Luc 
22 
was working on his modeling agency with Mr. Epstein? 
23 
MR. PIKE: Form, speculation. 
24 
BY MR. KUVIN: 
25 
Q. In other words whether they were partners 
2: 
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in the operation of the modeling agency? 
A. That I don't know. 
MR. PIKE: Form. 
. 
MR. KUVEN: Okay. Let's mark 16. 
(Plaintiffs Exhibit No. 16 was marked for 
identification.) • 
BY MR. KUVIN: 
Q. Take a look at Exhibit 16. 
A. Yes. 
Q. What is the date of the message according 
to the pad? 
A. 12/9/04. 
Q. Before the investigation began? 
A Correct. 
Q. When you were conducting the investigation 
of Mr. Epstein and interviewing all of these girls 
that you interviewed; did you learn of events, of 
any events that were occurring involving underage 
girls going back into 2004 and 2003? 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. In other words did all these events that 
were described in the probable cause affidavit occur 
in 2005 or did they occur prior to that? 
A. They occwred prior to that. 
Page 218 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. Okay. So, is it safe to say that when 
Mr. Goldsmith is calling Mr. Epstein in roughly 
December of 2004, that that period of time is within 
the time frame that some of the girls described that 
Mr. Epstein was bringing underage girls to the 
house? 
MR. PIKE: Form. 
• 
THE WITNESS: anted. 
BY MR. KUVIN: 
Q. Did you ever come to learn whether or not 
Mr. Goldsmith was at Mr. Epstein's home when 
underage girls were there? 
MR. PIKE: Form. 
THE WITNESS: That never came up. 
BY MR. KUVIN: 
Q. Okay. Did you ever come to learn why 
Mr. Goldsmith was calling Mr. Epstein so much —
MR: PIKE: Form. 
MR. KUVIN: During this period of time 
from December through March. 
MR. PIKE: I'm sorry. 
BY MR. KUVIN: 
Q. - from December through Marc h of 2004 and 
23 (Pages 215 to 218) 
. "(561) 832-750.0 
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Electronically signed by cynthia hopkins (601 
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Page 221 
1 
2005? 
. 2 
MR. PIKE: Fomi. 
3 
THE WITNESS: No. 
4 
(Plaintiffs Exhibit No. 17 was marked for 
5 
identification.) 
6 
MR. KUVIN: Let's take a look at 17. 
7 
MR. PIKE: Can I see that for a second? 
8 
BY MR. KUVIN: 
9 
Q. Exhibit 17. 
10 
A. She may be gone. 
11 
MR. PIKE: Kathy, are you gone? 
12 
BY MK KUVIN: 
13 
Q. Looking at Exhibit 17, does it appear that 
14 
there was another message from Mr. Goldsmith? 
15 
A. Yes, sir. 
16 
Q. What was the date of that one? 
17 
MR. PIKE: Form. 
18 
THE WITNESS: January 9th, 2005. 
19 
(A discussion was held off the record.) 
20 
MR. KUVIN: Okay. Let's take a look at 
21 
Exhibit 18. 
22 
(Plaintiffs Exhibit No. 18 was marked for 
23 
identification.) 
24 
BY MR. KU-VW: 
25 
Q. Let me take a quick look and see why I was 
Page 220 
1 
asking about that one. There is a massage there on 
2 
the left from David Copperfield. Do you see that? 
3 
MR. PIKE: Forth. . 
4 
171E WITNESS: Yes, sir. 
5 
BY MR. KUVIN: 
6 
Q. What's the content of the message? 
7. 
MR. PIKE: Form. 
THE WITNESS: "It's Jackpot." 
9 
BY MR. KUVIN: 
10 
Q. It's Jackpot, correct? 
11 
A. Yes, sir. 
12 
Q. Did you ever come to learn what that might 
13 
be referring to? . 
14 
A. No. 
15 
Q. What's the date of that message? 
16 
A. January 22nd, 2005. 
17 
MR. PIKE: On the pad. 
18 
BY MR. KUVIN: 
• 
19 
Q. According to the pad, correct? 
20 
A. Yes, sir. 
21 
MR. KUVIN: Okay. 19. 
22 
(Plaintiffs Exhibit No. 19 was marked for 
23 
identification.) 
24 
MR. KUVIN: Let me take a look at it. 
25 
THE WITNESS: Yes. sir. 
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BY MR. KUVIN: 
Q. Mere are two of them I wanted to ask you 
about. The bottom left corner, it's another message 
from Mr. Goldsmith, correct? 
A. Yes, sir. 
Q. What's the date of that —
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. — according to the message pad? 
A. According to the pad it states January 25th, 
2005. 
Q. And the message to the right, do you see 
that? 
A. Above it? 
Q. To the right. 
A. To the right. 
Q. Do you see how there is a section that 
appears to be whited out? 
A. Yes, sir. 
Q. Do you remember whether or not the 
original of that actually had someone's name there? 
A. It might have. We — I didn't white anything 
out. 
Q. Do you know if the State Attorneys may 
have whited stuff out? 
MR. PIKE: Form. 
THE WITNESS: It's possible. 
MR. KUVIN:. Okay. 
(Plaintiffs Exhibit No. 20 was marked for 
identification.) 
MR. KUVIN: 20. You can put that with the 
rest. 
MR. PIKE: I think Mr. Edwards wanted to 
take a look at that. 
MR. KUVIN: Do you want to see this? 
(Telephone interruption.) 
MR. KUVIN: We kept going, sorry. 
MS. EZELL: No, I want you to. I'm sony. 
My phone is just copping out today. 
MR. KUVIN: That's all right We're still 
going. 
MS. EZELL: Good. 
MR. KUVIN: Take a look at what we have 
marked as Exhibit 20. 
THE WITNESS: Yes, sir. 
BY MR. KUVIN: 
• 
Q. All right. In the top right corner there 
is a message there. Could you tell us what that 
message according to the pad is?
R.
MR. PIKE: Form. 
Page 222 
I 
24 (Pages 219 to 222) 
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1 
THE WITNESS: The top right coma is a 
2 
message from the Duchess of York. 
3 
MR. PIKE: Kathy, can you hit mute on your 
4 
phone? 
MS. EZELL: I can't on this one. I'm 
6 
going to another room. 
7 
MR. KUVIN: All right 
8 
MS. EZELL: Okay. 
9 
BY MR. KUVIN: 
10 
Q. And the date on that message is what? 
11 
A. January 25th, 2005. 
12 
Q. And is there a number left there? 
13 
A. Yes. 
14 
Q. And what's the content of the message? 
15 
• 
A. She's expecting your call. 
16 
Q. Did you ever come to learn why the Duchess 
17 
of York may be contacting Mr. Epstein? 
18 
A. No. 
19 
MR. KUVIN: rn show you what we'll mark 
20 
as Exhibit 21. 
21 
(Plaintiffs Exhibit No. 21 was marked for 
22 
identification.) 
23 
BY MR. KUVIN: 
24 
Q. If you take a look at Ethibit 21, message 
25' 
on the bottom. It looks like the person who it came 
Page 224 
1 
from has been deleted, but is there a date on there? 
2 
A. Yes, sir. 
3 
Q. What's the date according to the pad? 
4 
A. According to the pad it states 1/29/05. 
5 
Q. And what is the content of the message at 
6 
the bottom there? 
7 
A. I have 2 females for him. 
8 
MR. PIKE: May I see that? 
9 
THE WITNESS: Yes, sir. 
10 
MR. PIKE: I believe that that 
11 
mischaracterizes the language of the exhibit 
12 
Just for purposes of the record, it says: I 
13 
have a female for him. 
14 
THE WITNESS: A? 
15 
MB. PIKE: There is no Son female. 
16 
BY MR. KUVIN: 
17 
Q. Take a look. Do you agree with that? 
18 
MR. PIKE: There is still a form objection 
19 
to the question, so I am not waiving„ and I am 
20 
just correcting the language of the exhibit 
21 
because it's clear there is no S on the end of 
22 
the word female to make it plural. 
23 
MR. KUVIN: And it uses the singular A if 
24 
you wanted to be grammatically correct about 
25 
it. I don't know. It could be a 2 or it could 
1 
be an A. 
2 
BY MR. KUVIN: 
3 
Q. Can you tell whether or not ifs the 2 or 
4 
the letter A? 
5 
A. It looks like a 2 that I would write so... 
6 
Q. Okay. 
7 
A. I don't know. 
MR. KUVIN: All right. Fair enough. 
9 
We'll let the document speak for itself on that 
10 
issue. Let me show you what we'll mark as 22. 
11 
(Plaintiffs Exhibit No. 22 was marked for 
12 
identification.) 
13 
BY MR. KUVIN: 
14 
Q. 22 appears to be any additional messages 
15 
according to the pad for Mr. Goldsmith. 
16 
A. Yes. 
17 
Q. Is it Goldsmith or Goldberg? I've 
18 
forgotten now. 
19 
A. Goldsmith. 
20 
Q. Goldsmith, thank you. All right. At some 
21 
point last year did you come to learn — well, let 
22 
me back up. Eventually did you come to learn that 
2 3 
Mr. Epstein pled guilty to certain charges —
24 
A. Yes. 
25 
Q. — criminal charges — 
Page 226 
1 
A. Yes, sir. 
2 
Q. — against him where he was put in jail 
3 
fora period of time? 
4 
A. Yes, sir. 
5 
Q. And after that point in time, did you conic 
6 
to leant that he was on supervised release with 
7 
probation? 
8 
MR. PIKE: Fenn. 
9 
THE WITNESS: Yes, sir. 
10 
BY MR. KUVIN: 
17. 
Q. And did you come to leant the terms of 
12 
that probation; in other words what he could or 
13 
could not do as far as the community control was 
14 
concerned? 
15 
A. I believe it was house arrest. 
16 
Q. All right_ At any time that you can 
17 
recall in 2009, did you cornett:deem that 
18 
Mr. Epstein was not at his house? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: Yes. 
21 
BY MR. KUVIN: 
22 
Q. Tell me about that. 
23 
A. While driving in the Town of Palm Beach down 
24 
along South Ocean Boulevard, I saw Mr. Epstein and his 
25 
bodyguard walking along South Ocean Boulevard along, 
PROSE COURT REPORTING 
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1 
along South Ocean Boulevard. 
2 
Q. All right. Did you notify Captain Frick? 
3 
A. I notified my supervisor, Sergeant Silvestri 
4 
who was with Captain Frick at the time. 
5 
Q. Okay. Did you take any photographs of 
6 
Mr. Epstein when you saw him? 
7 
A. Yes, sir, I did. 
8 
MR. KUVIN: All right. Let's go ahead and 
9 
well mark Exhibits 23 and 24. 
10 
(Plaintiff's Exhibit No's 23 and 24 was 
11 
marked for identification.) 
12 
BY MR. KUVIN: 
13 
Q. All right. Take a look at what we have 
14 
marked as 23 and 24. Are those copies of 
15 
photographs that you took? 
16 
A. Yes, sir. 
17 
Q. All right. Do those photographs show 
18 
Mr. Epstein as you saw him that day? 
19 
A. Yes. 
20 
Q. And where did you see him? 
21 
A. This was taken in the area of Australian 
22 
Avenue and South Ocean Boulevard. 
23 
Q. Okay. South Ocean Boulevard being along 
24 
the ocean? 
25 
A. Yes. Asa matter of fact I was standing right 
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 
MR. PIKE: Form. 
MR. KUVIN: — on that day? 
MR. PUCE: Form. 
THE WITNESS: I believe he stated he was 
walking to work. 
BY MR. KUVIN: 
Q. Do you knovv how far it is from 
Mr. Epstein's home on El Brillo way to the building, 
we're at today where he supposedly has an office? 
A. I'd have to say several miles. 
Q. Is Ocean Drive in the direction of his 
house and this building here? 
A. No. 
Q. Is it, in fact, in the opposite direction 
towards the ocean? 
A. Yes. 
Q. And Mr. Epstein's home is on the Bay? 
A. On the Intracoastal side. 
Q. Gotcha. Based on where you saw 
Mr. Epstein walking, did you believe that this was a 
violation of his probation? 
MR. PIKE: Form. 
THE WITNESS: That's what I had thought 
which is why I notified my supervisor. 
Page 228 
1 
on the ocean wall when this one was taken. 
2 
Q. That one being 24? 
3 
A. Correct. 
Q. Did Mr. Epstein see you taking the 
5 
photographs as far as you know? 
6 
A. I have no idea. 
7 
Q. Okay. Was there a memorandum to the town 
8 
that was issued as a result of this incident? 
9 
A. I know that Captain Frick spoke with 
10 
Mr. Epstein at Clark and South Ocean, Clark Avenue and 
11 
South Ocean in the Town of Palm Beach. And I understand 
12 
that Captain Frick spoke with, I don't know her fast 
13 
name, but 1 know her last name is Sloan (phonetic). 
14 
Q. Okay. 
15 
A. From the Department of Corrections. 
16 
MR. PIKE: Form. 
17 
MR. KUVIN: Okay. 
18 
BY MR. KUVIN: 
19 
Q. Did you come to team - 
20 
' MR. PIKE: Sony, Spencer, I want to get 
21 
form to that. It's kind of like a race between 
22 
question and answer. So form to that one. 
23 
BY MR. KUVIN: 
24 
Q. Did you come to learn what excuse 
25 
Mr. Epstein gave for being along Ocean Drive --
Page 230 
1 
(Plaintiffs Exhibit No. 25 was marked for 
2 
identification.) 
3 
BY MR. KUVIN: 
4 
Q. All right. Let me show you what we have 
S 
marked as Fathibit 25. 
• 
6 
MR. PIKE: Wait a second. Did you fmish 
7 
your response? 
8 
THE WITNESS: Yes. 
9 
BY MR. KUVIN: 
10 
Q. While they are looking at that, do you 
11 
know how far Mr. Epstein's home is from any church 
12 
or school? 
. 
13 
MR. PIKE: Fonn. 
14 
THE WITNESS: Ifs over a thousand feet. 
15 
I blow that. 
16 
BY MR. KUVIN: 
17 
Q. Do you know what the closest church or 
18 
school is in that area of the island? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: The school would be, the 
21 
closest school would be Crippled Children's 
22 
Society which is on Royal Palm Way. The church 
23 
would be Bethesda by the Sea. 
24 
MR. KUVIN: Okay. 
25 
THE WITNESS: Which is further, even 
26 (Pages 227 to 230 
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2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 
BY MR. KUVIN: 
2 
Q. Okay. Are there any additional 
3 
conversations that you can recall having withM 
4 
that we haven't already discussed? 
5 
We've recounted two conversations that you 
6 
can recall with her. 
7 
A. Right. 
8 
Q. One is at the school where we talked about 
9 
where she broke down. The second one is when she 
1o.• 
explained to you the circumstances that you had in 
11 
the probable cause affidavit. I was wondering if 
12 
there was anything else. 
13 
MR. PIKE: Form, move to strike. 
14 
THE WITNESS: I spoke, 1 believe, briefly 
15 
with her father. I delivered a letter to her 
16 
home and hand delivered it to her father. 
17 
BY MR. KUVIN: 
18 
Q. • And what was that letter? 
19 
A. It was letter drafted by former Chief Reiter. 
20 
Q. What did it discuss? 
21. 
A. It was a letter — 
22 
• 
MR. PIKE: Form. 
23 
THE WITNESS: — that he had generated to 
24 
the parents of the victims. 
25 
illaNACEISaaa•MKAMA 
PROSE 
further north. 
BY MR. KUVIN: 
Q. Further north. Do you know if part of his 
conviction as a sexual offender prevents him from 
being a certain distance from schools or churches? 
MR. PIKE: Form. 
THE WITNESS: I believe so. But his 
residence is within compliance. 
BY MR. KUVIN: 
Q. Okay. During your investigation, while 
they are still looking at that, did you ever speak 
with a girl by name of 
that you can recall? 
A. No. 
Q. Did you ever discuss with, all of the 
girls that she may have brought? 
you ever have 
a chance to get into that conversation with her? 
MR. PIKE: Form. 
THE WITNESS: Obviously I asked that same 
question to everyone I interviewed. 
MR. KUVIN: Right. 
THE WITNESS: Some girls I was able to 
identify. And other girls I couldn't identify. 
The name was so common I couldn't pinpoint, 
but, no, the name does not ring a bell. 
Page 232 
1 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
BY MR. KUVIN: 
Q. Do you remember the content of that 
letter, generally what it said? 
A. It was basically —
. MR. PIKE: Fonn. 
THE WITNESS: II minter looking at it. I 
looked it over prior to delivering them. It 
mentioned that the case would probably — this 
is after the grand jury, after the arrest 
MR. KUVIN: Right 
THE WITNESS: That the case would be 
referred to the FBI to see if there was any 
federal nexus to it. 
BY MR. KUVIN: 
Q. So this was after the referral to the FBI? 
A. Yes. 
Q. Befogsget back to Exhibit 25, just 
briefly again= that name in particular, do you 
know whether she was a part of any of the federal 
investigation? 
A. I have no idea. 
Q. All right If she was not
 of your 
investigation and not a part of the federal 
investigation, as you sit here today do you know 
whether or not additional charges may be brought 
Page 234 
1 
against
. Epstein based upon the acts alleged by 
2 
Ms.
3 
MR. PIKE: Form. 
4 
BY MR. KUVIN: 
Q. Do you know? 
6 
A. 'have no idea. 
7 
Q. Do you know what the Statute of 
8 
Limitations is for a sexual assault or a sexual 
9 
battery?' 
10 
A. I )(now under 12 there is no statute of 
11 
limitations, however — 
12 
Q. We're talking about 15. 
13. 
MR. PIKE: Form. 
14 
MR. KUVIN: With person over the age of 
15 
15. 
16 
MR. PIKE: Wait a second. I believe the 
17 
witness is attempting to respond. So if he has 
18 
a response, please less him respond and don't 
19 
inte.nupt him. 
20 
BY MR. KUVIN: 
21 
Q. Fair enough. I am looking for whether or 
22 
not you know the Statute of Limitations for the 
23 
prosecution fora person over 15. 
24 
A. I believe it's five years. 
25 
Q. Okay. Am I correct in sayinetaszou sit .,„ 
te 
27 (Pages 231 to 234) 
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here today you don't know whether or not 
was a 
2 
part of the ultimate nonprosecution agreement that 
3 
was entered into with Mr. Epstein and the federal 
4 
authorities? 
S 
. A. I have no idea. 
6 
Q. Okay. All right. Take a look at Exhibit 
7 
25. Let me ask you generally while you're looking 
8 
at that, have you ever seen that before today? 
9 
A. No. 
10 
Q. Then that's going to limit a lot of my 
. 
11 
questions. Do you appear anywhere in that summary 
12 
that you can tell? 
13 
MR PIKE: I am sorry, what exhibit number 
14 
is that? 
15 
MR. KUVIN: Twenty-five. 
16 
THE WITNESS: Twenty-five. 
17 
MR. PIKE: I just want the record to 
18 
reflect it. 
19 
BY MR. KUVIN: 
20 
Q. And I may have missed it, but I don't see 
21 • 
your name in there so — 
22 . 
• A. No, I don't see it in there either. 
23 
Q. Were you, in fact, the one, though, that 
24 
saw Mr. Epstein walking along Ocean Drive? 
25 
A. Yes, sir. 
Page 237 
1 
Q. Do you know if the U.S. Attorney's Office 
2 
has developed any additional new information with 
3 
respect to new charges to be brought against 
4 
Mr. Epstein? 
5 
A. I have no idea. 
6 
Q. Has anyone shared with you information 
7 
with respect to what the U.S. Attorney's Office may 
8 
have generated through conversations with 
9 
Mr. Rodriguez who just pled guilty? 
10 
A. No,J do not. 
11 
Q. • Do you know whether he cut a deal and gave 
12 
over additional information to the U.S. Attorney's 
13 
Office to bring additional charges against 
14 
Mr. Epstein? 
15 
A. No, sir. 
16 
Q. Are you aware of any girls that 
17 
Mr. Epstein has trafficked across state lines? 
18 
MR. PIKE: Form. 
19.. 
THE WITNESS: No,. sir. 
20 
BY MR. KUVIN: 
21 
Q. Are you aware of any young girls wider the 
22 
age of 18 that he may have brought onto his jets or 
23 
planes? 
24 
.MR. PIKE: Form. 
25 
THE WITNESS: No, sir. 
Page 236 
1 
MR. PIKE: Fonn, asked and answered. 
2 
BY MR. KUVIN: 
3 
Q. And you called it into your superior at 
4 
the time? 
5 
MR. PIKE: Asked and answered. 
6 
THE WITNESS: Correct 
7 
BY MR. KUVIN: 
8 ill
you know a woman by the name of 
at the State Attorney's office? 
10 
A.. Yes. 
11 
Q. Did you speak with her at the U.S. 
12 
Attomey's.Office about your investigation? 
13 
A. One time I spoke with her. 
14 
Q. Okay. Has she contacted you at all 
15 
recently? 
16 
A. No. 
17 
Q. Do you know whe 
an r w girls 
18 
have met with or spoken to 
with the 
19 
U.S. Attorney's Office? 
20 
MR. PIKE: Form. 
21 
THE WITNESS: Not that I am aware of 
22 
BY MR KUVIN: 
23' 
Q. Do you know whether B.B. has now spoken 
24 
and interviewed with the U.S. Attorney's Office? 
25 
A. Not that Pm aware of. 
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 238 
BY MR. KUVIN: 
Q. Okay. Do you know whether or not the U.S. 
Attorney's Office has that type of information one 
way or the other? 
MR. PIKE: Form. 
THE WITNESS: I have no idea. 
BY MR. KUVIN: 
Q. Okay. Do you know whether or not 
Mr. Epstein Ina a security company now working at 
his house called Wackenhut? 
A. Yes. 
Q. Do you know when they were retained? 
A Shortly, shortly after. his release from the 
county jail. 
Q. Okay.. 
A Or just prior to his release. One or the 
• other. 
. Q. During the search warrant, was any terminal 
used to chock for DNA throtighout the house? 
MR. PIKE: Form. • 
• 
THE WITNESS: Not 100 percent, not in the 
house. I believe the massage table. 
BY MR. KUVIN: 
Q. How were the massage tables checked? 
MR. PIKE: Fonn.
28 (Pages 235 to 238) 
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THE WITNESS: That you will probably have 
2 
to refer to Mr. Parkinson on that, Greg 
3 
Parkinson, 
4 
BY MR. KUVIN: 
Q. And he is who? 
6 
A. The manager at the crime scene unit. 
7 
Q. Okay. Do you know whether the FBI also 
8 
took video surveillance at all of Mr. Epstein? 
9 
Mk PIKE: Form. 
10 
THE WITNESS: I have no idea. 
11 
BY MR. KUVIN: 
12 
Q. Did any of the surveillance video that you 
13 
or your department took of Mr. Epstein show any of 
14 
the potential victims that are listed in your 
15 
probable cause affidavit? 
16 
MR. PIKE: Form. 
17 
THE WITNESS: The surveillance log, i 
18 
remember there were some people that were 
19 
interviewed because of their recent visits to 
20 
Mr. Epstein's home that appeared to be young 
21 
females. 
22 
BY MR. KUVIN: 
23 
Q. On the surveillance video? 
24 
A. Yes. Well, it would have been under the 
25. 
surveillance of either B.S.F. or surveillance video, one 
Page 241 
1 
Q. All right. What's beneath the blacked out 
2 
portions since you created this document, if you 
3 
know? 
4 
A. The names and cellular phone numbers of the 
5 
girls that were interviewed. 
6 
jail So, did you confirm that, in fact, 
7 
was calling some of the girls you 
8 
interviewed? 
9 
MR.PLICE: Form. 
0 
THE WITNESS: Yes. 
11 
MR. KUVIN: Let's mark this as 27. I 
12 
think 27 — I will have you explain it — is a 
13 
copy of the letter that you delivered that you 
14 
mentioned before to C.L. 
15 
(Plaintiff's Exhibit No. 27 was marked for 
16 
identification.) 
17 
BY MR. KUVIN: 
18 
Q. Take a look at Exhibit 27. Is that a copy 
19 
of the letter you hand delivered to C.L.? 
20 
MR. PIKE: Form. 
21 
THE WITNESS: That is correct. 
22 
BY M. KUVIN: 
23 
Q. Okay. All right, I think I am about done 
24 
but I just have to ask: Did you have anything to'do 
25 
with the incident involving Gerald() Rivera? 
Page 240 
or the other. 
1 
2 
Q. Who is Michelle Pagan? 
2 
3 
A. Michelle Pagan is an officer with the Town of 
3 
4 
Palm Beach Police Department. 
4 
5 
Q. That's right. I'm sorry. I forgot. 
5 
6 
(Plaintiffs Exhibit No. 26 was marked for 
6 
7 
identification.) 
7 
8 
BY MR. KUVIN: 
8 
9 
Q. Let's take a look at what's been marked as 
9 
10 
Exhibit 26, and if you could explain what this 
10 
11 
document is. Would you explain what that document 11 
12 
is, Exhibit 26? 
12 
13 
A. That was a document I created just to show 
13 
14 
der 
rs, either called in or called out 
14 
15 
from 
cellular phone. 
15 
16, 
Q. Okay. There are some things blacked out 
16 
17 
on there. Why are they blocked out? 
17 
18 
MR. PIKE: Form. 
18 
19 
BY MR. KUVIN: 
19 
20 
Q. Let me ask you this: Did you black them 
20 
21 
out? 
21 
22 
A. No, l did not. 
22 
23 
Q. Does the original of this document have 
23 
24 
that information on it? 
24 
25 
A. Yes. 
25_ at,
PROSE COURT REPORTING 
Page 242 
MR. PIKE: Form. 
THE WITNESS: No. 
BY MR. ICUVIN: 
Q. No. Did you come to team at any time 
that Gerald° Rivera was standing outside of 
Mr. Epstein's home --
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. And someone called 911? Did you hear 
about that? 
MR. PIKE: Form. . 
THE WITNESS: Iheard rumors about that in 
the police department, but no, I had no 
involvement or knowledge of that. 
BY MR. KUVIN: 
Q. Okay. Do you know if that occurred while 
he was in jail or after he had been released on 
house arrest? 
A. I have no idea.
. 
MR. KUVIN: Okay. All right. I 
appreciate it. That's all the questions I have 
at this time. 
MR. EDWARDS: Who is up? 
MR. PIKE: Take a quick break off the 
Jeard. Everybody agree? 
29 (Pages 239 to 242) 
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Page 245 
MR. EDWARDS: Yes. 
2 
(A brief recess was held.) 
3 
(Plaintiffs Exhibit No. 28 was marked for 
4 
identificatica.) 
5 
CROSS (DETECTIVE JOSEPH RECAREY) 
6 
BY MR. EDWARDS: 
7 
Q. Good afternoon, Detective. 
9 
A_ Good afternoon. 
9 
Q. I have just handed you what we have marked 
10 
as Plaintiffs Exhibit 28. And I will show it to 
11 
defense counsel. Have you seen that document 
12 
before? 
13 
A. Yes. 
14 
Q. What's the date on that? 
15 
A. 11/28/04. 
16 
Q What is that document? 
17 
A. The Palm Beach Police Department Intelligence 
18 
Report. 
19 
Q. What is an Intelligence Report? 
20 
A. It is a report that is generated by an officer 
21 
on any information received not deemed to be an incident 
22 
report; something for detectives to follow-up on. 
23 
Q. Okay. Who's the officer that was the 
24 
author of that report? 
25 
A. It would be Keith Munyan. 
Page 244 
1 
Q. And have you spoken with Keith Munyan, 
2 
fist question is about anything related to Jeffrey 
3 
Epstein or the investigation? 
4 
A. I know fora time there was a time where he 
5 
was on B.S.F., the Burglary Strike Force, that conducted 
6 
the surveillance. 
7 
Q. Okay. 
8 
A. But actual conversation with him regarding the 
9 
investigation, no. 
10 
Q. Did you ever have a conversation with 
11 
Officer Munyan at any time from the beginning of the 
12 
world until today about that particular report that 
13 
was authored in November of 2004? 
14 
A. No, I did not. 
15 
(Mr. Epstein entered the deposition room.) 
16 
BY MR. EDWARDS: 
17 
Q. From my understanding of the previous 
18 
testimony, the investigation of Mr. Epstein began 
19 
sometime in March of 2005 upon a telephone call by 
20 
some relative o1
21 
A. Correct. 
22 
Q. And it's also my understanding that your 
23 
testimony was it was your belief that that was the 
24 
first knowledge that the police department had of 
25 
possible interactions with underage girls by Jeffrey 
1 
Epstein; is that correct? 
2 
MR. PIKE: Form. 
3 
THE WITNESS: Knowledge to me. 
4 
MR. EDWARDS: Okay. 
5 
THE WITNESS: lam — as far as the police 
6 
department I have no idea when. Obviously this 
7 
was prior to the investigation; however, this 
8 
was not a public record report that was passed 
9 
around from officer to officer to officer. 
10 
MR. EDWARDS: All right. So —
11 
THE WITNESS: When this is evaluated by 
12 
the supervisor and submitted, this actually 
13 
goes to independent units. 
14 
BY MR. EDWARDS: 
15 
Q. And do you know what supervisor that 
16 
particular November, 2004 — what are we calling it 
17 
again? 
18 
A. Intelligence report 
19 
Q. Intelligence report. Do you know who the 
20 
supervisor would have been at the time? 
21 
A. It looks like it might have been at that point 
22 
Sergeant Maio. That looks like his initials. 
23 
Q. Is Sergeant Maio somebody that you have 
24 
had any conversations with related to the 
25 
investigation into Jeffrey Epstein? 
Page 246 
1 
A. No. 
2 
Q. All right. The first time that you saw 
3 
that particular report that you're looking at, 
4 
Plaintiffs Exhibit 28, do you remember when that 
5 
was? 
6 
A That would have been after my investigation 
7 
began. 
8 
Q. Okay. After your investigation began 
9 
which would have been September of 2005? 
10 
A Correct. 
11 
Q. Do you know if -- well, when you reviewed 
12 
all of the materials to catch yourself up to speed, 
13 
I believe you testified that that was initially done 
14 
by Officer Pagan? 
15 
A. Correct. 
16 
Q: When you reviewed all of the materials to 
17 
catch yourself up to speed with the investigation, 
18 
was that particular report included in those 
19 
materials? 
20 
A. No, it was not 
21. 
Q. So Plaintiffs Exhibit 28 is something 
22 
that was produced to you or shown to you sometime 
23 
after your investigation into Jeffrey Epstein began 
24 
in September of 2005? 
25 
A. Correct 
PROSE COURT REPORTING 
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1 
Q. And do you remember if it was before or 
2 
after the execution of the search warrant in October 
3 
of 2005 that you first saw that document? 
4 
A I don't know the exact date that I was shown 
5 
this document, but I )(now that I would have liked to 
6 
have it prior to my interview with the person that I 
7 
interviewed on this case. 
8 
Q. Are you talking about Jane Doe No. 103? 
9 
A. Correct. 
10 
Q. She's the person that was allegedly, 
11 
according to this report that's been marked as 
12 
Plaintiffs Exhibit 28, was at Jeffrey Epstein's 
13 
house in November of 2004? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: That is correct. 
16 
BY MR. EDWARDS: 
17 
Q. And from what I understand based on the 
18 
report, house manager Alfredo Rodriguez, calls the 
19 
police because of a suspicious vehicle in Jeffrey 
20 
Epstein's driveway? 
21 
MR. PIKE: Form. 
22 
THE WITNESS: Correct. 
23 
BY MR. EDWARDS: 
24 
Q. Officer Munyan is the one reporting to the 
25 
scene and finds Jane Doe No. 103. 
Page 244 
I 
tour. It might be just after the ending of their tom. 
2 
They're jotting information down. They provide it to 
3 
the supervisor. The supervisor then initials off on the 
4 
bottom of it. 
5 
And then it gets disseminated to what is 
6 
now the Organized Crime/Vice and Narcotics Unit. It 
7 
is the sergeants responsibility then of that unit 
8 
to disseminate it to other units depending on the 
9 
information provided. 
10 
Obviously, if it, if this contained 
11 
information on narcotics, it would stay with 
12 
Organized Crime/Vice, and Narcotics. If it had 
13 
information on gypsy thefts, it would go to the 
14 
detective bureau. If it had an officer safety 
15 
information, you know, I stopped a kid and he had a 
16 
necklace with a, if you pulled it apart and it 
17 
became a knife, then it would go to the entire 
18 
police department. 
19 
Q. Okay. And do you know how that document 
20 
was disseminated or to which department it went? 
21 
A. This was disseminated to the Organized 
22 
Crime/Vice and Narcotics Unit. 
23 
Q. Why is that? 
24 
A. I don't know. 
25 
MR. PIKE: Form. 
Page 248 
1 
A. Correct. 
2 
MR. PIKE: Form. 
3 
BY MR. EDWARDS: 
4 
Q. Then you read the officer's comments 
5 
within the report about, you know, what muscle is 
6 
she massaging. And maybe that's not a direct quote 
7 
but that's from memory. 
8 
Seems like there is some idea on his 
9 
behalf that something was going on inside the house 
10 
that may not be correct, is that right? 
11 
MR. PIKE: Form, move to strike, compound, 
12 
confusing, leading, speculative. 
13 
MR. EDWARDS: If you understand that bad 
14 
question, go ahead. 
15 
l'HE WITNESS: ft appears that he came up 
16 
with his own opinion. 
17 
BY MR. EDWARDS: 
18 
Q. Okay. And when a report like that is 
19 
drafted, and you say is it always turned ova to the 
20 
captain or the sergeant? 
21 
A. Usually when an officer completes an 
22 
intelligence report in the Palm Beach Police Department, 
23 
they give it to their direct supervisor or the next 
24 
oncoming shift supervisor. The intelligence report may 
25 
or may not be completed during their shift, during their 
zw•Yel•MI.ms.A.VIC4C.C..“ MVO.. 
•Yi•••••, :•, "., ....•••..S•b1•14[10•••••Saillia 
Page 250 
1 
THE WITNESS: I don't know. That was —
2 
the supervisor at that particular time kept it 
3 
within Organized Crime. 
4 
BY MR. KUVIN: 
5 
Q. Do you know if there was any internal 
6 
follow-up to that report done by the Palm Beach 
7 
Police Department? 
8 
MR. PIKE: Form. 
9 
THE WITNESS: Not that frn aware of. 
10 
BY MR. KUVIN: 
11 
Q. You have obviously seen that intelligence 
12 
report You have been presented with that 
13 
intelligence report sometime after your 
14 
investigation. Have you ever gone back to look was 
15 
there a follow-up to that report? 
16 
A. I did look to see if there was a follow-up on 
17 
that report, and there was not much of a follow-up done 
18 
on it. 
19 
Q. Did you see any follow-up that —
20 
A. I — 
21 
Q. —at all? 
22 
A. I believe that they attempted to contact 
23 
Ms. Jane Doe No. 103 several times with negative 
24 
results. 
25 
Q 
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7. 
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Page 251 
MR. PIKE: Form. 
BY MR. EDWARDS: 
Q. Is there any documentation memorializing 
those telephone calls?
MR. PIKE: Form. 
THE WITNESS: I don't believe so. 
BY MR. EDWARDS: 
Q. Why do you believe that they attempted to 
contact her with negative results? 
MR. PIKE: Form. 
THE WITNESS: Because the person that was 
assigned to this, I spoke with who is now 
sergeant, Sergeant 'Crawl. And he said he 
attempted to contact her on several times to 
discuss with her this case. 
BY MR. EDWARDS: 
Q. I don't know that I can put my finger on 
the exact document right now, but I believe I read 
something and Fm not sure if it was authored by 
you or Chief Reiter about information back as early 
as 2001 of young females frequenting Mr. Epstein's 
house. Do you recall seeing something like that? 
MR. PIKE: Form. 
THE WITNESS: Them may have been some 
information received. There may have been some 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
BY MR. EDWARDS: 
Q. Okay. So, 1 am just going to direct your 
attention to the document that is tabbed 2001 on 
Page 2. 
A. Correct. 
Q. So flip it to Page 2, and just read that 
paragraph that begins with the information in 2001. 
Okay? 
A. Okay. 
Q. Have you seen that information before? 
A. Like I said, I had heard that there was 
previous indications of young females frequenting the 
house, but it was my understanding that it was Palm 
Beach Atlantic college girls coming over. 
Q. And would there be a file with the Palm 
Beach Police Department related to any 
investigation, interviews, surveillance, or any 
other evidence that was discovered during that 2001 
investigation? 
A. Not that I am aware of. 
Q. It appears from reading that document that 
there were interviews taken, correct? 
MR. PIKE: Form. 
THE WITNESS: It appears. 
1 
2 
3 
4 
5 
6 
8 
9 
10 
11 
12 
13. 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25. 
Page 252 
information received as to females young in 
appearance visiting or frequenting 
Mr. Epstein's home earlier than that, but I 
believe that was deemed to be Palm Beach 
Atlantic College kids back then. 
BY MR. EDWARDS: 
Q. Okay. And as early as 2001 it was 
reported to the Palm Beach Police Department there 
were numerous young women visiting his residence. 
And you're testifying that those youth women, to the 
best of your knowledge, were determined to be 
college kids? 
MR. PIKE: Form. 
THE WITNESS: I believe so. 
BY MR. EDWARDS: 
Q. So, there were interviews taken into the 
• 2001 information that was delivered to the police 
department related to these young women, correct? 
MR. PIKE: Form. 
THE WITNESS: I'm not sure. 
MR. EDWARDS: All right. Might as well go 
ahead and use a couple of stickers that we have 
there. You might want to show him Page 2. 
3/28/02 is the date on this. 
Page 25 
1 
BY MR. EDWARDS: 
2 
Q. It also appears that there was 
3 
surveillance? 
4 
A. Correct 
5 
MR. PIKE: Fonn. 
6 
BY MR. EDWARDS: 
7 
Q. And thafs a document that's being 
8 
generated years later, correct? 
9 
MR. PIKE: Form. 
10. 
THE WITNESS: Yes, sir. 
11 
BY MR. EDWARDS: 
12 
Q. So, just based on your knowledge and 
13 
experience as a police officer or a detective, do 
14 
you have any idea where that information or evidence 
15 
would be kept or stored if at all? 
16 
A. I have no idea. 
17 
Q. Okay. If I wanted to find out related to 
18 
that specific incident, terntse I know we did a 
19 
Florida request, and I believe it was all 
20 
information related to Mr. Jeffrey Epstein. And for 
21 
the most part we only got information related to 
22 
this particular investigation that you were a part 
23 
of. 
24 
Is there some other designation that I 
25 
need to send to the Palm Beach Police 
nt to 
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Page 255 
1 
get information about a 2001 investigation? 
2 
MR. PIKE: Form. 
3 
THE WITNESS: I have no idea. You might 
4 
want to check with the custodian of records, 
5 
Laura Oregero. 
6 
BY MR. EDWARDS: 
7 
Q. Okay. And why do you believe that this 
8 
particular 2001 investigation related to college 
9 
students? 
10 
MR. PIKE: Form. 
11 
THE WITNESS: Because I recall, I recall 
12 
someone, and I can't, I don't know who exactly 
13 
stated that there was information years prior 
14 
of girls going to the house, but it turned out 
15 
it was all college girls coming to work for 
16 
Mr. Epstein at the residence. 
17 
MR. PIKE: Form, move to strike. 
18 
BY MR. EDWARDS: 
19 
Q. And are you aware of what these college 
20 
girls were doing in terms of work? 
21 
A. I have no idea. 
22 
MR. PIKE: Form. 
23 
BY MR. EDWARDS: 
24 
Q. All right. The term work and the term 
25 
matcnee has been used by you and many other 
1 
2 
3 
4 
5 
0 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 256 
witnesses in this particular case. And by that, by 
those terms is it your understanding that those 
terms refer to the scenario wherein Jeffrey Epstein 
pays underage girls to ;Amorally assault them? 
MR. PIKE: Form. 
THE WITNESS: As far as the case that I 
investigated, 05368, the girls referred to it 
as work. And when I asked, because i, in my 
interviews I asked them what do you mean work, 
and that's what they referred it to. 
BY MR. EDWARDS: 
Q. When you say that's what — I mean I was 
trying to shorten it because I have listened to you 
testify about many girls, the same scenario over and 
over again. But are we talking about — well, I 
will let you put it in your own words. 
When the girls said I am going to Jeffrey 
Epstein's house to work, what did they ultimately 
elaborate and tell you what that meant? 
. MR. PIKE: Form, move to strike, narrative 
and leading. 
THE WITNESS: Providing massages whether 
them being naked or partially clothed, and some 
obviously being fondled or touched. 
Page 257 
1 
BY MR. EDWARDS: 
2 
Q. Okay. And I believe you told us in your 
3 
background you worked in narcotics before? 
4 
A. Yes, sir. 
5 
Q. in narcotics specifically, are there code 
6 
words that are used related to criminal activity? 
7 
MR. PIKE: Form. 
8 
111E WITNESS: Yes. 
9 
MR. PIKE: Relevance. 
10 
BY MR. EDWARDS: 
11 
Q. When people talk over the telephone about 
12 
what kinds of drugs they are selling and things like 
13 
that, is it your training and experience that code 
14 
words are often used? 
15 
A. Correct 
16 
MR. PIKE: Form 
17 
BY MI!: EDWARDS: 
18 
Q. In this particular case regarding Jeffrey 
19 
Epstein, the words work and massage in your training 
20 
and experience, are those code words that were used 
21 
by Jeffrey Epstein and the other people working for 
22 
him? 
23 
MR. PIKE: Form. 
24 
-THE WITNESS: As far as I know the girls 
25 
all referred to it as work. I don't ;mow if 
Page 258 
1 
that is a specific code word. 
2 
BY MR, EDWARDS: 
3 
Q. Do you know where they learned that word 
4 
front? 
5 
MR. PIKE: Form. Were you finished with 
6 
your response? 
7 
THE WITNESS: Yes. 
8 
MR. PIKE: Okay. 
9 
THE WITNESS: NorI have no idea. 
10 
BY MR. EDWARDS: 
11 
Q. Well, you've looked at several message 
12 
pads today and the word work is used on those, 
13 
correct? 
14 
A. Correct. 
15 
Q. And those, that was not written by the 
16 
girls. Those are things that are written by Jeffrey 
17 
Epstein's assistants to the best of your knowledge; 
18 
is that correct? 
19 
A. Yes. 
20 
MR. PIKE: Form. 
21 
BY MR. EDWARDS: 
22 
Q. Regarding the message pads, were those 
23 
taken, were all the message pads taken at the same 
24 
time? 
25 
MR. PiKE: Form. 
(561) 832-7500 
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THE WITNESS: Yes. 
2 
BY MR. EDWARDS: 
3 
Q. And by taken i mean retrieved at the same 
4 
time? 
5 
A. During the search warrant. 
6 
Q. All right. Were any the message pads, and 
7 
that is what in reading the report I have had a 
8 
tough time deciphering, were some taken from the 
9 
trash pulls and some from the house or were they all 
10 
taken Ia the search.warrant? 
13. 
MR. PIKE: Form. 
12 
'THE WITNESS: The message pads were 
13 
double-sided. You would write the message onto 
14 
its pad.. The top layer would peal off 
15 
depending on who the message was for, and then 
16 
there would be a carbon copy kept underneath. 
17 
And the pads that you're seeing, the majority 
18 
of those messages were carbon copies. 
19 
BY MR. EDWARDS: 
20 
Q. And taken when? 
21 
A. During the search warrant. 
22 
Q. All right. Were any of the messages that 
23 
we have copies of taken from trash pulls where it's 
24 
the actual message that's been crumpled up and 
25 
thrown away? 
1 
2. 
• 3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 261 
during the investigation? 
A Correct. 
Q. So, if it came down to trial would it be, 
would you be the person that would be able to say 
this is a fair and accurate representation of what 
was taken into evidence at this particular time? 
MR. PIKE: Form.
THE WITNESS: Based on the trash pulls 
that I requested, that I conducted, yes, I 
would be the one. I could tell you I could see 
it, and that's the one that I put into 
evidence. 
• 
• 
BY MR. EDWARDS: 
Q. And with respect to the message pads that 
were retrieved during the search warrant, would you 
also be able to identify them and indicate whether 
they are a fair and accurate representation of what 
was taken into evidence? 
• 
• A. 'Yes. 
' MR PIKE: Form. 
THE WETNESS: Yes. 
BY MR. EDWARDS: 
Q. And not only with respect to the message 
pads, but with all the evidence that is listed on 
your property receipt, assuming that one day we get 
Page 260 
1 
MR. PIKE: form. 
2 
THE WITNESS: Correct. 
3 
MR. PIKE: You're talking about messages. 
4 
Are you talking about the 2-inch stack of 
5 
documents that Mr. Kuvin earlier showed the 
6 
witness? And I am not talking, Mr. Kuvin 
7 
MR. EDWARDS: The format is similar to 
8 
that. 
9 
MR PIKE: Mr. Kuvin has already agreed to 
10 
produce them to us. Ifs not a trick. I just 
11 
want to understand what we're talking about. 
12 
Is it those message pads? 
13 
MR. EDWARDS: Right 
14 
BY /vfR. EDWARDS: 
15 
Q. Are those the message pads that you were 
16 
referring to? 
17 
A. Yes. 
18 
Q. I want to make sure that we're on the same 
19 
page. Were communicating. 
20 
A. But to answer your previous question from the 
21 
trash pulls, we did obtain originals, the top layer of 
22 
the message. 
23 
Q. Okay. And when documents, any papers, any 
24 
documents were retrieved from trash pulls and taken 
25 
into evidence, were those taken into evidence by you 
Page 262 
1 
to see the evidence, would you be the one to 
2 
identify it? 
3 
A. Yes. 
4 
MR. PIKE: Porta 
5 
BY MR. EDWARDS: 
6 
Q. And I know you have testified that the FBI 
7 
took possession of all of the documents and items 
8 
that are listed in the property receipt, right? 
9 
A That is correct? 
10 
. MR. PIKE: Form. 
11 
BY MR. EDWARDS: 
12. 
Q. Did you or your department — 
13 
A.. Let me, let me correct that. 
14 
'Mar. 
15 - 
A. The items that were returned to Janusz had 
16 
nothing to with the FBI. That was determined that he 
17 
was the rightful owner of the items collected, and that 
18 
was !chimed back to him and it contained no contraband 
19 
or any kind of images or anything like that. 
20 
Q. No evidence of any criminal activity that 
21 
you could tell? 
. 
22 
A Correct 
• • 
23 
MR. PIKE: Form. 
24 
BY MR. EDWARDS: 
...m."22_
2:_!......Sumn
o with 
to 
items 
TLI.LtaLIA2re 
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determined to be evidence and listed on the property 
2 
receipt, and just so that we're clear, the documents 
3 
that were not Janusz Banasiak, did you or your 
4 
office make any copies of any of that material? 
5 
A. No, because I actually signed out the message 
6 
pads to review them. I know that the State Attorney's 
7 
Office was provided a copy with the filing packet. 
8 
Q. Okay. Do you know approximately -- well, 
9 
not approximately. Do you know how many messages, 
10 
how many message squares were retrieved or how many 
11 
pages from the message pads were retrieved during 
12 
the search warrant? 
13 
MR. PIKE: Form. 
14 
THE WITNESS: I couldn't give you an 
15 
accurate number. I know some were. 
16 
BY MR. EDWARDS: 
17 
Q. More than one message pad? 
18 
A. As far as carbon copies are concerned? 
19 
Q. Right. 
20 
A. The carbon copies, there were several books 
21. 
taken. 
22 
Q. That's what I am asking. 
.23 
A. There were several books taken. If you look 
24 
at the property receipt, it will say phone message book, 
25 
phone message book and the location where it was taken 
1 
2 
3 
4 
5 
6 
8
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 265 
A. No. 
MR. PIKE: Form. 
BY MR. EDWARD& 
Q. Were you aware of any of donations that he 
has ever made? 
A. I recall a donation he made to purchase 
equipment, video enhancing equipment shortly thereafter 
that case. 
Q. Okay. Are you aware of a 550,000 donation 
back in 2002 by Mr. Epstein that was delivered 
personally to Chief Reiter by Gerald Goldsmith? 
A. No. 
Q. Has anybody ever made you aware that he 
donated $50,000 to the Palm Beach Scholarship fund 
April 1st, 2002? 
MR. PIKE: Form. 
THE WITNESS: No. 
BY MR. EDWARDS: 
Q. Has anybody ever made you aware that he 
donated $36,000 to the purchase of a forensic video 
analysis system in October of 2003? 
A. That, that was the —
MR. PIKE: Form. 
THE WITNESS: — video enhancing 
equipment 
Page 264 
1 
from. 
2 
Q. Okay. The way that they have been 
3 
presented to us, at least the copies, are four per 
4 
page. Is that how it appears on the book? 
5 
A. Yes. 
6 
Q. When is the first time that you had any 
7 
contact with Jeffrey Epstein? 
8 
A. I met Mr. Epstein during an investigation 
9 
where someone had broken into his home and stolen money 
10 
and I believe a firearm. And, ifl recall, I came over 
11 
to assist other detectives to install a covert camera in 
12 
hopes to catch the person breaking into the house. 
13 
Q. Okay. And I have seen that report 
14 
somewhere. And 1 think that will take a long time 
15 
to get into, and I don't believe we have that much 
16 
time, but that was sometime in 2003; is that 
17 
correct? 
18 
A. That's correct. That's the fast time I met 
19 
Mr. Epstein. 
20 
Q. Had you heard of him or known of him prior 
21 
to that time? 
22 
A. No. 
23 
Q. All right. Arc you aware of various 
24 • 
donations that he has made to the Palm Beach Police 
25 
over the years? 
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 266 
BY MR. EDWARDS: 
Q. Okay. That's what you were just talking 
about? 
A. Yes, sir. 
Q. And these donations, when they have been 
made, is it your understanding that they are made 
through a company owned or controlled by Jeffrey 
Epstein, COUQ Foundation, Inc.? 
MR. PIKE: One second. Can you repeat 
that for the record? 
MR. EDWARDS: Sure. 
BY MR. EDWARDS: 
. 
. 
• 
Q. When the donationthat you're aware of was 
made, was it your understanding that it was made 
through the COUQ Foundation, Inc., a company 
controlled by Jeffrey Epstein? 
MR. PIKE: Form. 
THE WITNESS: I have no idea. 
BY MR. EDWARDS: 
Q. When these donations are made, who 
receives the donation? 
• 
A. The chief or the town manager. 
. 
Q. Okay. So if the chief is the one writing 
letters thanking Mr. Epstein, the chief would be the 
best person to ask about these donations? 
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A. Correct 
2 
Q And in terms of how the records are kept, 
3 
copies of the checks and things ince that, that's 
1 
something for a record custodian or the chief, not 
5 
for you? 
6 
A. Not forme. Tints way above my pay grade. 
7 
Q. We talked about this November 2004 report. 
8 
You were not aware of that until sometime in 2005 or 
9 
2006, correct? 
10 
MR. PIKE: And for the record yotfre 
11 
talking about Exhibit 28, right? 
12 
THE WITNESS: Exhibit 28. 
13 
MR EDWARDS: I believe so. 
14 
BY MR. EDWARDS: 
15 
Q. Were you made aware that December, 
16 
December 14th, 2004, 15 or 16 days after that report 
17 
is generated, Jeffrey Epstein donates $90,000 for an 
18 
electronic firing range technology? Were you aware 
19 
of that? 
20 
A. No. 
21 
MR. PIKE: Form. 
22 
BY MR. EDWARDS: 
23 
Q. Do you know who it is that Jeffrey Epstein 
24 
talks to, if anybody, within the Palm Beach Police 
25 
Department back in 2004 to ultimately donate money? 
Page 269 
1 
over the telephone prior to your investigation that 
2 
began in September of 2005? 
3 
MR. PIKE: Form. 
4 
THE WITNESS: No. Like I said, l may have 
5 
introduced myself to him when I came over to 
6 
assist to install the camera during the 
7 
burglary investigation, but other than that... 
8 
BY MR. EDWARDS: 
9 
Q. When you first arrived to the house back 
10 
in 2003 related to the burglary, were there already 
11 
cameras in place? 
12 
MR. PIKE: Form. 
13 
THE WITNESS: I do not believe so. 
14 
BY MR. EDWARDS: 
15 
Q. All right So when you arrived, Jeffiey 
16 
Epstein was asking for your assistance in helping 
17 
set these cameras up? 
18 
A. I take that back It might have been, the 
19 
cameras might have already been installed as far as the 
20 
covert clock in the office area because that was the 
21 
area that was burglarized. 
22 
. Q. Okay. 
23 
A. And the only reason why I remember that is 
24 
because I had interference between his system and our 
25 
system. 
Page 268 
1 
A. Again, it would have to be the chief of police 
2 
or the town manager or —
3 
Q. 'guess what I am asking is there any 
4 
coordinator of donations --
5 
A. No. 
6 
Q. — that works -- okay. And do you know 
7 
what was done with the December 14th, 2004, donation 
8 
made by Jeffrey Epstein? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: I believe that the donations 
11 
were returned to him, I believe. 
12 
BY MR. EDWARDS: 
13 
Q. And by returned, they would have been 
14 
returned back to whatever company they were written 
15 
from, COUQ Foundation? 
16 
MR. PIKE: Font. 
17 
THE WITNESS: I believe. I have no idea. 
18 
BY MR. EDWARDS: 
19 
Q. And do you know if Chief Reiter and 
20 
Jeffrey Epstein had a relationship where they spoke 
21 
with each other back in 2004 and 2005 —
22 
A. I have no idea. 
23 
Q. -- on any type of frequent basis? 
24 
A. I have no idea. 
25 
Q. Did ou ever speak with Jetitial
sw
ein 
Page 270 
1 
Q. All right. I am going to go back to 
2 
Plaintiffs Exhibit 29, same page that we looked at 
3 
last time related to a 2001 investigation, and ask 
4 
you to read the paragraph just above of that 
5 
paragraph we reviewed before. 
6 
A. Yes, sir. This paragraph we're talking about, 
7 
September 2005? 
8 
Q. Yes. Are you ready? 
9 
A. Yes, sir. 
10 
Q. Do you remember speaking with the Chiefor 
11 
to Jeffrey Einstein or any of his representatives 
12 
directly about a 2005 donation that Jeffrey Epstein 
13 
was calling to make? 
14 
A. No.' 
15 
Q. All right When is the first time that 
16 
you learned that sometime around September of 2005 
17 
Jeffrey Epstein was calling the police department 
18 
make a donation? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: I didn't even know he was 
21 
calling in 2005 to make a donation. Like I 
22 
said, I have no, no involvement in that 
23 
whatsoever. 
24 
BY MR. EDWARDS: 
25 
Q. Okay. That's not something that Chief 
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Reiter ever talked to you about? 
2 
A. No. 
3 
Q. So, right now is the first time that 
4 
you're learning that? 
5 
A. Yeah. 
6 
Q. Okay. Well, it looks like based on this 
7 
report that it was discussed with Epstein that his 
a 
potential donation of funds to purchase an Automated 
9 
Fingerprint Identification System for approximately 
10 
$130,000 was never made; is that correct? 
11 
MR. PIKE: Form. 
12 
THE WITNESS: Correct. I know we're 
13 
not — we don't have any system. We go to the 
14 
Sheriffs office to input fingerprints. 
15 
BY MR. EDWARDS: 
16 
Q. And Epstein's response was that was not 
17 
exactly what he hoped to donate as he wanted to 
18 
donate something that would provide some direct 
19 
benefit to police officers such as the services of a 
20 
chiropractor fora year. 
21 
Were you ever aware that Jeffrey Epstein 
22 
was trying to get chiropractic services for the 
23 
police officers for a one-year period? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: No. 
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THE WITNESS: No. 
BY MR. EDWARDS: 
Q. Did you know that Jeffrey Epstein received 
a January 2005 citizen award? 
A. Not that I am aware of. I don't blow. Lite I 
said, these are things that I don't get involved with. 
You know, that's strictly the Chief and way above my pay 
grade. 
Q. If awards like that are given out, are 
they given out directly by the chief? 
A. Yes. 
Q. I apologize for my ignorance. I am just 
not sue exactly what goes on in the police 
department and whose role it is to do that. So 
you're not the right person. We'll just keep moving 
on. 
Some of the documents that we have talked 
about today have been redacted. I think the 
explanation is they are minor victims. My question 
is if we wanted an unredacted version and if we 
agree that we're entitled to it, would that be 
something that would be in the possession of the 
Palm Beach Police Department? 
MR. PIKE: Form. 
THE WITNESS: I would assume so. 
Page 272 
1 
BY MR. EDWARDS: 
2 
Q. Today is the first day you're learning it? 
3 
A. Yes, sir. 
4 
Q. Any reason that you can think of that that 
5 
information was not conveyed to you during the time 
6 
that you're the lead detective on the case against 
7 
him? 
8 
MR. PIKE: Form. 
9 
THE WITNESS: Well, because that's 
10 
something that really has no —1 mean, I have 
11 
no direct involvement with any donations to the 
12 
police department, nor would that have made a 
13 
diffeleme in the investigation. 
14 
BY MR. EDWARDS: 
15 
Q. You testified earlier the search warrant 
16 
was executed October 21st, 2005; is that correct? 
17 
MR. PIKE: Form, asked and answered. 
18 
THE WHNESS: The 20th, I believe. 
19 
BY MR. EDWARDS: 
20 
Q. Were you aware of a tel 
one call made 
21 
from somebody named 
22 
asking to get a copy of the January 2005 citizen 
23 
award that was given to Jeffrey Epstein and ■ 
24. 
(phonetic)? 
25 
MR PIKE: Form. 
in November of 2005 
Page 274 
1 
BY MR. EDWARDS: 
2 
Q. Okay. The information that was provided 
3 
this week tots, most of which is redacted, is 
4 
something and was redacted recently for the purpose 
5 
of producing it to us, is that what you think? 
6 
MR. PIKE: Form. 
7 
THE WITNESS: Correct. 
8 
BY MR. EDWARDS: 
9 
Q. Somewhere there is an unredacted version? 
10 
A. Correct. 
11 
Q. And if I wanted to discuss the 
12 
investigation of Jeffrey Epstein between March of 
13 
2005 and September of 2005, is Officer Pagan the 
14 
person to speak with? 
15 
A. Yes. 
16 
Q. With Mr. Kuvin you spoke about many 
17 
different young females that were at Jeffrey 
18 
Epstein's home. And you interviewed numerous of 
19 
those females, correct? 
20 
A. Correct. 
21 
MR. PIKE: Form. 
22 
BY MR. EDWARDS: 
23 
Q. And did you record those interviews? 
24 
MR. PIKE: Asked and answered. 
25 
THE WITNESS: I believe so, yes, the 
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majority of them. 
BY MR. EDWARDS: 
Q. And do you have any copies of those tapes 
of the interviews? 
MR. PIKE: Form. 
THE WITNESS: They were all turned over to 
the FBL 
BY MR. EDWARDS: 
Q. They are not backed up on a computer or 
anything? 
A. No, sir. They were microcassettes. The ones 
that were conducted at the police department were video 
cassettes, but all those as well were turned over to the 
FBI. 
Q. Is it your.understanding that Jeffrey 
Epstein pled guilty to two felonies related to 
- restitution, correct? 
MR. PIKE: Asked and answered. 
THE WITNESS: Contl 
BY MR. EDWARDS: 
Q. In your interviews of these young females, 
were any of those females prostitutes prior to 
meeting Jeffrey Epstein — 
• MR. PIKE: Fonn. 
Page 277 
1 
manner, but you are saying that you may have jotted 
2 
down some 
3 
A. Correct 
4 
Q. Where would that, where would that diagram 
5 
be? 
6 
A. All that went over to the FBI. 
7 
Q. Okay. That stuff that's obviously not in 
8 
the property receipt but that's additional stuff 
9 
that has gone to the FBI? 
10 
A. Correct. Like I said, they wanted everything 
11 
including my working files, my — anything that I may 
12 
have jotted just so I can keep record of who brought 
13 
who. 
14 
Q. And again is that information that you 
15 
never made a personal copy of either? 
16 
A. It was all in my thumb drives which I had to 
17 
actually hand over to them. 
18 
Q. Okay. • 
19 
MR. PIKE: Form to that question. 
20 
BY MR. EDWARDS: 
21 
Q. What about any notes that you took during 
22 
the entire course of the investigation, do you have 
23 
any of those? 
24 
A. Once I transcribed them onto the rcµnt, those 
25 
were shredded and discarded. 
Page 276 
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WO% SIZ.0••••••••••
001... 
Q. You never tried to do it in a formal 
25 
BY MR. EDWARDS: 
Q. — to your knowledge? 
A. No. 
MR. PIKE: Pm sony. I don't understand 
the answer. So maybe you can follow-up with 
that. Tell you what, we'll just keep it at 
form. 
BY MR. EDWARDS: 
Q. • In organized crime you've seen these 
diagrams where it has a mob boss? 
A. Organizational chart. 
Q. Yes, organizational chart. Did you ever 
prepare any diagrams or charts like that for this 
case related to which girl brought another girl 
brought, another girl, the organizational chart 
so-to-speak? 
MR. PIKE: Form, move to strike. 
THE WITNESS: Not a chart, per se, but 
perhaps Tye done like this person brought 
these throe girls, this person brought these 
two girls, this person brought five girls. But 
That a, you know, like an L.C. chart where 
you've.got the mob boss, the under-boss. 
BY MR. EDWARDS: 
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Page 278 
MR. PIKE: Form. 
BY MR. EDWARDS: 
Q. What did you do today to prepare for the 
deposition, If anything? 
A. I read over the redacted incident report. 
That's basically it. 
Q. Okay. And the redacted incident report, 
you have been asked questions about who is this 
person that's underneath the redacted portion. And 
for the most part you haven't been able to identify 
a lot of those people. So, am I correct in 
understanding that you never went back and looked at 
the unredacted version? 
MR. PIKE: Form. 
BY MR. EDWARDS: 
Q. At least to prepare for this deposition? 
A. I believe there was just one girl thatl 
wasn't 100 percent certain. 
Q. Okay. 
A. But on the others I was able to based on the 
body of it identify who the girls were. 
Q. Okay. During these interviews, how long 
did you spend with each person? 
A. Depends on the length of the videos, of the 
interviews. Some were an hour. 
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Q. I mean, I'm sorry for such a bad question, 
but in looking at these property receipts, I just 
don't see where it tells me how much time each 
interview had taken. So, l mean, is there an 
average? 
A. That's not going to indicate on any property 
. receipt. There is no... 
Q. Right Okay. Have you ever seen the 
nonprosecution agreement? 
A. No. 
. 
Q. Have you ever seen the attached list of 
victims that was attached as an addendum to the 
nonprosecution agreement? 
MR. PIKE: Form. 
THE WITNESS: I believe the Chief had a 
copy of it. He may have, you know, done one of 
these, but, no, not in my physical hands. 
MR. PIKE: And just for the record when 
the witness said --
THE WITNESS: I held it up. 
MR. PUCE: — one of these, he held up 
Exhibit 29. 
MR. EDWARDS: Which said memorandum. 
MR. PIKE: Memorandum. 
THE WITNESS: I just held it up. 
Page 281 
1 
A. I remember getting doctunents from Alan 
2 
Dershowitz which were flight logs pertaining to 
3 
• Mr. Epstein's plant And I subpoenaed the information 
4 
from Jet Aviation, but I don't, I don't recall preparing 
a flight log. 
6' 
• • 
Q. Okay. Do you remember receiving 
7 
information from Jet Aviation directly? 
3 
MR. PIKE: Form. 
9 
-THE WITNESS: Jet Aviation does not keep 
10 
records according to them as to who flies on 
11 
what plane. I guess you can just drive up to a 
12 
plane, board it. They have no idea who's on 
13 
the, who is flying on the plane. They have 
14 
records of when the plane comes in, if the 
15 
plane is serviced, and when the plane leaves. 
16 
BY MR. EDWARDS: 
17 
Q. Did you over attempt to check with customs 
18 
or FAA on any of the passengers that have ever been 
19 
on international flights with Jeffrey Epstein or on 
20 
his planes? 
21 
MR:PIKE: Form. 
22 
THE WITNESS: I'm trying to recall. 
23 
BY MR. EDWARDS: 
24 
Q. At the current time do you have any 
25 
knowledge of that being done by either the U.S. 
Page 280 
1 
BY MR. EDWARDS: 
2 
Q. If a memorandum exists and it is the 
3 
attached addendum to the nonprosecution agreement 
4 
containing the names of the underage victims, would 
5 
that be something in the possession currently of the 
6 
Palm Beach Police Department? 
7 
MR. PIKE: Form. 
8 
THE WITNESS: I don't believe so. 
9 
BY lvflt EDWARDS: 
10 
Q Is that something that's been destroyed or 
11 
also-
12 
• 
MR. PIKE; Form. 
13 
THE WITNESS: I never received a copy of 
14 
it so... 
15 
BY MR. EDWARDS: 
16 
Q. Have you ever seen it? 
17 
A. Like I said, I may have seen it. I may have 
18 
been shown it, you know, and just by holding it up and I 
19 
am only using this exhibit as an example. It may have 
20 
been just shown to me like this but not in my hands 
21 
where I actually read the entire document. 
22 
MR. PIKE: Move to strike. 
23 
BY MR. EDWARDS: 
24 
Q. In your investigation, did you prepare a 
25 
flight log summary? 
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Page 282 
Attorney's office or the FBI? 
A. I have no idea what the FBI does. They are 
primarily one way. You give them the information and 
nothing comes back, so... 
Q. I am starting to get that idea. I am 
understanding that. Okay. 
A. But you know, and I work with them almost on a 
daily basis, so I am in direct contact with them. And 
still I have yet to see information come back the other 
way. 
Q. Just so the record is clear, when you say 
you're working with them on a daily basis, when 
you're in the Organized Crime Unit on other cases, 
correct? 
A. Yeah, and I am also assigned to the MT, the 
Joint Terrorism Task force here in West Palm Beach. 
Q. My understanding from reading your reports 
is that you also subpoenaed phone records of 
numerous individuals, correct? 
A. Correct. 
Q. One of those individuals is Jeffrey 
Epstein? 
A. I believe so. 
Q. =='? 
A. Yes. 
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