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IN 741E CIRCUIT COURT OF THE FIFTEENTH JUDICIAL MOAT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
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CASE No.50200SCA037315000004B AB 
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Plaintiff. 
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-vs- 
VOLUME IV OF IV 
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Defendants 
DEPOSITION OF 
DETECTIVE JOSEPH RECAREY 
Friday, March 19, 2010 
10:03 - 5:23 p m 
505 South [take Drive 
Suite 1100 
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West Palm Beach, Florida 33401 
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21. 
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Reported By. 
Jana Ricciuti. Mit FPR. CLR 
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Notary Public. Stew of Florida 
Prose Gault Reporting 
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la 
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APPEARANCES 
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On tehalf 
Janc Den I thectralt 8: 
JESSICA
1 
 
BOOK ESQUIRE 
MERME1812:214 & HOROW112, l'A. 
W205 lagoon nukearr1 
Son 2218 
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phon
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On batonMtn Plaintiff, lane Doe Nall: 
ISOM MANUEL Minn  mom 
GARCIA. ELKINS & BOEFIFUNGER 
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224 Dina Mew Saito 900 
War tide 
33401 
Phan 
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sad 
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TARA k FINNIGAN, !MUM 
TARA& FINNIGAN. PA 
13 
VA Miura Street 
State WO 
West Pailliarida 
33401 
Mono 
an Wulff of the Datong, hffny Emleos 
MICHAEL PIKE, ESQUIRE 
BURMAN, CRIITOR LETT/ER& COLEMAN, LIP 
303 014066 Boolean 
Stile 4'.0 
West /MC 
33401 
Phone' 
and 
MIUION O. Whl MIRO. ESQUIRE 
LAW00110E OF MILTON G. WEINBERG 
20 Pin Pima 
Suite WOO, 
Bent
 02116 
Moue: 
I', -1r 502 I 
a 
Page 5C. 
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uNDED STATES DISTRICT COURT 
SOUTHERN DISTRICT OP FLORIDA 
CASE NO.10-80309 
JANE DOE NO. 103. 
Plaintiff, 
VOLUME IV OF IV 
JRPFREY CPSIEIN, 
Defendant. 
DEPOSITION OF 
DEIECTIVE JOSEPH RECAREY 
Tuesday, April 27, 2010 
10:03 - 5:23 pm. 
505 Saab Flagler Drive 
Stitt 1100 
Weft Palm Beach, Florida 33401 
Reported By: 
Jam Fticciuti, RPR, FPR, CLR 
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Notary Public, State of Florida 
Prose Cain Reporting 
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Page 503 
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Appearances continued... 
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On behalf of the Witness: 
' 
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JOANNE M. O'CONNOR, ESQUIRE 
JONES, FOSTER, JOHNSON & STUBBS, P.A. 
4 
505 South Flagler Drive, Suite 1100 
West 
Florida 33401 
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Phone:
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Also Present Jeffrey Epstein 
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.... - 
2 (Pages 
PROSE. COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricci uti (601 
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Electronically signed by Jeana RIccluti (601 
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500 to 503) 
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INDEX 
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wrrNESS: COMM CROSS CROSS REDIRECT RECROSS 
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DETECTIVE JOE RECAREY 
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BY MR. WEINBERG 505 
BY MS. ARDOUR 
636 
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BY MR. GARCIA 
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- - - 
EXHIBITS 
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NUMBER 
DESCRIPTION 
PAGE 
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DEPOSITION EX. 29 
MESSAGE BOOKS 
592 
DEPOSITION EX. 30 
HANDWRITTEN NOTE ON 
617 
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JEFFREY E. EPSTEIN MEMO 
PAD 
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DEPOSITION EX. 31 
HANDWRITTEN MESSAGE 
622 
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counsel? 
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MS. ARBOUR: Form. 
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THE WITNESS: I believe so, yes. 
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BY MR. WEINBERG: 
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Q. And that was an offer that was extended by the 
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State Attorney following discussions with the Palm Beach 
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Police Department, correct? 
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A. That was when we had just heard about it. We 
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were unaware that the offer was made. 
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Q. And how did you become aware that the offer 
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was made? 
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A. I had made numerous telephone calls to the 
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State Attorney's office to inquire where we were, and 
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did not receive any return phone calls. I went over to 
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the State Attorney's office personally on an tmrelated 
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incident to drop off some filittpackets, and that's 
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when I went by and I saw =was in her office. 
18 
Q. 
was an experienced State attorney, 
19 
correct? 
20 
MS. ARBOUR: Form. 
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THE WITNESS: I know she had been there for 
22 
some time. 
23 
BY MR. WEINBERG: 
24 
Q. And you knew she had been a prosecutor for sex 
25 
offense cases for some time, correct? 
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Page 505 
PROCEEDINGS 
BY MR. WEINBERG: 
Q. Good afternoon, sir. 
A. Good afternoon. 
Q. To finish up the subject that we were talking 
about right before the recess, do you ever recall 
dicr-ncsions with the State Attorney's office about an 
offer that was extended to Mr. Epstein to plead guilty 
and receive a five-year period of probation for an 
aggravated assault charge? 
A. Yes. 
Q. And that was a subject of discussion between 
you and members of the State Attornes fice? 
A. With Assistant State Attorney
I don't know if that's her last name, how 
it's pronounced, but close enough. 
Q. If we call her =, 
I think we both know who 
we're discussing. 
A. Yeah. 
Q. And those discussions occurred within or 
around the winter of 2005,'6? 
A. I believe so. 
Q. And was that a sentence and a charge option 
that was extended to Mr. Epstein through his then 
Page 507 
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A. She did a lot of crimes against children. 
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Q. And she, on other occasions, advocated 
3 
prosecution of people on felony charges, correct? 
4 
A. I hadn't had many dealings with her so I don't 
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know. You know, l knew Mier. She was actually at the 
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office, State Attorney's office, when I was employed 
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there many years ago. 
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Q. And that was how many years ago? 
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A. I've been with Palm Beach almost 19 years. 
10 
Q. So we're talking about at least 20 years ago? 
11 
A. Yeah. 
12 
Q. And she had been there, to your knowledge, 
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continuously from the time that you knew she was there 
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20 years ago? 
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A. Yeah. 
16 
Q. And you knew her specialty to be charging 
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people that were — for offenses that dealt with 
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violations of underagtal people, mama 
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MS. ARBOUR: Fonn. 
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THE WITNESS: I believe so. I believe so. 
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Like I said, I didn't have many dealings with her. 
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BY MR. WEINBERG: 
23 
Q. So you saw her in the office that day? 
24 
A. And that was the time that I just had learned 
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of the offer that was made to previous counsel. 
PROSE COURT REPORTING AGENCY, 
Electronically signed by Jeana ificciuti (801M 
Electronically signed by Jeana Moduli (601 
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Q. And did you take a position on that offet? 
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A. Personally, I told her I didn't agree with it, 
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but I couldn't speak for the department. It actually 
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had to come from people with a higher pay grade than 
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mine, so I just relayed the information back to 
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Chief Reiter. 
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Q. And what, if anything, did Chief Reiter do? 
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MS. ARBOUR: Form. 
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THE WITNESS: I believe he tried to make 
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contact with State Attorney Barry Krischer. 
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BY MR. WEINBERG: 
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Q. Did he make contact with State Attorney 
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KriSehe', to your knowledge? 
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A. I'm not 100 percent certain if he did or 
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didn't. I bow there was some time where none of our 
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calls were being returned from the State Attorney's 
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office. 
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Q. Jane Doe 103 was one of the witnesses who was 
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at the center of the State investigation, correct? 
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A. One of them, yes. 
21 
Q. And you knew that Jane Doe 103 had a MySpace 
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page that was one of the MySpace profiles that was 
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provided to the State Attorney by Mr. Epstein's then 
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counsel, Professor Dersbowitz, correct? 
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A. Yes, I knew that there were pages sent of the 
Page 510 
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correct? 
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MS. ARBOUR: Form. 
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THE WITNESS: f know that when there's 
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misdemeanor arrests in the Town of Palm Beach, a 
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lot of officers pretty much try to gain any 
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intelligence they can from any of the people that 
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they encounter. Some of the information actually 
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leads to other cases, clearance of minor rocas 
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thefts, bike thefts. 
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BY MR. WEINBERG: 
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Q. And in this case, it led to you going to sec 
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Jane Doe 103, first calling her on October 10th and then 
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visiting ha in Jacksonville on October 11th, correct? 
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A. Yes. 
I5 
Q. And you also, in your investigation, learned 
16 
that Jane Doe 103 had lost her job at Victoria Secret 
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for stealing, did you not? 
18 
A. No. 
19 
Q. You never received any information regarding 
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Jane Doe 103's employment history with Victoria Secret? 
21 
A. She was actually employed there when I went up 
22 
to seeker. Thrift where I met with her. 
23 
Q. Did you ever team at any time that she had a 
24 
problem that led to her losing her employment? 
25 
A. No. 
Page 509 
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MySpaces, but I wasn't sure of whom at that particular 
2 
time. They provided us copies thereafter, but right 
3 
there, immediately, I wasn't aware of whom had pages. 
4 
Q. You eventually received than and reviewed 
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than, correct? 
6 
A. tJb-huh. 
7 
Q. And you understood that from even before then, 
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that Jane Doe 103 had a background that involved at 
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least one arrest, correct? 
10 
A. Yes. 
11 
Q. And you understood that when she was arrested 
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in early October, she in fact informed the arresting 
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officers that she had information regarding Mr. Epstein, 
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correct? 
15 
A. I believe so. 
16 
Q. And if you go to your probable cause affidavit 
17 
ai page 11, at the bottom of 10, it starts, 'On 
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September 11, 2005, Jane Doe 103 was arrested by the 
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Palm Beach Police Department for misdemeanor possession 
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of marijuana. During the arrest, Jane Doe 103 told the 
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arresting officer that she had information about sexual 
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activity taking place at the residence of Mr. Epstein." 
23 
A. Yes. 
24 
Q. Jane Doe 103 essentially was asking the 
25 
arresting officer to assist in her cooperating; is that 
Page 511 
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Q. So you knew she had been arrested for 
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marijuana? 
3 
A. Uhelmh. 
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Q. You knew she had a MySpace page where there 
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was information that was -- that showed her to use 
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thugs, correct? 
7 
A. Uh-huh. 
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MR. PIKE: Yes or no? 
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THE WITNESS: Yes. 
10 
BY MR. WEINBERG: 
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Q. You knew that the role of the State Attorney, 
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the prosecutor that would have to present this case to 
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the jury, was to weigh evidence, correct? Not only the 
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evidence you provided but also any evidence that was 
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provided by those representing the target of criminal 
16 
investigation? 
17 
A. Yes. 
18 
Q. And
 knew that as a result of that weighing 
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process, =, 
an experienced State Attorney, told you 
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that she believed at least that Jane Doe 103 was a 
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consenting participant and not a victim of criminal 
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offenses by Mr. Epstein, correct? 
23 
MR. GARCIA: Object to the form. 
24 
THE WITNESS: I don't — consenting victim, 
25 
you mean? 
4 (Pages 508 to 511) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciutl (601
Electronically signed by Jeana Ricciutl (601 
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BY MR. WEINBERG: 
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case, "Is it okay to take a taxi". 
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Q. She told you that there were no victims here 
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MS. ARBOUR: Form. 
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when — 
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BY MR. WEINBERG: 
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A. Originally, that was her statement, yes. 
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Q. Is that right? 
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Q. Right. And if there were no victims here, 
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MS. ARBOUR: Same objection. 
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then she's really saying to you that, after reviewing 
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THE WITNESS: Yes. 
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all of the evidence that she received, not only from you 
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BY MR. WEINBERG: 
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but from the defense, she didn't consider Jane Doe 103 
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Q. So whoever was at die Epstein home receiving 
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to be a victim? 
9 
the call would essentially write this denim on a message 
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MS. ARBOUR: Form. 
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pad that had at least two different layers? 
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111E WITNESS: 1 believe that's what she 
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MS. ARBOUR: Fem. 
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stated. 
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THE WITNESS: Yes. 
13 
BY MR. WEINBERG: 
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BY MR. WEINBERG: 
14 
Q. And given her knowledge of what occurred on El 
14 
Q. And that when you seized the message pad from 
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Brillo Way, she didn't see any victims in this case. 
15 
the trash pulls, there was only one layer, which was the 
16 
MS. ARBOUR: Form. 
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original that had been thrown out or crumpled out, 
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THE WITNESS: 1 believe that's what she 
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correct? 
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stated. 
18 
A. Yes. 
19 
BY MR. WEINBERG: 
19 
Q: AM when you went on October 20th and 
20 
Q. Whether or not she physically did possess the 
20 
conducted a search and seizure, you would seize the pads 
21 
message pads or whether she had access to information, 
21 
that included all of the copies of the original 
22 
the message pads that you reviewed were in the hundreds, 
22 
messages, correct? 
23 
if not thousands, correct? 
23 
A. Yes. 
24 
A. Uh-huh. 
24 
Q. And they were in various handwriting, were 
25 
Q. And that these pads reflected incoming calls 
25 
they not? 
Page 513 
Page 515 
1 
to Mr. Epstein's phone that was in Mr. Epstein's 
1 
A. Yes. 
2 
residence on El Brillo, correct? 
2 
Q. And they provided you with leads to witnesses, 
3 
A. Correct. 
3 
did they not? 
4 
Q. And they reflected messages that came from 
4 
A. Yes. 
5 
people that left their phone numbers? 
5 
Q. And provided you with names and numbers? 
6 
A. Yes. 
6 
A. Yes. 
7 
Q. And it reflected messages that included, for 
7 
Q. And gave you information that there was lots 
8 
instance, from.. on July 9, 2004, 
is available 
8 
of people who, at least according to these telephone, 
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on Tuesday. Was that a message that was concluded in 
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incoming telephone calls, were inviting themselves to 
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these message pads? 
10 
Mr. Epstein's home — 
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MS. ARBOUR: Form. 
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MS. ARBOUR: Form. 
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111E WITNESS: Yes, that was some like that, 
12 
BY MR. WEINBERG: 
13 
yes. 
13 
Q. — either directly or through their friends, 
14 
BY MR. WEINBERG: 
14 
correct? 
15 
Q. And that is clutmeteristic of lots of the 
15 
MS. ARBOUR: Form. 
16 
messages that were being received by whoever was taking 
16 
MR. GARCIA: Object to form. 
17 
down a message at the Epstein residence, correct? 
17 
THE WITNESS: There were several messages that 
18 .
MS. ARBOUR: Form. 
18 
I recall was written to Mr. Epstein indicating 
19 
THE WITNESS: Iih-huh, yes, correct. 
19 
girls' names and times that they were available. 
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BY MR. WEINBERG: 
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BY MR. WEINBERG: 
21 
Q. And the way it worked, if I'm right, is that 
21 
Q. Like, for instance here, she wants to confirm 
22 
somebody would answer the phone and, for instance, the 
22 
a 11:00 tomorrow, message for JAE from a woman's name. 
23 
message would say on July 19, '04, Mr. Epstein: Phone 
23 
That would be typical messages on these pads that you 
24 
call from M., leaving a reply mobile phone number or 
24 
reviewed? 
25 
cellular number, and leaven very short message, in this 
25 
MS. ARBOUR: Form. 
5 (Pages 512 to 515 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciuti (601 
Electronically signed by Jeans Ricciuti (601 
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Page 516 
THE WITNESS: That would be some, yes. 
BY MR. WEINBERG: 
Q. And many of them appeared to be incoming calls 
from different girls which said, Em in town, can I come 
over, can I schedule a meeting? 
MS. ARBOUR: Form. 
THE WITNESS: Some were like that. 
BY MR. WEINBERG: 
Q. And some appeared to be responses to a phone 
call made by someone at the El Bulb home asking, are 
you available, and there would be a phone call back 
saying, Pm available tomorrow afternoon or Wednesday 
morning or Thursday afternoon. 
A. Correct. 
Q. And by and large, these messages did not 
include any negotiation over dollars? In other words, 
there was not on a message pad that any of these 
incoming girls were saying, I will come over ifIeffrey 
gives me $500 or $300; there was no evidence of that 
kind of incoming phone call, correct? 
MS. ARBOUR: Form. 
THE WITNESS: Not that I can recall, no. 
BY MR. WEINBERG: 
Q. And likewise, there was no indication on these 
message pads that any of the people calling 
1 
of 18; is that right? 
2 
A. What groupings? 
3 
Q. Well, let's say, did you ever interview a 
4 
woman named II.? 
5 
A. Yes. 
6 
O. And youlcnew that her date of birth was in 
7 
and that she was over 18 when you 
8 
interviewed her —
9 
A. Yes. 
10 
Q. — and represented herself to be over 18 when 
11 
she saw Mr. Epstein? 
12 
MS. ARBOUR: Font 
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THE WITNESS: Yes. 
14 
BY MR. WEINBERG: 
15 
Q. And, likewise, 
was another person who 
16 
said yes, she had been to Mr. Epstein's house at a time 
17 
when she was over 18? 
18 
A. Correct 
19 
Q. And then M. was in her 20s when you 
20 
interviewed her? 
21. 
A. Yes. 
22 
Q. And there was an., who after the publicity 
23 
came out, called in and said she was 25 at the time she 
24 
met with Mr. Epstein? 
25 
A. Yes. 
I 
I 
Page 517 
1 
Mr. Epstein's home were, in essence, particularizing 
2 
what they were going to do or what they intended to do 
3 
or what they might do once they got there, correct? 
4 
MS. ARBOUR: Form. 
5 
THE WITNESS: Can you repeat that question? 
6 
BY MR. WEINBERG: 
7 
Q. Sure. Theres nothing on these message pads 
8 
that indicates, I'll come over and give a topless 
9 
massage to Mr. Epstein? 
10 
A. No. 
11 
Q. These are essentially contact and scheduling 
12 
calls? 
13 
MS. ARBOUR: Form. 
14 
THE WITNESS: Yes. 
15 
BY MR, WEINBERG: 
16 
Q. And often reflect the fact that the callers 
17 
are not connecting on the first call, so they're going 
18 
back and forth and trying to arrange times for a 
19 
particular woman to come over to Mr. Epstein's home, 
20 
correct? 
21 
MS. ARBOUR: Form. 
22 
THE WITNESS: Yeah. 
23 
BY MR. WEINBERG: 
24 
Q. And some of these calls come from a whole 
25 
grouping of persons that you learned were over the age 
Page 519 
1 
Q. And., who you interviewed, who told you 
2 
that yes, she went to Mr. Epstein's home on many 
3 
occasions, and she was over 187 
4 
A. Yes. 
5 
Q. And a 
6 
A. She was a licensed masseuse. 
7 
Q. Licensed masseuse who was over 18. 
8 
A. Yes. 
9 
Q. And some of the people interviewed had tumcd 
10 
18 during the period that they were seeing Mr. Epstein 
11 
and so told you, correct? In other words, that they had 
12 
started seeing Mr. Epstein when they were 17, and then 
13 
they became 18 and continued to see him when they were 
14 
18 and, in fact, you interviewed them when they were 18? 
15 
MS. ARBOUR: Form. 
16 
THE WITNESS: Some, yes. 
17 
BY MR. WEINBERG: 
18 
Q. And they, too, are included in Mese book of 
19 
message pads? In other words, this was not limited, the 
20 
incoming calls were not limited to girls that were 17 or 
21 
16, and included girls that were 18, 19,20, 25 and even 
22 
older, correct? 
23 
MS. ARBOUR: Form. 
24 
THE WITNESS: Correct. 
25 
BY MR. WEINBERG: 
PROSE COURT REPORTING AGENCY, 
Electronically signed by Jeana Rlcciuti (401Ia 
Electronically signed by Jenne Ricclutl (601 
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INC. 
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Page 520 
Q. Now, when you drafted the search warrant 
7 
affidavit and you agreed with me that you understood 
3 
when you drafted it, as an experienced detective of 
4 
almost two decades, that the judge would be relying on 
3 
the content of what you preiented to him, correct? 
6 
A. Yes. 
7 
MS. ARBOUR: Form, asked and answered. 
BY MR. WEINBERG: 
Q. That the judge did not have some external 
bases to test the representations, either for 
completeness or for accuracy? 
MS. ARBOUR: Form. 
THE WITNESS: Correct. 
BY MR. WEINBERG: 
Q. And you made representations in the search 
warrant affidavit that were repeated in the probable 
cause affidavit, did you not, that were attributed to 
A. Yes. 
Q. And directing myself to the probable cause 
affidavit, because that's the one that is unsealed and 
an exhibit in this case, you essentially said to, on the 
probable cause affidavit, that M. said that Jeffrey 
Epstein wanted young girls —
A. Yes. 
Page 522 
1 
now almost five years ago, that she had said to you that 
2 
Jeffrey Epstein preferred girls between 18 and 20. 
3 
A. I would have documented that in the incident 
4 
report, but... 
5 
Q. Would it be an important modification of the 
6 
statement attributed to her that Jeffrey Epstein wants 
7 
young girls, correct? 
8 
MS. ARBOUR: Form. 
9 
THE WITNESS: Had she said it, but again, I 
10 
don't — 
I 1 
BY MR. WEINBERG: 
12 
Q. I understand. Had she said it, it certainly 
13 
would have been considered important enough to include 
14 
in the various affidavits that you drafted that relied 
15 
in part on what 
told you. 
16 
MS. ARBOUR: Form, the tape speaks for itself. 
17 
BY MR. WEINBERG: 
18 
Q. Correct? 
19 
A. Correct. 
20 
Q. The message pads include messages like, was 
21 
wondering if she would get work tonight, she couldn't 
22 
work yesterday because of some family event. That's the 
23 
messages, those contents, you would have view of the 
24 
message pads, correct? 
25 
MS. ARBOUR: Form. It speaks for themselves. 
Page 521 
1 
Q. 
correct? 
2 
Do you recall that during your tape recorded 
3 
interview with M., she told you that Jeffrey Epstein 
4 
preferred to receive massages from girls between 18 and 
20 years old? 
A. I recall her slating, "The younger, the 
7 
better," but I don't recall that he prefers girls 
8 
between 18 and 20. 
9 
Q. Will augrce with me that if the tape 
10 
recording of
 interview with you reports that as a 
11 
statement made by her, that the tape recording would be 
12 
the most accurate source of what she told you back in 
13 
early October 2005? 
14 
MS. ARBOUR: Form. 
15 
MR. GARCIA: Do you have the tape recording to 
16 
play, because my understanding is that's under FRI 
17. 
control. 
18 
MR. WEINBERG: 
asking questions about 
19 
whether or not it included —
20 
MR. GARCIA: Without playing the tape 
21 
recording, I think it's an unfair question. 
22 
MR. WEINBERG: You can object. I'll ask it. 
23 
THE WITNESS: If the recording indicated? 
24 
BY MR. WEINBERG: 
25 
Q. That III. told you in early October of 2005, 
Page 523 
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THE WITNESS: Oh-huh. 
2 
BY MR. WEINBERG: 
3 
Q. Did you ever interview n woman named M.? 
4 
A. I attempted it, and I don't think she ever 
5 
returned my calls. 
6 
Q. Did you cvcr go to her house? 
A. Let me think. I may have. I mean, I can't 
8 
recall if I went to her house or not, but I know I 
9 
telephoned her and I never got any call back from her. 
10 
Q. Did you, dining this investigation, ever, 
11 
yourself, go to MySpace pages to conduct any background 
12 
investigation on the various women that you were 
13 
proffering to the State Attorney as reliable witnesses? 
14 
MR. GARCIA: Objection, asked and answered. 
15 
MS. ARBOUR: Joined. 
16 
THE WITNESS: Again, I looked at them when 
17 
they were turned over, but no, l didn't. 
18 
BY MR. WEINBERG: 
19 
Q. I'd ask you to look at page 65 of the incident 
20 
report, paragraph 4, and see if that refreshes your 
21 
recollection. 
22 
A. Yes, I did. 
23 
Q. And do you recall just how you accessed 
24 
MySpace? Did you run through a list of all your 
25 
witnesses and saw whether or not certain of them had 
7 (Pages 
'PROSE COURT REPORTING.AGENCY, INC..
Electronically signed by Jeana Ricciuti (601M 
Electronically signed by Joana Rlcciu0 (601 
520 to 523) 
bdcd1876c72e-432d-13cf0-b19no6561291 
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2 
A. Correct. 
3 
Q. And you concluded that -- ifs all redacted 
4 
hero, but it looks like 10 or 12 of your witnesses had 
5 
6 
A. Correct. 
7 
Q. And did you download the infonnaticm from 
8 
these MySpace pages into sonic evidentiary format? 
9 
A. I believe either I printed them or I might 
10 
have viewed them and
 made reference of it, that 
11 
they had a MySpace page. 
12 
Q Did you ever study the contents of the MySpace 
13 
page? 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
MySpace pages? 
MYSPoce Pages. 
A. The ones that were viewable, 1 looked at. Thu 
ones that weren't, eventually they all became private. 
Q. And the ones that were viewable, did you 
identify certain of your witnesses as including in their 
MySpace page evidence that they were involved in the use 
of drugs? 
A. I recall pictures of like a marijuana leaf, 
comments made of being high when the photo was taken and 
some alcohol use. I remember that as well. 
Q. And did you include those obsavations in your 
incident report that ultimately would have gone to the 
State Attorney to assist the State Attorney in assessing 
1 
Beach, Mr. Epstein? 
2 
A. Yes. 
3 
Q. And the question is: You went on MySpace, you 
4 
looked at certain pages that reflected at least some of 
5 
your witnesses who were not only using drugs but 
6 
bragging about using drugs publically and publishing 
7 
pictures or references to themselves as drug users, 
8 
correct? 
9 
A. On the MySpace page, right. 
10 
Q. Right. Did you do anything else, as an 
11 
experienced investigator, to try to determine by 
12 
through the investigation into the background of any of 
13 
the witnesses? 
1 4 
A. I believe I checked than under the local 
15 
systems to see if they had been arrested. I did like a 
16 
criminal background check on them and the sworn taped 
17 
statement that we took as well. 
18 
Q. October 20th you went to Mr. Epstein's home 
19 
with a group of others; is that correct? 
20 
A. Uh-huh. 
21. 
MR. PIKE: Yes? 
22 
THE WITNESS: Yes. 
23 
BY MR. WEINBERG: 
24 
Q. And you went there with a search warrant —
25 
A. Correct 
Page 525 
1 
the credibility of the people that you were proffering 
2 
to them as witnesses? 
3 
A. Did I include those in with the State 
I 
Attorney? I believe they had them by then. That was 
the winter of '05, '06. 
6 
Q. But this was an independent review of MySpace 
7 
that was not related to what Professor Dershowitz gave 
the State Attorney; this was something you were 
reporting that you did on your own, correct? 
10 
A. I tray have done it on my own to view it myself 
11 
after learning from the State Attorney's office. I'm 
12 
not —I can't recall if I did it totally on my own or 
13 
when I first heard of the MySpace pages, J researched it 
14 
myself to view it myself. 
15 
Q. Did you do anything other Than look at MySpace 
16 
pages to try to assess the credibility of any of your 
17 
witnesses based on what you could learn about them from 
18 
other people? In other words, you were essentially 
19 
proffering to the State Attorney certain statements that 
20 
had been made to you regarding what occurred on El 
21 
Milo Way, correct? 
22 
A. Uh-huh. 
23 
Q. And you were relying on those statements and 
24 
their detail as a basis for asking the State Attorney to 
25 
bring a criminal prosecution against a residence of Palm 
Page 527 
1 
Q. — correct? And in the search warrant, you 
2 
requested the authority to seize all computers, all 
3 
equipment, any discs, any DVDs, any media, correct? 
4 
A. Uh-huh. 
5 
MS. ARBOUR: Form, asked and answered. 
6 
THE WITNESS: Correct. 
7 
BY MR. WEINBERG: 
8 
Q. And you seized whatever you found there, 
9 
correct? 
10 
A. Yes. 
11 
Q. And you, yourself, looked through what you 
could look through and asked your forensic people to 
:3 
look through what you couldn't look through; is that 
14 
correct? 
15 
A. That is correct. 
16 
Q. And as a result of the search and seizure, 
17 
there was no picture of Jane Doe 103 that was seized, 
18 
correct? 
19 
A. That's correct. 
20 
Q. And there was no camera that was found in the 
21 
massage room, no coven camera found in the second floor 
22 
massage room of the Epstein home, correct? 
23 
MS. ARBOUR: Form. 
24 
THE WITNESS: No, we did not find a camera 
25 
that day, no. 
ccers
1/4.-7,- 
a 
-2--
,44.4aredeSev*......-4t-YeetSiers, 
Mr-nteaf 
J 
8 (Pages 524 to 527 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana IlIcciutl (601 
Electronically signed by Jeans Riccluti (601 
bded1876-c726-432da-f041 9666661291 
EFTA00298348

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10 
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13 
14 
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19 
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1 
BY MR. WEINBERG: 
2 
Q. The only camera you found was the camera that 
3 
you knew about from your 2003 investigation, the one 
4 
that was in the clock aimed at Mr. Epstein's desk and 
5 
the second camera that was in the garage, correct? 
6 
A. We found, yes, the second camera in the 
7 
garage- 
• 
8 
Q. Did you ever, on any other day, find any 
9 
camera other than the cameras you, yourself, installed 
10 
in 2003 and the camera that Mr. Epstein pointed out to 
11 
you in 2003 from the lint floor area? 
12 
A. No, we didn't see — we didn't find any other 
13 
cameras. 
14 
Q. And you had only been to his house, twice; is 
15 
that correct? Once —
16 
A. The day of the search warrant and the day that 
17 
I assisted by putting the cameras. 
18 
Q. You never went back in and altered his home 
19 
after October 20, 2005, did you? 
20 
A. No. 
21 
Q. Do you know of any audio or wire electronic 
22 
interceptions that were directed against Mr. Epstein or 
23 
his residence at any time by anyone? 
24 
A. No. 
25 
Q. There were certainly none that was connected 
1 
THE WITNESS: Yes. 
2 
BY MR. WEINBERG: 
3 
Q. At any time prior to that, did Jane Doe 103 
4 
ever call you and say that she was concerned about an 
5 
investigator? 
6 
A. Yes. 
7 
Q. And did she call — do you recall when she 
8 
called you? Before or after the service of the 
9 
subpoena, if you remember? 
10 
A. It was before. 
11 
Q. And did she call you at night or in the day 
12 
time? 
13 
A. I believe she called me in the evening time 
14 
and left me a voice mail, and I returned her call in the 
15 
morning. 
16 
Q. And when she left you a voice mail, where 
17 
would she have called, into the office, or... 
18 
A. Into the Police Department. 
19 
Q. Did she have your cell phone number? 
20 
A. I had provided the victims with a cell phone 
21 
number, yes. 
22 
Q. Was that a cell phone number that you carried? 
23 
A. Uh-huh. 
24 
Q. Was it one of several cell phones you carried? 
25 
A. Yes. 
I 
I 
Page 529 
1 
to your State investigation? 
2 
A. No. 
3 
Q. So nobody under your command was outside his 
4 
house at any time trying to intercept telephone 
5 
communications of any kind? 
6 
MS. ARDOUR: Form, asked and answered. 
7 
BY MR. WEINBERG: 
8 
Q. Is that right? 
A. Not to my knowledge, no. 
Q. And not to your knowledge, did anybody try to 
intercept electronic communications, e-mails, any other 
form of communication emanating from either his 
residence or any Internet service provider? 
MS. ARBOUR: Form, asked and answered. 
THE WITNESS: No. 
BY MR. WEINBERG: 
Q. Do you recall that during the course of your 
investigation, before you ended up drafting your May 1st 
affidavit, there was a decision made to conduct a grand 
jury? 
A. Yes, a couple of times. 
Q. Whether it was March or April, a subpoena was 
served on Jane Doe 103 by yourself in Tallahassee, 
correct? 
MS. ARBOUR: Form, asked and answered. 
Page 531 
1 
Q. Was it a cell phone that was paid for by the 
2 
Palm Beach Police Department? 
3 
A. I believe 1 was paying for that one. 
4 
Q. Was there a second cell phone — 
A. Here's the thing: The Town was offering us a 
6 
stipend onto a cell phone. I had, prior to that, a few 
7 
months left on another cell phone to the end of 
8 
contract. So fora time period there I carried two 
9 
phones until the contract expired, and at which time I 
10 
shut off that service and then just used the —
11 
Q. The phone left was the one that the Town was 
12 
offering you a stipend? 
13 
A. Yes. 
14 
Q. And by the Town," do you mean the Palm Beach 
15 
Polka Department? 
16 
A. Palm Beach Police Department. 
17 
Q. And this was the nut 
that you began to give 
18 
out to different witnesses —
19 
A. That is correct. 
20 
Q. — not only in this case but in other cases? 
21 
A. Correct. 
22 
Q. Is that a — do you get copies of the cell 
23 
records that are connected to that phone or do they go 
24 
directly to the Palm Beach Police Department? 
25 
A. No, 1 receive the bill, but it's not an 
9 (Pages 528 to 531) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciuti (801 
Electronically signed by Jeana Rlcciull (601 
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EFTA00298349

Page 532 
1 
itemized bill. It's just a regular bill. I pay it and 
2 
I shred it. 
3 
Q. You pay it, you shred it and then you get 
4 
reimbursed by the Town --
5 
A. The Town offers --
6 
Q. -- a flat sum before — 
A. -- a flat sum, a monthly sum. 
8 
Q. And with which service provider is that? 
9 
A. AT&T. 
10 
Q. And can you give us the number of the cell 
11 
phone that Jane Doe 103 -- that you would have given to 
12 
Jane Doe 103 or other witnesses during this time period? 
13 
A. Hold on one second. 
14 
MS. O'CONNER: Were going to object. If you 
15 
don't want to raise this issue in terms of the cell 
16 
phone records on the motion to compel that's 
17 
pending, we can address it with the court. 
18 
MR. PIKE: les noted. 
19 
MS. CYCONNER: We raised a number of statutory 
20 
objection to producing information regarding his 
21 
cell phone. 
22 
BY MR. WEINBERG: 
23 
. How about e-mails? You mentioned 
24 
[sic]. 
25 
A. That's correct 
Page 534 
1 
Q. To any State Attorney? 
2 
A. Nope. 
3 
Q. To anyone associated with the investigation of 
4 
Jeffrey Epstein? 
5 
A. Norte. 
6 
Q. Same question for your cell phones: I assume 
7 
you have a cell phone other than the cell phone that you 
8 
receive through the Palm Beach PD stipend. 
9 
A. No. This is the only phone I use. 
10 
Q. And that's the phone that's subject to the 
11 
separate inquiry. 
12 
How about reimbursing expenses? When you have 
13 
expenses in connection with, for instance, the Epstein 
14 
investigation, would there be a record of those 
15 
expenses? 
16 
MS. ARBOUR: Form. 
17 
THE WITNESS: We are given investigative funds 
18 
to utilize an investigation, and sometimes --
19 
BY MR. WEINBERG: 
20 
Q. Who would give you the funds? 
21 
A. — sometimes the funds is issued by the 
22 
Detective Bureau sergeant. 
23 
Q. Would they give you a flat amount and leave to 
24 
your discretion the utilization of that amount? 
25 
A. No. The maximum I think they give you is 
Page 533 
1 
Q. Is that an account that you paid for or that 
2 
the Palm Beach Police pays for it? 
3 
A. The Palm Beach Police pays for it. 
4 
Q. Are the copies of your e-mail on the server of 
5 
the Palm Beach Police Department? 
6 
A. Yes. 
7 
MR. PIKE: Can we go off the record for a 
8 
second? 
9 
MS. OtONNER: Yes. 
10 
(Discussion held off the record.) 
11 
BY MR. WEINBERG: 
12 
Q. So the e-mail is 
[sic]. 
13 
Do you have a separate e-mail account, a personal e-mail 
14 
account as contrasted to a public e-mail account? 
15 
A. I do, but that's — lust that for my family 
16 
and nothing work-related. 
17 
Q. So it's your representation that none of the 
18 
witnesses in this case ever e-mailed to you to your 
19 
personal e-mail? 
20 
A. Never. 
21 
Q. And no communications front your personal 
22 
e-mail to Chief Reiter? 
23 
A. No. 
24 
Q. To the FBI? 
25 
A. Nopc. 
Page 535 
1 
$200, and that's to be utilized if you're going out of 
2 
County to pay for gas or if you run into a situation 
3 
with a flat tire, to get a tire replaced or repaired, 
4 
that kind of thing, providing you get a receipt —
5 
Q. What about, you do things on video 
6 
surveillance and you have to continue to buy new 
7 
equipment to film the 24 hours a day of comings and 
8 
goings of a residence; would there be records of those 
9 
purchases? 
10 
A. For equipment? 
11 
Q. Yes. 
12 
A. I'm sum there would be. I don't recall any 
13 
purchases. 
14 
Q. How about travel, did you do any travel in 
15 
connection with the Epstein investigation? 
16 
A. Up to Jacksonville, Tallahassee, all within 
17 
State. You know, we didn't leave. 
• 
18 
Q. You didn't have to travel to New York or to 
19 
any other location? 
20 
A. No. 
21 
Q. Did you ever contact any law enforcement 
22 
officers in any other jurisdiction with the exception of 
23 
this meeting with Special Agent Ortiz and other agents 
24 
of the FBI? 
25 
MS. ARBOUR: Form. 
10 (Pages 532 to 535) 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Moduli (601 
Electronically signed by Jeana RIcduti Mit 
bdcd1878-c720-432d-8cf0-b19ae656129t 
EFTA00298350

Page 536 
Page 538 
1 
THE WITNESS: I think, during the 
2 
investigation, I telephoned New Mexico to see if 
3 
there was any incidences involving the ranch that 
4 
Mr. Epstein owns. 
5 
BY MR. WEINBERG: 
6 
• Q. And what did you learn? 
7 
A. It was a huge ranch, but they didn't have 
8 
anything documented. 
9 
I believe I also called the NYPD to see if 
10 
they bad any incidences involving Mr. Epstein up in New 
11 
York. 
12 
Q. What did you leant? 
13 
A. They had nothing on file after numerous phone 
14 
calls up there, once someone returned your call. 
15 
believe that was it. 
16 
Q. When you went to Tallahassee to serve the 
17 
grand jury subpoena to Jane Doe 103, that was a subpoena 
18 
that required her attendance, was it not? 
19 
A. Yes. 
20 
Q. It was fora given date to come to West Palm 
21 
Beach and to appear in front of a grand jury being 
22 
conducted by the State Attorney? 
23 
A. Yes. 
24 
Q. Did you and her have any conversations 
25 
regarding that subpoena and her compliance obligations? 
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 
correct? 
. 
A. I believe so. 1 documented it in the incident 
report 
Q. But, in fact, nobody got taken care of; nobody 
over got banned in this case, did they? 
MS. ARBOUR: Form. 
THE WITNESS: Not that I'm aware of, no. 
BY MR. WEINBERG: 
Q. And there's no evidence that you're aware of 
that any persons were paid large sums of money not to 
cooperate with you, correct? 
MS. ARBOUR: Forrn. 
THE WITNESS: Not that I'm aware of. 
BY MR. WEINBERG: 
Q. So this is simply Jane Doe 103 telling you 
what 
said, and that was said to you on this 
occasion where she received a grand jury subpoena, 
right? 
A. Yes. 
Q. Did you ever interview 
A. I know that Jane Doe 103 didn't want to pursue 
the natter any further. I know I forwarded that 
information to 
a, 
and I also subpoenaed 
='s 
cell phone records, which indicated phone calls 
to Jane Doe 103 when she indicated she did get the 
Page 537 
1 
A. I'm trying to recall what we discussed. 1 
2 
served her with a subpoena and instructed her to call 
3 
the phone number that was on there to make arrangemans. 
4 
Q. How long were you with her in Tallahassee on 
5 
this occasion? 
6 
A. I'd say about 40 minutes, 50 minutes. 
7 
Q. And did you decide that you were to be the 
8 
person to save the subpoena as contrasted to any of the 
9 
different people working under or with you? 
10 
A. Yes, I am the one who served the other search 
11 
warrant — subpoenas. 
12 
Q. So you served ull of the subpoenas? 
13 
A. Uh-huh. 
14 
Q. And was that the only reason to go to 
15 
Tallahassee that day? 
16 
A. I spoke to her also regarding some phone calls 
17 
that she had received which she felt was threatening in 
18 
nature. 
19 
Q. And what were the results of those 
20 
conversations? 
21 
A. She had received a phone call from =, 
22 
indicating to her that those that are with Mr. Epstein 
23 
will be compensated and those that go against him 
24 
basically would be dealt with. 
25 
Q. We're talking about March or April of 2006, 
Page 539 
1 
threatening calls. 
2 
Q. But did you ever — did_. ever get asked 
3 
whether or not that was a statement that she had made to 
4 
Jane Doe 103? 
5 
A. No, I didn't, again, bes tise Jane Doe 103 did 
6 
not want to pursue the matter. 
7 
Q. So at no time WES 
- did 
testify 
8 
or provide you with anarroboration from Jane Doe 
9 
I03's allegations that 
had conveyed some sort of 
10 
threat to her, correct? 
11 
A. Again, l didn't speak to 
12 
Q. Nor did anyone else in the Palm Beach Police 
13 
Department, to your knowledge? 
14 
A. No, except for that one time I tried to 
15 
interview her at her boyfriend's job. 
16 
Q. Nor did any State Attorney, to the best of 
17 
your knowledge? 
18 
A. No, not that I'm aware of. 
19 
Q. Now, this was the last time you saw Jane Doc 
20 
103? 
21 
A. I believe there was — there were two grand 
22 
jury subpoenas. Yes, this would have been the last time 
23 
I met with her. 
24 
Q. Did you reserve her for the second, the summer 
25 
grand jury? 
11 (Pages 536 to 539) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Jeana Rlcciull (801 
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EFTA00298351

Page 540 
1 
A. The second time, I provided the State where 
2 
they could serve the subpoenas. 
3 
Q. And to your knowledge, was she served a second 
4 
time? 
5 
A. I have no knowledge. 
6 
Q. Do you recall any conversations with her 
7 
regarding that the second grand jury conflicted with her 
8 
school schedule? 
9 
A. That is correct, yes. 
10 
Q. But that was in response to her receiving a 
11 
subpoena? 
12 
A. Yes. I went to Tallahassee, correct 
13 
Q. So you went to 'fallahassee a second time? 
14 
A. Yes. 
15 
Q. To serve her with a second subpoena? 
16 
A. I think the trip — Pm confining the trips. 
17 
There was a trip that I went up to Jacksonville to 
18 
interview her. The second time I went up to see her, ii 
19 
was in Tallahassee. That one time that I went up there 
20 
to save her, we discussed the 
issue, but I 
21 
didn't go back the third time. 
22 
Q. Somebody else served her, to your knowledge? 
23 
A. It would have been the State Attorney's 
24 
office. 
25 
Q. And as a result of her being served a second 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
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Page 542 
A. Yes. I was there. 
Q. In response to a subpoena, correct? 
A. Yes. I was there. 
Q. And did you know whether or not she had bad 
any conversations with anyone other than you about her 
belief that her finals needed to be attended to rather 
than a grand jury subpoena? 
A. That she —
Q. In other words, did you ever speak to the 
State Attorney that she had gotten a pass on appearing 
in front of the grand jury because of her school 
schedule? 
A. Oh, I have no idea. 
Q. All you do know is that the State Attorney was 
waiting for her and she didn't come? 
A. I don't know if she was waiting for her, 
Q. Didn't they expect her to appear and testify 
in response to the subpoena and she failed to appear 
that day? 
A. Again, I don't know the conversations that she 
had with the State Attorney's office. I do know that 
she relayed that information to me. I told her to relay 
that information to the State Attorney's office. I 
was —
Page 541 
1 
time, did she have a conversation with you regarding the 
2 
second subpoena's conflicting with her finals schedule? 
3 
A. Correct 
4 
Q. And she made a phone call to you to complain 
5 
about the service? 
6 
A. Correct. 
7 
Q. And what was the conversation between Jane Doe 
8 
103 and you on that occasion? 
9 
A. It was finals week and she could not leave and 
10 
not take her final to come down for the grand jury. I 
11 
recommended that she contact the State Attorney's office 
12 
and make recommendations through the State Attorney's 
13 
office. 
14 
Q. And did you have any followup with her to see 
15 
if she had been formally excused from the grand jury by 
16 
the State Attorney? 
17 
A. No, 'did not 
18 
Q. Did you leant that she didn't show up at the 
19 
grand jury? 
20 
A. Yes. 
21 
Q. Did you learn that she had not been excused by 
22 
the State Attorney? 
23 
A. I don't think she officially came out and told 
24 
me that she was not excused. 
25 
Q. But you do know that she failed to appear? 
Page 543 
1 
Q. Did you empathize with her conflict? 
2 
A. Absolutely. 
3 
Q. And did you in any way tell her that, I 
4 
understand that your finals are important and you should 
5 
tell the State Attorney that you can't come? 
6 
A. I explained to her that she needed to contact 
7 
the State Attorney's office and make arrangements 
8 
through the State Attorney's office. 
9 
Q. You encouraged her to get excused front the 
10 
grand jury subpoena? 
11. 
MS. ARBOUR: Form 
12 
11IE WITNESS: I reconunended that she contact 
13 
the State Attorney's office and let her know what 
14 
was going on as far as her finals. 
15 
BY MR. WItINI3ERG: 
16 
Q. And whether she did or didn't, you have no 
17 
knowledge? 
A. No, but I was present during the entire grand 
19 
jury, so l blew she wasn't —
20 
Q. That she didn't come? 
21 
A. (Non-verbal response). 
22 
And you don't recall any conversation where 
23 
or any State Attorney informed you that she had 
24 
authorized Jane Doe 103 not to comply with the grand 
25 
jury subpoena? 
PROSE COURT REPORTING AGENCY, 
Electronically signed by Jeans Ricciuti (601
Electronically signed by Jean. Ricciutt (601 
12 (Pages 
540 to 543) 
INC. 
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Page 544 
1 
A. No, 1 don't recall any of those conversations. 
2 
Q. Toll records, you examined some toll records 
3 
in this case, did you not, telephone toll records? 
4 
A. Do you mean itemized records? 
5 
Q. Yes. 
6 
A. Yes. 
7 
Q. And, for instance, you told us there was a 
8 
record between Jane Doe 103 and 
9 
A. Uh-huh. 
10 
a 
And there were records between.. and 
11 
correct? 
12 
A. Correct. 
13 
Q. And it's fair to say that those toll records 
14 
establish connections between two phones, correct? 
15 
A. That is correct 
16 
Q. They don't tell you who was on either end, do 
17 
they? 
18 
A. No. 
19 
Q. They don't tell you the content of the call, 
20 
correct? 
21 
A. No. 
22 
Q. They tell you how long the call was and phone 
23 
numbers connected, but not the content of the call, 
24 
correct? 
25 
A. No, not the content. Date and time. 
Page 546 
1 
now, Sergeant Dawson, but back then it was Detective 
2 
Dawson. 
3 
Q. Were you a participant in that second 
4 
investigation —
5 
A. Yes. 
6 
Q. -- that has a separate case number, an 
7 
'06 number instead of an '05 number? 
8 
A. Correct 
9 
Q. And that investigation lasted until when? 
10 
A. Not very long. It lasted up to when the Feds 
11. 
came in and basically took over. 
12 
• 
Q. Again, I think you said the last time when the 
13 
FBI comes in, it becomes a one-way street? 
14 
A. That is correct. 
15 
Q. And that's been your 20-year experience as a 
16 
State law enforcement officer? 
17 
A. Correct 
18 
Q. And yet, this case, ironically, the Feds were 
19 
invited in by you and Chief Reiter, correct? 
20 
MS. ARBOUR: Form. 
21 
THE WITNESS: Correct. 
22 
BY MR. WEINBERG: 
23 
Q. And this Is the first time you've invited the 
24 
Feds into a State investigation? 
25 
A. I've been a participant in other 
I 
Page 545 
3. 
Q. Anywhere in your investigation, were you ever 
2 
a participant in or hear any phone calls between any of 
3 
the witnesses in this case? 
4 
A. In other words —
5
Q. Let me ask it another way. Did you ever, in 
6 
any way, receive a to 
recording of any telephone call 
7 
engaged in by 
8 
A. No. 
9 
Q. And certainly never received or heard a tape 
10 
recording of Jeffrey Epstein, correct? 
11 
A. No. 
12 
Q. Or anyone else who was associated with the la 
13 
Brftlo residence, correct? 
14 
A. No. 
15 
Q. The only evidence you have of what transpired 
16 
during any call is the message pad and what somebody 
17 
told you happened during a call, correct? 
18 
MS. ARBOUR: Form. 
19 
THE WITNESS: And the toll records. 
20 
BY MR. WEINBERG: • 
21 
Q. And the toll records. Okay. 
22 
Now, after the grand jury returned a charge 
23 
against Mr. Epstein, you conducted a followup 
24 
investigation, did you not? 
25 
A. The followup investigation was initiated by, 
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 547 
investigations where the Feds have come in and worked . 
with us, and Pve assisted than in — 
Q. Sure. But this is the first case where you've 
conducted an over-one-year State investigation of an 
offense that occurred at a residence in Palm Beach and
that the chief of police of your department brought this 
case to the Federal government; is that correct? 
MS. ARBOUR: Form. 
THE WITNESS: Like I said, we've worked with
the FBL Is that what you're trying to get at, in 
the past? 
BY MR. WEINBERG: 
Q. Bringing the case to the FBI, this is what's 
unusual in this case is the chief of police not 
accepting the charged decisions made by the State 
Attorney, brought this investigation over to the United 
States Attorneys office. That's a first for you, isn't 
it? 
MS. ARBOUR: Form. 
THE WITNESS: There were many firsts in this 
case. 
BY MR. WEINBERG: 
• 
Q. This was one of them? 
MS. ARBOUR: Form, asked and answered. 
THE WITNESS: There was — 
13 (Pages 544 
PROSE COURT REPORTING AGENCY, INC. 
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MS. O'CONNER: Is there a question pending? 
2 
MR. WEINBERG: Yes. 
3 
BY MR. WEINBERG: 
4 
Q One of the firsts in this case was that this 
5 
was the first time that your chief of police brought the 
6 
case to the Federal government after a year of State 
7 
investigation, correct? 
MS. ARBOUR: Form, asked and answered. 
9 
THE WITNESS: I believe so. 
10 
BY MR. WEINBERG: 
11 
Q. Now, Mr. Epstein stays at El Brillo, and hes 
12 
there on a periodic basis, at least until this case 
13 
ended up in the Criminal Justice System, correct? He 
14 
would come there at times and be absent at times, 
15 
correct? 
16 
A. Yes. 
17 
MS. ARBOUR: Form. 
18 
BY MR. WEINBERG: 
19 
Q. And the investigation began in March; is that 
20 
right? 
21 
A. Yes. 
22 
Q. And there was an allegation made bye, and 
23 
resulted horn a phone call by her parents, correct? 
24 
MS. ARBOUR: Form, asked and answered. 
25 
THE WITNESS: Yes. 
Page 550 
1 
allegation, there was no attempts to charge Mr. Epstein 
2 
or arrest Mr. Epstein in March, April, May, June, July, 
3 
August and into September of 2005, correct? 
4 
A. Correct. 
5 
Q. And then you picked up this case in late 
6 
September of 2005, correct? 
7 
A. Correct. 
. 
8 
MS. ARBOUR: Form, 
9 
BY MR. WEINBERG: 
10 
Q. And you interviewed M. in the first week of 
11 
October 2005, correct? 
12 
MS. ARBOUR: Form, asked 
13 
THE WITNESS: Correct. 
14 
BY MR. WEINBERG: 
15 
Q. And.. gave you certain corroborating_ 
16 
information that confirmed the information that.. had 
17 
given you about their joint visit In early '05 to 
18 
Mr. Epstein's home? 
19 
A. Correct. 
20 
Q. Correct? 
21 
That led to a request for a search warrant 
22 
rather than a request for an arrest warrant, correct? 
23 
A. Correct. 
24 
Q. And surveillance continued on Mr. Epstein's 
25 
home on occasion when you knew he was in town? 
asked and answered. 
and answered. 
Page 549 
1 
BY MR. WEINBERG: 
2 
Q. And then there were trash pulls that, in some 
3 
respects, were believed to included objects that you 
4 
thought were reflective of anal sex, correct? 
5 
MS. ARBOUR: Form, asked and answered. 
6 
THE WITNESS: Yes. 
7 
BY MR. WEINBERG: 
8 
Q. Yet, there was no attempts to arrest 
9 
Mr. Epstein in April of 2005, were they? 
10 
A. Again, that was when Detective Pagan had that 
11 
case. 
12 
Q. I'm not being critical of you. 
13 
A. No, I'm just saying I don't know. I don't 
14 
know back then what she did. 
15 
Q. Well, you have access to her case file, do you 
16 
not? 
17 
A. Right. 
18 
Q. And you, in fact, on September 22nd, asked 
19 
that the case file be provided to you so that you, as an 
20 
experienced investigator, could kern from the history 
21 
of this case, correct? 
22 
MS. ARBOUR: Form, and asked and answered. 
23 
THE WITNESS: Correct. 
24 
BY MR. WEDIBERG: 
25 
Q. And you knew for six months following the E. 
Page 551 
1 
A. Yes. 
2 
Q. And trash pulls continued, correct? 
3 
A. Correct. 
4 
Q. And your investigation disclosed that the 
5 
youvrwomen going to his home were more than just 
6 
and M., correct? 
7 
A. Correct. 
8 
Q. And yet there was no arrest warrant in October 
9 
or November or December brought against Mr. Epstein, 
10 
correct? 
11 
A. Correct 
12 
Q. And no attempt to initiate a criminal charge 
13 
against him through the end of the year 2005? 
14 
A. Correct. 
15. 
Q. In the beginning of 2006, you continued to 
16 
conduct interviews of women, including.., correct? 
17 
MS. ARBOUR: Form, asked and answered. 
18 
THE WITNESS: Yes. 
19 
BY MR. WEINBERG: 
20 
Q. You continued to do garbage pulls, correct? 
21 
A. In 306,1 don't know if we continued to do 
22 
trash pulls. 
23 
Q. You continued to do surveillances, on 
24 
occasion, of Mr. Epstein's home? 
25 
A. On occasion, I believe. 
14 (Pages 548 to 551) 
PROSE COURT REPORTING AGENCY, .INC. 
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Electronically signed by Jeana Ricciuti (801 
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Page 552 
t'".
-
1 
Q. Studied the results of the seizures of 
1 
reporters and media broadcasters? 
2 
October 20th to try to augment your investigation? 
2 
MS. ARBOUR: Fenn. 
3 
MS. ARBOUR: Form. 
3 
THE WITNESS: I wasn't privy on who he —1 
4 
THE WITNESS: We went through the evidence 
4 
mean, obviously, he's — 
5 
collected, if that's what you're trying to get at, 
5 
BY MR. WEINBERG: 
6 
Yee- 
6 
Q. He's the chief. 
7 
BY MR. WEINBERG: 
7 
A. — hers the chief, you know. 
8 
Q. And yet the first time you executed a probable 
6 
Q. You're the detective. 
9 
cause affidavit was May 1,2006, correct? 
9 
A. Exactly. 
10 
MS. ARBOUR: Form, asked and answered. 
10 
Q. Let me run through a couple of additional 
11 
THE WITNESS: Correct. 
11 
investigators and see whether you actually have ever had 
12 
BY MR. WEINBERG: 
12 
conversations with them, and if you have, then follow it 
13 
Q. And the first time Mr. Epstein was charged was 
13 
up with whether those conversations addressed any part 
14 
late in the summer or during the summer of 2006 by the 
14 
of this communication. 
15 
turn of an indictment for solicitation by the grand 
15 
Richard Fandrey? 
16 
jury, correct? 
16 
A. No. 
17 
A. Correct. 
17 
Q. Kenneth Jenne? 
18 
Q. Now, have you ever spoken to any reporters 
18 
A. Na 
19 
from outside the Palm Beach area — 
19 
Q. Patrick Roberts? 
20 
MS. ARBOUR: Form, asked and answered. 
20 
A. Na 
21 
BY MR. WEINBERG: 
21 
Q. Christina Kitterman? 
22 
Q. — regarding Mr. Epstein? 
22 
A. Uh-uh. 
23 
MS. ARBOUR: Same objection. 
23 
Q. Michael listen? 
24 
THE WITNESS: No. I know we received a lot of 24 
A. No. 
25 
phone calls. We received a lot of phone calls from 
25 
Q. And again, do you have any knowledge that 
Page 553 
Page 555 
1 
different reporters. 
1 
several of these investigators went to Mr. Epstein's 
2 
BY MR. WEINBERG: 
2 
property and entered it at or around 10:00 to 10:30 on 
3 
Q. Do you know whether or not Mr. Reiter was in 
3 
March 17,2010, dressed in black and leaving in a 
4 
touch — former Chief Reiter was in touch with various 
4 
vehicle registered to an investigator named Richard 
5 
reporters? 
5 
Fandrey? 
6 
A. I don't believe so. 
6 
MS. ARBOUR: Form. 
7 
Q. Did he talk to you about having been 
7 
THE WITNESS: No, sir. 
8 
interviewed by Mr. Connolly from Vanity Fair? 
8 
BY MR. WEINBERG: 
9 
A. Not that I'm aware of 
9 
Q. Do you have any knowledge that there was 
10 
Q. Did he talk to you about being interviewed by 
10 
surveillance of an entry onto Mr. Epstein's property by 
11 
anyone from the New York Daily News? 
11 
private investigators connected to this case on any 
12 
A. No. 
12 
occasion? 
13 
Q. New York Post? 
13 
A. No, sir. I was under the assumption that 
14 
A. No. 
14 
Wackenhut was still protecting the property. 
15 
Q. New York Tunes? 
15 
Q. After Mr. Epstein entered his plea and began 
16 
A. (Non-verbal response). 
16 
his service of his sentence, did you receive any 
17 
Q. Any other magazine? 
17 
followup requests for you to conduct investigations of 
18 
A. No, sir. 
18 
him? 
19 
Q. Any local reporters from the media here? 
19 
A. Again, I received a phone call from 
20 
A. Not that I'm aware of. 
20 
Mr. Edwards pertaining to a victim that was not in the 
21 
Q. TV broadcasters looking for news about 
21 
original report I referred him over to the FBI. 
22 
Mr. Epstein? 
22 
Q. Did anyone in the FBI ask you to conduct any 
23 
A. Not that I'm aware of. 
23 
followup investigation of Mr. Epstein? 
24 
Q. Would it surprise you if there was e-mail 
24 
A. No. 
25 
traffic between Chief Reiter and some of the local 
25 
Q. And that includes the time he was in jail? 
15 (Pages 552 to 555 
PROSE COURT REPORTING AGENCY, INC.' 
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1 
A (Non-verbal response). 
2 
Q. The time he was on work release, no request? 
3 
A. None. 
4 
Q. The time he was on probation, community 
5 
control? 
6 
A. No. 
7 
Q. So you've never received an FBI request to, in 
8 
any way, investigate Mr. Epstein? 
9 
A. No. 
10 
Q. Surveille Mr. Epstein? 
11 
A. No. 
12 
Q. Report to them any of your knowledge of 
13 
Mr. Epstein's ongoing conduct? 
14 
A. No. 
15 
Q. Same question for the US Attorney's office: 
16 
Have they ever initiated a call to you at any time after 
17 
Mr. Epstein went to jail asking you to do anything in 
16 
connection to their ongoing investigation of 
19 
Mr. Epstein? 
20 
A. Absolutely not. 
21 
Q. And what about Probation? Has Probation ever 
22 
asked you to initiate any surveillance or investigation 
23 
of Mr. Epstein? 
24 
A. No. Aside from that ono day that I saw him 
25 
walking on the — along South Ocean Boulevard, that was 
1 
Probation Department? 
2 
A. As far as I'm concerned, yeah. As far as I 
3 
know. 
4 
Q. On that occasion, he was how far from his home 
5 
when you saw him? 
6 
A. From El Brillo to Clark and the ocean, fd say 
7 
about a mile, mile and a half. 
8 
Q. And Clark is north of El Brillo? 
9 
A. Yes, north of Royal Palm Way. 
Io 
Q. And in other words, coming this way from 
11 
Mr. Epstein's house, from south to north? 
12 
A. Yes. 
13 
Q. Right? 
1 4 
A. Yes. 
15 
Q. And Mr. Epstein's office is north of his 
16 
house, correct? 
17 
A. Northwest. 
18 
Q. Northwest, so north and then west. You'd have 
19 
to go over a bridge, right? 
20 
A. Right. 
21 
Q. And the bridge that's closest to his office is 
22 
north of his house? 
23 
A. Actually, this one right here, Okeechobee. 
2 4 
Okeechobee Boulevard right here. 
25 
Q. So he would go over Okeechobee Boulevard and 
Page 557 
1 
it. That was the only — and I didn't even contact 
2 
Probation. I believe Captain Frick (phonetic) is the 
3 
one who contacted Probation and something Sloan 
4 
(phonetic). 
Q. Are you aware of any — putting yourself aside 
and putting this ono incident aside, arc you aware of 
the Palm Beach Police Department having any ongoing role 
in the investigation of Jeffrey Epstein? 
A. As far as today? 
Q. Yes, as of today. 
A. No. 
Q. How about at any time over the past year, 
starting with the time he was out on work release and 
thereafter on commtmity control —
A. There did no — 
Q. — house arrest? 
A. — investigation, not that I'm aware of. 
Q. Is the one occasion the only time that you or 
anyone working with you spoke to Probation about 
Mr. Epstein's ongoing activities? 
A. That was the only time I think —
Q. That you were involved? 
A. Yes. 
Q. And is it the only time that you are aware 
that anyone else has had communications to and from the 
Page 559 
1 
end up at his office, and Clark is between El Brillo and 
2 
Okeechobee Boulevard, correct? 
3 
A. Actually, Clark is north of Okeechoboo 
4 
Boulevard. 
5 
Q. So is there a second bridge just to the north 
6 
of Okeechobee? 
7 
A. Yes, there is a north bridge. 
8 
Q. What's the name of that bridge? 
9 
A. The North Bridge. 
10 
Q. And that's a bridge that comes west from Rahn 
11 
Beach? 
12 
A. Yes. 
13 
Q. And ends up in this community of offices that 
14 
includes Mr. Epstein's office? 
15 
A. If his office was in Mr. Goldberger's Office, 
16 
the quickest route would have been on Okeechobee. 
17 
Q. But one of the route — you have to get off 
18 
the beach, right? 
19 
A. Correct. 
20 
Q. And there's two bridges that are connecting 
21 
the beach to the Palm Beach financial district, one 
22 
being Okeechobee and one being the bridge to the north 
23 
of it? 
24 
MS. ARBOUR: Form, asked and answered. 
25 
THE WITNIZS: Right. There is one south, too, 
16 (Pages 556 to 559) 
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Electronically signed by Joana Ricciutl (601 
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Page 560 
1 
fin sorry. I didn't want to just make you think 
2 
there was only two bridges. 
3 
BY MR. WEINBERG: 
4 
Q. That's way south. 
5 
A. That's southern. 
6 
MS. ARBOUR: Objection, form. 
7 
BY MR. WEINBERG: 
8 
Q. You had a thumb drive that you gave to the 
9 
FBI? 
10 
A. Yes. 
11 
Q. And the thumb drive consisted of what? 
12 
A. The thumb drive consisted of photographs of 
13 
the victims, some of my supplements that were saved onto 
14 
the thumb drive. That was turned over to the FBI. 
15 
Q. Are those records that are on the thumb drive 
16 
also in the public records of the Palm Beach Police 
17 
Department, or were there additional —
18 
A. Those were actually my personal thumb drives. 
19 
Q. Those were your personal thumb drives? 
20 
A. Yeah. 
21 
Q. Was everything on it also in the case file? 
22 
A. Yes. 
23 
Q. So the photographs are in the case file? 
24 
A. Yes. 
25 
Q. And these photographs came from driver's 
Page 562 
1 
residence — Mr. Epstein's residence? 
2 
A. I'm trying to think. I can't recall. it's 
3 
been a while since I've seen those. 
4 
Q. Was Ms... somebody that was interviewed by 
5 
you in '05 or '06? 
6 
A. It might have been'06 when I interviewed her. 
7 
Q. And she was one of the ova 18 people that —
8 
A. Correct 
9 
Q. -- that you ended up interviewing in phase two 
10 
of your investigation of Mr. Epstein? 
11 
MS. ARBOUR: Fenn, asked and answered. 
12 
THE WITNESS: Yes. 
13 
BY MR. WEINBERG: 
14 
Q. And you interviewed about how many people that 
15 
told you they engaged in consensual adult activities 
16 
with Mr. Epstein? 
17 
MS. ARBOUR: Form. 
18 
THE WITNESS: It's tough to say. I don't 
19 
know, less than ten. I don't know. 
20 
BY MR. WEINBERG: 
21 
Q. And of the other people, taking Jane Doe 103 
22 
out and taking out the one other person who you 
23 
mentioned who had the digital penetration that stopped 
24 
when she withdrew, the other people told you that they 
25 
consented to go to Mr. Epstein's home, correct? 
1 
license photos of the different witnesses? 
2 
A. Driver's license photos and some of the 
3 
yearbooks that wore collected. 
4 
Q. Were there surveillance of Mr. Epstein's 
5 
residences? Have you seen than since September of 2005? 
6 
A. What do you mean *surveillances'? 
7 
Q. When you, assuming there were videos taken of 
8 
Mr. Epstein's residence --
A. Correct, yes. 
Q. — it showed the comings and goings of him? 
A. Correct. 
Q. And did you watch them? 
A. I saw some of than, yes. 
Q. And did it show any particular people going 
into Mr. Epstein's home that you identified? 
A. Yes, and she was subsequently interviewed as 
well. 
Q. And what was her name, if you remember? 
A. 
She was overage. 
Q. So she was one of the group of people that was 
over 18? 
A. Correct, and an aspiring model. She brought 
her portfolio ova and did some minor modeling at the 
house. 
Q. Anybody else seen on these videos entering a 
Page 561 
Page 563 
1 
MS. ARBOUR: Form. 
2 
THE WITNESS: Well, what do you mean 
3 
"consented"? 
4 
BY MR. WEINBERG: 
5 
Q. They did so voluntarily. 
6 
MS. ARBOUR: Same objection. 
7 
THE WITNESS: Right. Nobody was bound and 
8 
gagged. 
9 
BY MR. WEINBERG: 
10 
Q. Not only bound and gagged, but they made a 
11 
decision that they were — 
12 
MS. ARDOUR: Form, asked and answered. 
13 
THE WITNESS: Right, they were going to go to 
14 
the house. 
15 
BY MR. WEINBERG: 
16 
Q. And they, one way or the other, drove to 
17 
Mr. Epstein's residence from wherever they lived or 
18 
worked? 
19 
MS. ARBOUR: Form, and asked and answered. 
20 
BY MR. WEINBERG: 
21 
Q. Is that correct? 
22 
MS. ARBOUR: Same objection. 
23 
THE WITNESS: Some of them took taxis. 
24 
BY MR. WEINBERG: 
25 
Q. Some of them got driven by friends and some oi 
 
3 
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PROSE COURT REPORTING AGENCY, INC. 
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Page sc..: 
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- them drove themselves, correct? 
2 
MS. ARBOUR: Form, asked and answered 
3 
THE WITNESS: Correct. 
4 
BY MR.. WEINBERG: 
5 
Q. And they all made a decision to drive their 
6 
cars or get into a taxi to be driven or to get into 
7 
their friends' cars to go to El Brine Way? 
8 
MS. ARBOUR: Form, and asked and answered 
9 
THE WITNESS: Correct. 
10 
BY MR. WEINBERG: 
11 
Q. They then told you, as a matter of routine and 
12 
practice, that they either were dropped off, parked 
13. 
their cars and entered the first floor of Mr. Epstein's 
14 
home, correct? 
15 
MS. ARBOUR: Form. 
16 
THE WITNESS: Correct 
17 
BY MR. WEINBERG: 
18 
Q. They went inside and were greeted by someone 
19 
and often brought upstairs to the second floor, correct? 
20 
MS. ARBOUR: Form, and asked and answered. 
21 
THE WITNESS: Correct. 
22 
BY MR. WEINBERG: 
23 
Q. MI., for instance, when you interviewed her, 
24 
said that on her first occasion, she was taken there by 
25 
a Mend, went in the first floor door and was taken 
2 
3 
4 
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6 
7 
8 
9 
10 
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12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
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24 
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BY MR.. WEINBERG: 
Q. And that they would be paid for it? 
A. Yes. 
MS. ARBOUR: Form, and asked and answered.
BY MR. WEINBERG: 
Q. M. also told you that she told them to 
represent themselves as 18 years old, correct? 
MS. ARBOUR: Form. 
THE WITNESS: I don't know if she said that 
they have to be 18, unless — if it's documented in 
the report, then it is. 
BY MR. WEINBERG: 
Q. At least some of the girls told you that, in 
fact, they told Mr. Epstein — they were directed to 
tell Mr. Epstein they were 18 and, in fact, they did? 
MS. ARBOUR: Form. 
THE WITNESS: I know that on several 
occasions, some of the girls said, you know, that 
they knew that Mr. Epstein knew that they were in 
high school, that they were asked what high school 
they attended, what grade they were in, that kind 
of thing. 
BY MR. WEINBERG: 
Q. And other girls, I iko M., told you that they 
were told that they needed to say they were 18, they 
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Page 565 
upstairs to the second floor, correct? 
A. Correct. 
Q. She told you she gave Mr. Epstein a massage, 
correct? 
A. Yes. 
Q. She told you Mr. Epstein perceived that she 
was uncomfortable giving him a massage? 
A. Yes. 
Q. And that Mr. Epstein told her she didn't have 
to or shouldn't — not didn't have to — strike that —
but she wouldn't be asked to do what she was 
uncomfortable with a second time? 
MS. ARBOUR: Form. 
THE WITNESS: Correct. 
BY MR. WEINBERG: 
Q. 
thereafter, said that she brought six 
people to Mr. Epstein's home? 
A. Correct. 
Q. AndMold you that on each and every one 
of them, she told them precisely what they were going to 
be asked to do, which was to give a massage to 
Mr. Epstein in various states of undress, correct? 
MS. ARBOUR: Form, and asked and answered. 
THE WITNESS: Yes. 
Page 567
1 
needed to represent themselves as 18 if asked, and that 
2 
she did represent herself to be an I8-year-old when she 
3 
made her single visit to Mr. Epstein's home in the early 
4 
part of 2005, correct? 
5 
MS. ARBOUR: Form, and asked and answered. 
6 
THE WITNESS: That's the interview that 
7 
Detective Pagan conducted. 
8 
Can I just have two minutes? 
9 
(A brief recess was taken.) 
10 
BY MR. WEINBERG: 
11 
Q. FBI agents, you had several meetings with them 
12 
after this meeting with Special Agent Ortiz? 
13 
A. T believe I had one more meeting with 
14 
Kirkendahl and someone else. 
15 
Q. Do you recall where that meeting occurred? 
16 
A. I believe it was at the US Attorneys office. 
17 
Q. In Palm Beach? 
18 
A. West Pah». 
19 
Q. West Palm? 
20 
And was that a meeting at which you reviewed 
21 
the evidence that you then collected pursuant to your 
22 
role as the case agent in charge of the '05 Epstein 
23 
case? 
24 
A. I believe I gave Agent Kirkendahl a summary of 
25 
the case. There was another agent in there, 1 can't 
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recall his name. 
2 
Q. Does Jason Richards ring a bell? 
3 
A. Jason came in after the fact, but there was 
4 
someone else in there. Jason wasn't present in that 
5 
meeting. 
6 
Q. And this was the second meeting, the first one 
7 
being with the Chief and Ortiz -
8
A. Correct. 
9 
Q. — and the other one being with Kidcendahl and 
10 
the second agent; is that correct? 
11 
A. Correct. 
12 
Q. And this meeting got more detailed in terms of 
13 
your giving the FBI agents, in essence, an overview of 
14 
the results of your State investigation? 
15 
A. Correct 
16 
Q. And did you give them evidence at this time? 
17 
A. I don't believe so. 
18 
Q. Did you review evidence with them? 
19 
A. I might have had with me a small case file 
20 
which had flight logs -- which had some of the flight 
21 
logs, that I may have shown them. 
22 
Q. And those would have been flight logs that 
23 
would have derived from where? 
24 
A. Mr. Dashowitz. 
25 
Q. Was Mr. Dershowitz brought the flight logs to 
Page 570 
1 
A. I signed it out on the 3rd and returned it on 
2 
the 4th. 
3 
Q. And what did you sign out on the 3rd? 
4 
A. Items No. 1 through 5, 8 through 12,5 through 
5 
I7, 20 to 22. 
6 
Q. And these were items that reflect evidence 
7 
that was seized on October 20th from Mr. Epstein's home? 
8 
A. Right. It would probably be the page right 
9 
before this one. 
10 
Q. And you checked it out on the 3rd and returned 
11 
it on the 4th because you wanted to view it with the 
12 
FBI; is that correct? 
13 
A. Correct_ 
14 
Q. And that's October 3, 2006, correct? 
15 
A. Correct. 
16 
Q. And if we then go back to what has been 
17 
separately admitted into evidence here — I don't recall 
18 
the exhibit number, but 
showing you what appears to
19 
be a property receipt dated October 20th that has 
20 
numbers 1 through 58, and ask you whether or not those 
21 
four handwritten pages, numbered 1 through 58, arc the 
22 
log of evidence that was taken from Mr. Epstein's home 
23 
on October 20th, pursuant to your execution of the State 
24 
search warrant. 
25 
A. Correct. 
Page 569 
1 
the State Attorney? 
2 
A. Correct. 
3 
Q. And that was in connection with his efforts to 
4 
persuade the State Attorney that the State Attorney 
should reject the initiatives of the Palm Beach Police 
6 
Department for nue serious charges? 
7 
A. 1 believe so. 
3 
Q. And do you recall reviewing the message pads 
9 
at any time with the FBI agents? 
10 
A. I may have had some copies. Like I said, l 
11 
had a small case file; that I didn't bring the entire 
12 
case. I may have had some. 
13 
Q. And there would have been some report on the 
14 
chain of custody log regarding your having checked out 
15 
various exhibits to review and then retwn; is that 
16 
possible? 
17 
A. What I had was copies. 
18 
Q. So I'm showing you a supplement for a chain of 
19 
custody, a Palm Beach property receipt. And if you 
20 
would just refresh your recollection from the lower two 
21 
lines and see if that provides us with some reflection 
22 
regarding the review of evidence. 
23 
A. Correct. 
24 
Q. And what does that tell you now that your 
25 
memory is refreshed? 
Page 571 
1 
Q. And the numbers that appear on that inventory 
2 
log as having been checked out by you on the 3rd of 
3 
August correspond to the numbers that are on the 
4 
inventory from the search of October 20th, correct? 
5 
A. Correct 
6 
Q. And so it's clear from reading those two 
7 
documents together, that on October 3rd — strike 
8 
that — on August 3, 2006, you were reviewing with the 
9 
FBI the results of your search and seizure dating back 
10 
to October 20, 2005, correct? 
11 
A. Correct. 
12 
Q. And you were showing them things like message 
13 
pads, correct? 
14 
A. Correct. 
15 
Q. And you were informing them that the message 
16 
pads, in some respects, corroborated what you informed 
17 
them were the results of your witness interviews? 
18 
A. Correct 
19 
Q. And you, in essence, were using the evidence 
20 
that came from Mr. Epstein's home to demonstrate that 
21 
there was support for these narratives that were given 
22 
to you by your various witness interviews that you began 
23 
to conduct in October of 2005, correct? 
24 
A. COrrect. 
25 
Q. And I through 5 are largely the phone message 
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book from the kitchen, the phone message book from the 
2 
cacti off the kitchen, the file folder of messages, 
3 
shredded paper from the office, an orange folder marked 
4 
"Messages: correct? 
5 
A. Correct. 
6 
Q. And then in addition, there were pictures --
7 
A. I think the orange folder was massages. 
8 
Q. Marked 'Message," it says here, M-E-S-S-Afir-E. 
9 
A. Okay. 
10 
Q. M-E-S-S-A-G-E, right? 
11 
Is this your handwriting? 
12 
A. No. 
13 
• Q. Okay. And then there were photos that are 
14 
numbered 8 through 12. If I can — since 1 don't have a 
15 
second copy of this., do you mind if I just read with 
16 
You — 
17 
A. Absolutely. 
18 
Q. -- so we can shortcut this already lengthy 
19 
afternoon? 
20 
8 through 12 are the photos of difference 
21 
pictures taken from Mr. Epstein's home. 
22 
A. Correct 
23 
Q. And then 15 through 17 were more photos and 
24 
more message books taken from the rust floor, correct? 
25 
A. Uh-huh. 
Page 574 
1 
they were returned. 
2 
Q. Do you recall whether they were returned with 
3 
the rest of the houseman's possessions? 
4 
A. I don't believe so. 
5 
Q. What was returned to the houseman were copies 
6 
kept by the Palm Beach Police Department? In other 
7 
words, were they copied and the originals were returned 
8 
to the houseman? 
9 
A. No. Items that belonged to the houseman were 
10 
returned right to the houseman. 
11 
Q. And no copies were kept by the Palm Beach 
12 
Police Department? 
13 
A. No. 
14 
Q. And therefore, none were turned over to the 
15 
FBI when they executed their later subpoena, correct? 
16 
A. They all were turned over. 
17 
Q. To the houseman? 
18 
A. To the FBI. 
19 
Q. So the FBI got copies of everything that 
20 
appears on items 1 through 58 of the search warrant 
21 
inventory? 
22 
A. Items that belonged to Mr. Janusz were given 
23 
back to him. His personal computer, his external media, 
24 
his photo discs for his camera, those were returned. 
25 
Q. Was his computer reviewed before it was 
Page 573 
Q. And then you checked out 20 through 22, which 
2 
was photos from his desk and from a table in the first 
3 
floor office? 
4 
A. Correct 
5 
Q. And then you went to 26 to 30, which were more 
6 
pictures, transcript? That's Jane Doe 103,1 assume? 
7 
A. Correct 
8 
Q. So videotapes of what turned out to be adult 
9 
pornography, correct? 
10 
A. Yes. 
11 
Q. More pictures? 
12 
A. Yes. 
13 
Q. And then 49 and 50 were two message books, 
14 
correct? 
15 
A. Correct. 
16 
Q. And they came from the separate standalone 
17 
residence that is called the guest house, correct? 
18 
A. Correct. 
19 
Q. And those ultimately were message books that 
20 
were in the possession of one of Mr. Epstein's 
21 
employees, correct? 
22 
A. The houseman, yes. 
23 
Q. But they were returned to the houseman; is 
24 
that correct? 
25 
A. The message books? It would indicate there if 
Page 575 
1 
returned? 
2 
A. Yes. 
3 
Q. And it was, in other words, your forensic team 
4 
or your Sheriffs forensic team 
5 
A. The Sheriffs office. 
6 
Q. 
reviewed the computer? 
7 
A. Correct 
8 
Q. And by reviewing the computer, they image de 
9 
computer, do they not? 
10 
A. Uh-huh. 
11 
Q. And they look through the image in order not 
12 
to upset the authenticity of the different files and 
13 
folders that were in the original seized computer, 
14 
correct? 
15 
A. Correct 
16 
Q. Because you didn't know what was in the 
17 
computer, did you? 
18 
A. Correct. 
19 
Q. So in the event there was something there that 
20 
would be evidence, you didn't want to copy it and change 
21 
the modification dates by looking at the original; is 
22 
that right? 
23 
A. Correct. 
24 
Q. So what happens is that the forensic team's 
25 
law enforcement, what they did in this case, they imaged 
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the Dell computer that was taken from the guest house? 
2 
A. Correct. 
3 
Q. The image of the Dell computer was reviewed, 
4 
correct? 
5 
A. Correct 
6 
Q. As were different CPU units that were seized, 
7 
one on the first floor and one on the second floor of 
8 
Mr. Epstein's residence, correct? 
9 
A. 'believe there was only one on the first 
10 
floor. I don't believe there was one on the second 
11 
floor. 
12 
Q. So there was an additional CPU unit. What is 
13 
a CPU? 
14 
A. Like, a computer processing tmit. 
15 
Q. And that was imaged as well, correct? 
16 
A. Correct 
17 
Q. And the image was looked through there as 
18 
well? 
19 
A. Correct 
20 
Q. And the only piece of evidence that you 
21 
thought might be of value was a vahazy, dim lighted 
22 
picture of someone that might ben? 
23 
A. Correct There was video images of that. 
24 
Q. But you couldn't tell for sure and, therefore, 
25 
you'd be candid with us and say, I'm not 100 percent 
Page 578 
1 
Q. So die image was retained as evidence? 
2 
A. It was a packet of like CDs that contained the 
3 
images of that. 
4 
Q. Of his compute?? 
5 
A. His computer and the other CPU computer. 
6 
Q. And those were retained and not returned? 
7 
A. Correct. 
8 
Q. And then they were ultimately part of the 
9 
subject of the grand jury subpoena that the Palm 
10 
Beach — 
11 
A. Correct 
12 
Q. — PD produced —
13 
A. Correct. 
14 
Q. - later in August; is that correct? 
15 
A. Yes, sir. 
16 
Q. So that, if I'm clear, the computer forensic 
17 
procedures used on Janusz's computer, the Dell compute:, 
18 
were identical to those that would be used on any seized 
19 
computer, which is a complete and thorough computer 
20 
review of the image of the hard drive of the seized 
21 
computer? 
22 
A. Correct. 
23 
Q. And it's essentially they just an A tot 
24 
search to see whether or not the computer contains any 
25 
file or folder or e-mail or data or picture that would 
1 
sure that it was..? 
2 
A. It might be somebody else. 
3 
Q. And that was the CPU that connected to the 
4 
first floor camera, correct? 
5 
A. Correct. 
6 
Q. And that was the same CPU that was seen in 
7 
2003 to reflect the identify of the thief that was 
8 
stealing the money from Mr. Epstein's desk? 
9 
A. Possibly. 
10 
Q. It was the same connection? There was a 
11 
camera on the first floor directed at Mr. Epstein's 
12 
desk? 
13 
A. Correct. 
14 
Q. And the photos went into a separate unit? 
15 
A. Correct. 'at, I do remember. 
16 
Q. And there was nothing of value that was seen 
17 
in Mr. Epstein's fust floor desk or office that was 
18 
recorded by this camera that was in the clock, correct? 
19 
A. Correct. 
20 
Q. No sex, no massage, just a man at his desk? 
21 
A. Correct. 
22 
Q. Now, when the Dell computer was returned to 
23 
Janusz from a complete search by the forensic team, was 
24 
the image of the computer returned to him as well? 
25 
A. I don't believe so. 
Page 577 
Page 579 
1 
be consistent and further your investigation? 
2 
A. I don't believe there were e-mails. I think 
3 
it was file pictures or any data, but I don't think eve 
4 
went into e-mails. 
5 
Q. So you know these computers contain, 
6 
essentially, a mountain of information when they are 
7 
regularly used? 
8 
A. Correct. 
9 
Q. And what was done by your forensic team is to 
10 
essentially skim or scan through or review this mountain 
11 
of data to see if any one file or folder or piece of 
12 
data was consistent with and furthered your 
13 
investigation? 
14 
A. Correct 
15 
Q. And in terms of this Dell computer, the answer 
1.6 
was none? 
17 
A. Right. 
18 
Q. And in terms of the CPU that was taken from an 
19 
area on the first floor of Mr. Epstein's house, there 
20 
was none with the exception of a single image that was 
21 
bard to see and might be a? 
22 
A. There were segments of videos, but again, the 
23 
lighting was poor, so... 
24 
Q. And again, when you went in there on 
25 
October 20th with a warrant, you had no allegation from 
I 
I 
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