EFTA00298342

Page 580 
1 
any particular witness that thae would be anything on 
2 
any of those computers that would be a porn photo, for 
3 
instance? 
4 
MS. ARBOUR: FO(111. 
5 
BY MR. WEINBERG: 
6 
Q. No one told you that? 
7 
A. No. 
8 
Q. Now, this was the first shoe that you had a 
9 
discussion with Agent Kirkendall regarding the Epstein 
10 
investigation, August 3rd or 4th of 2006? 
11 
A. I believe the first time was with Junior, the 
12 
second time was with ICiiitendahl and another agent 
13 
Q. Do you have any memos or notes of that meeting 
14 
or were you essentially seeing them as a witness to 
15 
their investigation? I mean — strike that 
16 
Did you take any notes of that meeting? 
17 
A. No, I did not take any notes. 
18 
Q. And what did you see your role as at that 
19 
meeting? 
20 
A. Providing them, basically, a synopsis of the 
21 
case and answering any questions that they may have. 
22 
Q. Do you recall any particular questions? 
23 
A. I knew that one of the questions were, did any 
24 
of the victims fly out of the country with Mr. Epstein. 
25 
At that point, I had that packet of some of the flight 
Page 582 
1 
A. Pretty much. 
2 
Q. And did you physically bring them the case 
3 
materials? 
4 
A. No. They came to the police department and 
5 
took possession of them. 
6 
Q. Was this a fourth meeting with them? 
7 
A. No. That was the mating. 
0 
Q. In other words, they called you in advance and 
9 
said they were coming with a subpoena, please —
10 
A. We're coming with a truck and subpoena, get 
11 
everything ready. 
12 
Q. And they got the results of the search and 
13 
seizure from October 20th; is that right? 
14 
A. Well, everything — 
15 
Q. Everything on your inventory list. 
16 
A. Everything but what belonged to Janusz. That 
17 
went back to him. 
18 
Q. Except what you imaged that belonged to 
19 
Janusz, which was maintained and turned over pursuant to 
20 
the subpoena? 
21 
A. Correct 
22 
Q. Second is that you gave them all of the 
23 
physical results of the trash pulls, correct? 
24 
A. Correct. 
25 
Q. Both those that occurred in March and April 
I 
1 
1 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 . 
Page 581 
logs, so... 
Q. Which came to you from Mr. Epstein's lawyer --
A. Right. 
Q. — through the State Attorney? 
A. But there was several that were missing, so... 
Q. The ones you had reflected no trips on 
Mr. Epstein's plane by any of the persons that you 
identified as being people who went to his house — 
A. That's —
Q. — in your case, correct? 
A. Thaes pretty much correct 
Q. Was there a third meeting with the FBI? 
A. The third meeting I think it was when they 
showed up with the grand jury subpoena requesting all 
info on the case. 
Q. And did you have a substantive discussion with 
them on that occasion, or was it just an occasion where 
they served the subpoena on you as the person to whom —
A. They served a subpoena on nit as the person who 
had the information. 
Q. And it was a broad subpoena that essentially 
asked you for everything? 
A. Everything. 
Q. And you produced everything because that's 
what you do when you get a federal subpoena? 
Page 583 
1 
under the aegis of Officer Pagan or the Burglary Task 
2 
Force, and those that were conducted under your 
3 
investigatory supervision, correct? 
4 
A. Correct 
5 
Q. And did you watch the trash pulls or was that 
6 
something you said you assigned to others to watch? 
7 
A. That was assigned to others to watch. 
8. 
Q. And they'd report to you that they watched it? 
9 
A. And they actually conducted their supplements. 
10 
Q. And physically, they took the bag of garbage 
11 
from the garbage man, right? 
12 
A. Correct. 
13 
Q. By pre-arrangement, correct? 
14 
A. Uh-huh. 
15 
Q. At a place close to Mr. Epstein's home but 
16 
inaccessible to his vision, correct? 
17 
A. Correct. 
18 
Q. And they then took that bag back to the Palm 
19 
Beach Police Department and searched within it for 
20 
evidence, correct? 
21 
A. Correct. 
22 
Q. And that bag, to your knowledge, was taken 
23 
from within Mr. Epstein's property gates? 
24 
A. Correct. 
25 
Q. inside the gates. And it happened on occasion 
22 (Pages 580 to 583) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Joana RiccitlE (601M 
Electronically signed by Joana Ricciull (601 
bdcd1876-0726-4326411410431964656129f 
EFTA00298362

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 S84 
two and three times a week? 
A. I believe so. 
Q. And it happened at times that there wouldn't 
be on limey garbage runs at Mr. Epstein's house? 
A. Once a week there is a recycle pickup day. 
Q. And did you participate in the search through 
the garbage? 
A. No. 
Q. But others did and you directed them as to 
what to look for, correct? 
A. Correct. 
Q. Evidence of Mr. Epstein's meetings with or 
phone call — strike that. Evidence of Mr. Epstein's 
meetings or relationships to different witnesses in your 
case? 
A. Correct. 
Q. Leads to new witnesses, correct? 
A. Correct. 
Q. And you got leads to new witnesses from the 
garbage pulls, correct? 
A. Correct. 
Q. And then you got more leads to new witnesses 
from message pads that were seized from Mr. Epstein's 
home on October 20th? 
A. Correct. 
Page 586 3 
1 
and that's when Jason stepped in. 
2 
Q. Did you have any communications with Jason? 
3 
A. I can't recall if l did or didn't. 
4 
Q. And how about with any of the United States 
5 
Attorneys, did you have any substantive communications 
6 
with anyone in the upper hierarchy of the US Attorney's 
7 
office? 
 
1 
A. No. 
9 
Q. So there was no conversations between you and 
1 
10 
the US Attorney? 
11 
A. No. 
12 
Q. The acting US Attorney? 
13 
A. No. 
14 
Q. The head of criminal? 
15 
A. No. 
16 
Q. And how about the US Attorney in charge of the 
17 
investigation of Mr. Epstein? 
18 
A. No. 
19 
Q. No meetings involved with Ms. 
20 
A. Na 
21 
Q. All of your carununications were with FBI 
22 
agents, and you've provided us with the details 
23 
regarding those meetings. And there were really 
24 
primarily two meetings; one attended by Chief Reiter 
25 
between.you and Special Agent Ortiz, and then the 
I 
Page 585 
Q. Now, the FBI came and the file was essentially 
checked out on October 28, 2006 at 1:30 p.m.? 
A. Where it says TOT FBI? Yeah. 
Q. Did you have any occasion to meet with the FBI 
after October 28 -- or after August 28, 2006? 
A. I think I was telephoned once by Agent 
7 
Kirkendahl requesting clarification on something, and 
8 
then I would call her, hey, how's everything going, can 
9 
you share anything, and no, 1 never got any response 
10 
back as far as what was going on or... 
11 
Q. Do you recall what the subject was that the 
12 
FBI agent asked you about, Agent Kirkendahl? 
13 
A. No. 
14 
Q. And so that was the last substantive 
15 
communication with Agent Kirkendahl? 
16 
A. Like I said, I would call her. 
17 
Q. Right, but those were essentially, what can 
18 
you tell - 
19 
A. Nothing. 
20 
Q. There was no content to those? 
21 
A. No, no. 
22 
Q. And what about the male agent that you 
23 
remembered meeting with Agent Kirkendahl that was on 
24 
August 4, 2006? Did you ever have a followup with him? 
25 
A. Shortly thereafter, I think he loft the FBI, 
Page 5R7 
1 
followup meeting which this evidence log reflects 
2 
occurred on August 3rd or 4th wherein you reviewed 
3 
largely the results of the search and seizure of 
4 
Mr. Epstein's home on October 20, 2005? 
5 
A. Correct 
6 
Q. Mr. Reiter, Chief Reiter or former 
7 
Chief Reiter, how often do you speak to him since he 
8 
left office? 
9 
A. I've seen him maybe two or three times and 
10 
spoken to him maybe a handful of times. 
11 
Q. Do you know whether or not he is employed or 
12 
planning to be employed as a private investigator? 
13 
A. I have no idea. 
14 
Q. Do you know whether he was ever employed by 
15 
the Rothstein firm? 
16 
A. I have no idea. 
17 
Q. Do you know whether or not he's engaged in any 
18 
private investigation in connection with any of the 
19 
Plaintiffs' cases against Mr. Epstein? 
20 
A. I have no idea. When we speak, we don't speak 
21 
about business. 
22 
Q. Understandably, given that you're being 
23 
deposed. 
24 
Before (Thief Reiter left and, in fact, before 
25 
the Plaintiffs' lawyers instituted these civil lawsuits, 
PROSE COURT 
Electronically signed by Jeana Ricautt (601 
Electronically signed by deans RIcetun 0101 
gIV•SS - ' 
.--IrraWCWO“••••••••••
•• 
23 (Pages 584 to 587) 
REPORTING AGENCY, INC. 
bdcd1876,c72o 432c1.8cf0-b19ao656129f 
EFTA00298363

Page 588 
1 
though, you and the Chief would see each other 
2 
regularly, correct? 
3 
A. Yes. 
4 
Q. In fact, you and the Chief would e-mail each 
other regularly regarding matters of common interests; 
6 
is that correct? 
7 
A. Yes. 
8 
Q. And you and the Chief would c-mail each other 
9 
about interests including the ongoing efforts of the 
10 
media to find out what's going on in the Epstein case? 
11 
A. Yes, through Goo& alerts and things he would 
12 
come across and things I would come across, I would send 
13 
to him. 
14 
Q. In other words, Reiter to Ramey, 
15 
September 6, 2007, 'Channel 5 ran a major story on 
16 
Epstein at 6:00. Showed footage of Epstein at PBIA and 
17 
audio of Connolly from Vanity Fair saying Epstein would 
18 
take a plea as early at tomorrow, signed Reiter." 
19 
Do you remember that one? 
20 
A. Yes. 
21 
Q. Or Reiter to Recarey, December 10,2008, 
22 
'Shiny Shade advised me they're naming her article 
23 
tomorrow that Epstein's on work release. Read it 
24 
online. Please notify Nesbitt. Thanks, Reiter." 
25 
Do you recall following that direction and 
Page 590 
1 
last week. 
2 
Q. So you don't know about all these c-mails that 
3 
have been disclosed to us through public record searches 
4 
reflecting e-mails between Chief Reiter and the 
5 
different members of the media wherein he's keeping them 
6 
in touch with the events connected to the Epstein case9
7 
A. No. 
8 
Q. Or his e-mail to the US Attorney's office, 
9 
saying, "Contrary to your information, you may note that 
10 
nothing in the story relative to the plea was attributed 
11 
to me, as I have not discussed this case with the news 
12 
media." 
13 
Are these not e-mails that you remember or 
14 
that you were copied on? 
15 
A. No. I'm the low man on the totem pole. 
16 
Q. I understand. That's why there's a chief and 
17 
the rest of us. 
18 
A. And many wigwams. 
19 
MR. WEINBERG: May I have one minute with my 
20 
co-courtsel? This depo may be concluded. 
21 
(A brief recess was talon.) 
22 
MIL WEINBERG: In the interest of speed, 
23 
say thank you for a long day, Detective Recarey. 
24 
I'm finished. 
25 
THE WITNESS: Thank you very much. 
Page 589 
1 
notifying — 
2 
A. I may have called her and left her a voice 
mail, Nesbitt Kirkendahl. Like I said, everything with 
the FBI is one way. They don't share the information. 
A lot of times I would call her desk line and it goes 
right to voice mail, so I would just leave her thc 
information and... 
8 
Q. Can you recall as an aftermath of that 
information regarding work mleuse that there was some 
10 
discussions as to whether or not Mr. Epstein's contract 
11 
required him to do day-to-day in prison, meaning to 
12 
serve 18 months, or whether instead he had to be 
13 
sentenced to 18 months which would make him eligible for 
14 
work release and that the conclusion was that he was 
15 
eligible for work release like all others? 
16 
A. Correct 
17 
Q. And do you recall Mr. Reiter, Chief Reiter, 
18 
having ongoing communications with a Joyce Reingold at 
19 
the PB Daily News in the fall of 2008? 
20 
A. I have no idea. 
21 
Q. But you knew Unlike waste chief and he was 
22 
the contact person for a lot of the media•to-police 
23 
communications? 
24 
A. Actually, Janet Consuelo is the — well, was 
25 
the PIO for the Police Department. She just retired 
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 591 
CROSS (DETECTIVE JOE RECAREY) 
BY MS. ARBOUR: 
Q. Detective, the search warrant that you 
executed on 358 El Brillo Way, prior to the execution in 
October of 2005, did you do any research on who the 
property owner was? 
A. Yes. 
Q. And were you able to determine who owned that 
FroPa1Y? 
A. Yes. I believe it was Mr. Epstein, but I 
think it was under a corporation. 
Q. Did you do any research on potential residents 
at that address? 
A. Yes. 
Q. And do you recall who you identified as a 
potential resident, if anyone? 
A. Mr. 
ein,l believe 
and 
MMTM 
Q. Did you determine that it was an address used 
by Jeffrey Epstein? 
A. Yes. 
Q. The message pads that you seized during the 
search warrant in October of 2005, do you recall how 
many there were? 
A. Five, five or six, I think. 
PROSE COURT 
Electronically signed by Jeana Rlcciutl (601
Electronically signed by Jeana McGinn (601 
24 (Pages 588 to 591 
REPORTING AGENCY, INC. 
bdcd1876-c72e-432d-Ilet0-b19a4561291 
EFTA00298364

Page 592 
Page 594 
1 
Q. Does that include the ones that were 
2 
ultimately returned to Mr. Janusz? 
3 
A. None were returned to Mr. Janusz. 
4 
(Deposition Exhibit No. 29 was marked for 
5 
identification.) 
6 
BY MS. ARBOUR; 
7 
Q. I'll show you what I've marked as 29, and It 
8 
represent to you that I got those from a public records 
9 
request from the State Attorney. I'll ask you to flip 
10 
through them and ask you if that seems to be all the 
11 
ones that you seized. 
12 
A. This was three message books. This would be 
13 
No. 2 on the property receipt. 
14 
Q. So would there be an additional two or three 
15 
message books malted as No. 1 or something on the 
16 
property receipt? 
17 
A. There would be No. 1, No. 2. On the search 
18 
warrant return, you would see the different ones that 
19 
bad the different message books. 
20 
Q. Do you recall, of all of the message books 
21. 
that you reviewed, not just the one in May ljust marked 
22 
as 29, what time period they covered? 
23 
A. Off the top of my head, no, I couldn't tell 
24 
you. 
25 
Q. Do you know if they extended into 2004? 
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 
Q. At any time. 
A. I recall a lot of names. Would you know, more 
or less, what page? 
Q. The truth is, I'm not even sure if she's in 
there. • 
just asking if her name's in there. 
A. Oh, I can't recall. 
Q. Do you recall seeing the name Jane Doe 4 on 
any of those messages? 
A. Yes. 
Q. Do you recall seeing the name Jane Doe 3 on 
any of those messages? 
A. I can't recall. 
Q. How about Jane Doe 6? 
A. No, I'm sorry. 
Q. How about Jane Doe 7? 
A. Yes. 
Q. And how about Jane Doe 8? 
A. Yes, I remember Jane Doe 8. 
Q. 
you recall seeing a 
or a 
A. Yes. 
Q. Do you recall seeing the name M.? 
A. Yes. 
Q. ChM. Okay. 
Did you ever speak with 
at 
Page 593 
1 
A. I knew we got current books and older books, 
2 
but I couldn't tell you the time frame. 
3 
Q. Do you recall what rooms the message pads were 
4 
taken from inside the main residence at El Brillo? 
5 
A. There was some taken from the small office in 
6 
the kitchen area, there was some taken from the kitchen 
7 
area, there was some taken from — there was some taken 
8 
from the guest house, I believe the pool house and then 
9 
there is like a little pantry area. There was, I think, 
10 
a book taken from there too. 
11 
Q. And when you say the pool house, is that the 
12 
room that Mr. Epstein or someone used as an office out 
13 
by the pool? 
14 
A. Yes. There was like a pad, you know, like a 
15 
writing -- like an old grease marker pad. 
16 
Q. Obviously, since I got those as part of a 
17 
public records, a lot of them are redacted. Must 
18 
going to ask you if you recall seeing any of the 
19 
following names on the pads. Anything you need to refer 
20 
back, that's fine. 
21 
Do you recall seeing the name Jane Doe 2 on 
22 
any of those messages? 
23 
A. Can I refer? 
24 
Q. Absolutely. 
25 
A. Do you know, more or less, when? 
Page 595 
1 
any point during your investigation? 
2 
A. It doesn't ring a bell. 
3 
Q. Do you recall speaking to anyone who informed 
4 
you that they brought a girl named Jane Doe 8 to 
5 
Mr. Epstein's house? 
6 
A. No. 
7 
Q. Do you recall ever speaking to a girl who 
8 
informed you that she brought Jane Doe 6 to 
9 
Mr. Epstein's home? 
10 
A. No. 
11 
Q. During your execution of the search warrant in 
12 
October 2005, did you recover any vibrating massagers? 
13 
A. I remember a twin torpedo, but no. 
14 
Q. What is a twin torpedo? 
15 
A. Double sided — 
16 
Q. Okay, some type of sex toy? 
17 
A. Yeah. 
18 
Q. Which room did you recover that from? 
19 
A. That was from a back bedroom. 
20 
Q. Do you recall — I'm sorry, did you recover 
21 
any lotions from within a bathroom? 
22 
MR. PIKE: Form. 
23 
THE WITNESS: From a small credenza, there was 
24 
a lotion 
there was a lotion in a small credenza 
25 
in the master bedroom, a little Joy Jelly bottle. 
25 (Pages 592 to 595) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciuti (601 
Electronically signed by Jeana Ricetull (601 
bdcd1876-c720-432d-Bc10-b19ae8561291 
EFTA00298365

Page 596 
Page 598 
BY MS. ARBOUR: 
2 
Q. And the master bedroom, was that the same 
3 
master bedroom you understood to be the massage room? 
A. Yes. 
Q. Turning back to your testimony about reviewing 
the phone records for Ms. 
and Mr. Epstein I 
1 
believe you said you reviewed as part of your 
i 
investigation. 
9 
A. Yes. 
10 
Q. When you reviewed Ms. 
phone records, 
11 
what period of time did those phone records cover? 
12 
A. I don't 'mow the specific time frame. 
13 
Q. Do you recall if it covered only 2005? 
14 
A. Possibly. I don't recall but... 
15 
Q. Would it be noted in the probable cause 
16 
affidavit? 
17 
A Probably in the incident report 
18 
Q. You can flip through if that helps to refresh 
19 
your recollection. 
20 
A. I wouldn't even know where to find it at this 
21 
point. 
22 
Q. You believe it's in the incident report, 
23 
though? 
24 
A. I believe so. 
25 
Q. And would it be the same time period that 
I 
been made? 
2 
A. I believe so. 
3 
Q. Were you able to cross reference any of the 
4 
witnesses with Mr. Epstein's phone records? 
5 
A. I only subpoenaed the house phone records 
6 
because there was no indication of anything on his cell. 
7 
But there was, I believe, some phone calls made to the 
8 
victims/witnesses from the house. 
9 
Q. And did you do any research to find out who 
10 
was the registered user of that house phone? 
11 
A. It was registered to Mr. Epstein. 
12 
Q. Were you able to confirm that Ms 
13 
placed or received any phone calls from Jane We 
14 
during your review of ha records? 
15 
A. Yes. 
16 
Q. Were you able to confirm that Ms. 
17 
received or made any phone calls to Jane Doe 7? 
18 
A. Yes. 
19 
Q. Were you able to confirm that Ms. 
20 
or received any phone calls from Jane Doe 3? 
21 
A. I can't recall if there were any calls to 
22 
Jane Doe 3. 
23 
Q. Were you able to confirm that any phone calls 
24 
had been made or received by the house phone by 
25 
Jane Doe 4? 
made 
Page 597 
I 
covered Mr. Epstein's phone records as Ms. M? 
2 
A. I believe Mr. Epstein's was not as in depth as 
3 
Ms. 
4 
Q. And with regard to the phones, did you pull 
S 
the phone records for the house phone itself or cellular 
b 
phones for each of the people? 
7 
A. I believe it was Ms. 
cell phone and 
house phone records. 
Q. At any point, were you able to match up 
10 
victims with Ms. 
phone records where there had 
11 
been some communication between the two of them? 
12 
A. Yes. 
13 
MR. PIKE: Form. 
14 
BY MS. ARBOUR.: 
15 
Q. Were any of those victims under the age of 18 
16 
at the time the phone calls were made? 
17 
MR. PIKE: Form. 
18 
l'HE WITNESS: I believe so. 
19 
MS. ARBOUR: Is your objection to the use of 
20 
the word "victim"? 
21 
MR. PIKE: Yes. 
22 
BY MS. ARBOUR: 
23 
Q. Were any of the witnesses that you were able 
24 
to cross reference with Ms. 
phone records under 
25 
the age of 18 at the time the phone calls appear to have 
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 599 
MR. PIKE: Form. 
114E WITNESS: I believe so, yes. 
BY MS. ARBOUR: 
Q. Were you able to cross reference any phone 
calls received front or made to Jane Doe 7 from the house 
phone? 
A. I can't recall brim the house phone, Pm 
sorry. 
Q. What you interview — as part of your 
investigation, you interviewed Janusz Banasiak: is that 
correct? 
A. Yes. Well, I take that back. I attempted it. 
That never happened. 
Q. At any point, did you come to Team that he 
rented a car for Jane Doe 4 to use? 
A. Yes. 
Q. And how did you learn that? 
A. Through Jane Doe 4. 
Q. And what did she tell you? 
MR. PIKE: Form 
THE WITNESS: When I interviewed her, she told 
me that there was a rental car for her use that she 
was utilizI9L- actually, when I went down to talk 
to her at 
University, I actually found the car 
parked in the school lot. 
26 (Pages 596 to 599) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciutl (601 
Electronically signed by Jeana Ricciutl (601 
'1561) 832-7506 
bded1676-072•432d-W0-019ae656129t 
EFTA00298366

Page 600 
1 
BY MS. ARBOUR: 
2 
Q. What did she tell you about how she came to 
3 
acquire that car? 
4 
A. She needed a car to get around. 
5 
MR. PIKE: Fonn. 
6 
THE WITNESS: She asked Mr. Epstein if he 
7 
could raft her a car, at which time there was a 
8 
rental car available to her. 
9 
BY MS. ARBOUR: 
10 
Q. And you went back and researched who, in fact, 
11 
rented that car; is that right? 
12 
A. Correct. 
13 
Q. And that was Mr. Banasiak? 
14 
A. Yes. 
15 
Q. When you met with each of the witnesses, each 
16 
of the girls who had later — who you suspected may have 
17 
been at Mr. Epstein's house, did you tape record each 
18 
and every single one of the interviews? 
19 
A. Yes. 
20 
MR. PIKE: Form. 
21 
BY MS. ARBOUR: 
22 
Q. And when the incident report says that a 
23 
statement is sworn, that you took a sworn statement from 
24 
a witness, what does that mean? 
25 
A. Where 1 swear them in. I made them raise 
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 602 
partial truth, and she did not elaborate any further. 
Q. Did any of the other girls that you 
interviewed give you that same impression, that they 
were holding back or not telling the truth? 
MR. PIKE: Form. 
THE WITNESS: I also had that feeling from 
Jane Doe 7. 
BY MS. ARBOUR: 
Q. What is it about Jane Doe 7 that gave you that 
feeling? 
MR. PIKE: Form. 
THE WITNESS: The fact that she was extremely 
nervous, extremely scared when talking about the 
investigation. 
BY MS. ARBOUR: 
Q. When you spoke with Jane Doe 7, do you recall 
if any of her parents were home? 
A. Yes, her mother was present. 
Q. Was she in the same room as Jane Doe 7 or was 
she in a different room, do you recall? 
A. She was in a different room. 
Q. How did you know to go and interview Jane Doe 
7 as part of your investigation? 
A. That name was given to me 
Q. Did she indicate that Jane Doe 7 was one of 
Page 601 
1 
their right hand and, do you solemnly swear to tell the 
2 
truth, the whole truth and nothing but the truth_ 
Q. Are those the exact words that you used? 
1 
A. Yes. 
Q. Have you since learned that some of those 
.3 
girls that you interviewed did not tell you the entire 
7 
truth about what happened at Mr. Epstein's house? 
8 
MR. PIKE: Form. 
9 
TIM WITNESS: I had heard, I believe, Jane 
10 
Doe 4 was not truthful, 100 percent truthful. 
11 
BY MS. ARBOUR: 
12 
Q. During the course of your entire 
13 
investigation, did you ever have an opinion or a feeling 
14 
that maybe one or more of the girls was holding back on 
15 
what happened at Mr. Epstein's house? 
16 
MR. PIKE: Form. 
17 
THE WITNESS: Yes. 
18 
BY MS. ARBOUR: 
19 
Q. Can you tell me more about that? 
20 
A. I actually went to interview Jane Doe 4 twice 
21 
because I had that feeling from her when 1 spoke with 
22 
her. I actually went dam to 
twice to speak to 
23 
her. On the second time that 1 went down to speak to 
24 
her, I told her the reason why I came down was that 1 
25 
felt she was being untruthful, or at least telling me a 
Page 603 
1 
the girls she brought to Mr. Epstein's home? 
2 
A. Yes. 
3 
Q. What did you tell Jane Doe No. 7's parents 
4 
about why you were there to interview Jane Doe 7, if you 
5 
recall? 
6 
A. Pretty much same as I told all, I believe that 
7 
they were either a victimaitness to an investigation 
8 
that I was conducting about an individual that lived 
9 
within the Town of Palm Beach. 
10 
Q. When you met with Jane Doe 7 and spoke with 
11 
her, did she cry? 
12 
A. She was scared and she was nervous. We were 
13 
sitting -- the first time I went out to her house, she 
14 
was not home. We waited for a little while and 
15 
eventually we lett, not knowing what time she was going 
16 
to be back. When I received a phone call the following 
17 
morning, 'went back out there and she was visibly 
18 
scared. You could tell, she was shaking. 
19 
Q. During the course of your interview, did she 
20 
tell you that Mr. Epstein touched her buttocks? 
21 
MR. PIKE: Form. 
22 
BY MS. ARBOUR: 
23 
Q. You eventually interviewed her, correct? 
24 
A. Yes. 
25 
Q. During the course of that interview, did she 
27 (Pages 600 to 603) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Rlcciuti (601 
Electronically signed by Jeana RIcclutl (601 
bdcd1876-c720-432d-8cf0-b19ae6561291 
EFTA00298367

1 
2 
3 
4 
5 
6 
7 
8 
9 
Page 604 
tell you that Mr. Epstein touched her buttarles? 
MR. PIKE: Form. 
MS. ARBOUR: I believe so. 
BY MS. ARBOUR: 
Q. During the course of that interview, did she 
tell you that he =shit-bated in front of her? 
MR. PIKE: Form. 
THE WITNESS: I believe so. 
BY MS. ARBOUR: 
1 
2 
3 
4 
5 
6 
7 
8 
9 
Page 606 
A. Yes. 
Q. During the course of your interview with 
Jane Doe 7, did she tell you that she was paid to give 
Mr. Epstein massages during which he touched her in a 
sexual way? 
MR. PIKE: Form. 
THE WITNESS: Yes. 
BY MS. ARDOUR: 
Q. Did you interview a girl named Jane Doe 3 as a 
10 
Q. During the course of your interview did 
10 
part of your investigation? 
11 
Jana Doe 7 play you a voice mail from Ms. M? 
11 
A. Yes, I did. 
12 
A. Yes. 
12 
Q. How did you know to speak with Jane Doe 3? 
13 
Q. What do you remember about that voice mail? 
13 
A I think this was another name provided to me 
14 
MR. PIKE: Form. 
14 
bY 
15 
THE WITNESS: It was a voice mail left on her 
15 
Q.Do you recall if.lane Doe 3 told you that M. 
16 
cell phone from 
asking Jane Doe 7 to 
16 
was the one who arranged for her to go to Mr. Epstein's 
17 
call her and let her know what I was looking into. 
17 
house? 
18 
BY MS. ARBOUR: 
18 
MR. PIKE: Form. 
19 
Q. Did Jane Doe 7 tell you that 
had called 
19 
THE WITNESS: I believe so. 
20 
multiple times during the investigation? 
20 
BY MS. ARBOUR: 
21 
MR. PIKE: Form. 
21 
Q. At any point during your conversations with 
22 
THE WITNESS: Yes. 
22 
Jane Doe 3, did she tell you that she was paid to give 
23 
BY MS. ARBOUR: 
23 
Mr. Epstein a massage in which he touched her in a 
24 
1QpWhat is your understanding of how many times 
24 
sexual manna? 
25 
Ms. 
called Jane Doe 7? 
25 
MR. PIKE: Ram. 
Page 605 
Page 607 
1 
A. I believe approximately three times that 
1 
THE WITNESS: That is correct. 
2 
evening. 
2 
BY MS. ARBOUR: 
3 
Q. Did you ever review Jane Doe 7 or Ms. 
3 
Q. Did she tell you that Mr. Epstein touched her 
4 
phone records to see how many phone contacts there were 
4 
buttocks? 
5 
that day or within that period? 
5 
MR. PIKE: Form. 
6 
A. Again, I can't recall how many or the time 
6 
THE WITNESS: Yes. 
7 
frame of the phone records. 
7 
BY MS. ARBOUR 
8 
Q. Did Jane Doe 7 tell you that Ms. 
was 
8 
Q. Did she tell you that Mr. Epstein touched her 
9 
the one she spoke with in order to arrange Mr. F-pstcin's 
9 
breasts? 
10 
massages? 
10 
MR. PIKE: Same objection. 
11 
MR. PIKE: Form. 
11 
THE WITNESS: Yes. 
12 
TUE WITNESS: Yes. I do recall 
12 
BY MS. ARBOUR 
13 
BY MS. ARBOUR: 
13 
Q. Did she tell you that he masturbated in front 
14 
Q. Was it your understanding that.4sr 
14 
of her? 
15 
would call her or she would call Ms. 
or did you 
15 
MR. PIKE: Same objection. 
16 
get into that at all with her? 
16 
THE WITNESS: Yes. 
17 
MR. PIKE: Form. 
17 
BY MS. ARBOUR: 
18 
THE WITNESS: How it was told to me was 
18 
Q. Did you ascertain from Jane Doe 3 If she knew 
19 
would call like a day or two prior to their arrival 
19 
you were investigating Mr. Epstein before you went to 
20 
to Palm Beach, to coordinate a time and a date when 
20 
speak with her? 
21 
they were going to be in the Town of Palm Beach, 
21 
MR. PIKE: Form. 
22 
and if she was interested in working. 
22 
THE WITNESS: I interviewed.., who is an 
23 
BY MS. ARBOUR: 
23 
associate of hers as well, and I had interviewed 
24 
Q. So Ws your understanding Ms. 
would 
24 
her prior to Jane Doe 3. 
25 
make a phone call to Jane Doc 7 to schedule work? 
25 
iI 
28 (Pages 604 to 607) 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciutl (601 
Electronically signed by Jeana RIccluti (601 
bdcd1876-c72c-432d-8c10-b19ae6561291 
EFTA00298368

I 
Page 608 
BY MS. ARBOUR: 
1 
Page 6101 
occurred at Mr. Epstein's house; is that correct? 
1 
2 
Q. Did Jane Doe 3 indicate to you that she was 
2 
A. Correct. 
3 
expecting you to come by or that someone had told her 
3 
Q. Did she tell you that she —
4 
that you were investigating? 
4 
MR. PIKE: Form. 
5 
MR. PIKE: Form. 
5 
BY MS. ARBOUR: 
6 
. THE WITNESS: Someone had told her. 
6 
Q. — went to Mr. Epstein's house more than one 
/ 
BY MS. ARBOUR: 
7
time? 
8 
Q. Was it your understanding that M. told her 
8 
MR. PUCE: And form to this question. 
9 
there was an investigation? 
9 
THE WITNESS: Yes. 
10 
MR. PIKE: Same. 
10 
BY MS. ARBOUR: 
11 
ME WITNESS: I believe so. 
11 
Q. How many times did she tell you that she went
12 
BY MS. ARBOUR: . 
12 
to Mr. Epstein's house to give him a massage? 
13 
Q. Did Jane Doe 3 ever tell you that she was paid 
13 
MR. PIKE: Form. 
14 
to bring other underaged girls to Mr. Epstein's house 
14 
(Mr. Epstein left the proceedings.) 
15 
for massages? 
15 
MR. PIKE: You can continue. 
16 
MR. PIKE: Form. 
16 
THE WITNESS: I can't— I don't know. 
17 
THE WITNESS: I can't recall if she did or she 
17 
MIL PIKE: May I ask a quick question? Do you 
18 
didn't. 
18 
need to terminate at 5:00? 
19 
BY MS. ARBOUR: 
19 
MS. O'CONNER: No. Thank you, though. 
20 
Q. Would it help to refer back to the PC? Do you 
20 
BY MS. ARBOUR: 
21 
have it there? 
21 
Q. Would it help to look at the PCA, page 9? 
22 
A. Yeah. 
22 
A. Yes. Okay. 
23 
Q. I think page 8 is Jane Doe 3. 
23 
Q. Did she tell you how many times she went to 
24 
MR. PIKE: Same objection to the extent the 
24 
Mr. Epstein's house to give hint a massage? 
25 
question is pending. 
25 
MR. PIKE: Form. 
Page 609 
Page 611 
1 
THE WITNESS: Yes. 
1 
THE WITNESS: A lot is what she claimed. 
2 
BY MS. ARBOUR: 
2 
BY MS. ARBOUR: 
1 
Q. Yes, she did tell you that? 
3 
Q. And over what period of time do you understand 
4 
MR. PIKE: Form 
4 
she was going to Mr. Epstein's home to give him these 
() 
THE WITNESS: That she had gone back to the 
5 
massages? 
house with.. on two other occasions. 
6 
A. Since she was 16. 
7 
BY MS. ARBOUR: 
7 
MR. PIKE: Form. 
8 
Q. Did she tell you who she generally spoke with 
8 
BY MS. ARBOUR: 
9 
in order to make arrangements to go to Mr. Epstein's 
9 
Q. What is your understanding of how she came to 
10 
house for these massages, whether she was providing them 
10 
Mr. Epstein's house for the first time? 
11 
or another girl was? 
11 
A. I believe she was taken to the house by.. 
12 
MR. PIKE: Form. 
12 
Q. And did she tell you on her subsequent visits 
13 
THE WITNESS: The het that she went with 
13 
how she would make arrangements to get to Mr. Epstein's 
14 
M., so I'm sure they would contact M. 
14 
house, if she would call Ms. 
or if she would call 
15 
BY MS. ARBOUR: 
15 
the house, or can you walk me through what she told you 
16 
Q. Did you ever pull 
's phone records as a 
16 
about how she got there? 
17 
part of your investigation? 
17 
MR. PIKE: Form. 
18 
A. I believe they were pulled by Detective Pagan. 
18 
THE WITNESS: if
 refer to it? 
19 
Q. Do you know how many times, if any, there was 
19 
BY MS. ARBOUR: 
20 
convene — or there were phone calls between 
.'s 
20 
Q. Absolutely, go ahead. 
21 
22 
number and lane Doe 3's number on those records? 
A. No. 
21 
22 
A. Okay. 
Q. 
she toll you that she would call 
23 
Q. Lee 
on 
s focus 
your interview with Jane Doe 4, 
23 
Ms. a 
to make arrangements to come ova and give 
24 
or your interviews with Jane Doe 4. At some point, she 
24 
Mr. Epstein massages? 
25 
did discuss or she did give you a version of events that 
25 
MR. PIKE: Form. 
r. 
29 (Pages 608 to 611) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana RICOinti (601 
Electronically signed by Jeans Riecluti (601 
bdcd1876.c720-432d-13c10-b19ae6561291 
EFTA00298369

Page 612 
Page 614 
1 
THE WITNESS: Correct. 
2 
BY MS. ARBOUR: 
3 
• Q. Didshe tell you that IVIs. 
would call 
4 
her to make arrangement to come over and give 
5 
Mr. Epstein a massage? 
6 
 
MR. PIKE: Form. 
7 
THE WITNESS: On occasion. 
8 
BY MS. ARBOUR: 
9 
Q. Did she tell you that she would make 
10 
arrangements through.. to go ova to Mr. Epstein's 
11. 
house to give him a massage? 
12 
A. Initially. 
14 
number on 
phone records, specifically, 
Q. Didyou ever cross reference Jane Doe 4's 
13 
15 
that you recall? 
16 
A. Jane Doe 4, I do remember on her cell phone. 
17 
Q. And do you recall if Jane Doe 4's number 
18 
appeared on Ms. 
phone records? 
19 
A. Jane Doe 4, I believe so, yes. 
20 
Q. Do you know if you looked specifically to see 
21 
if any of Ms. 
phone records indicated 
22 
communication between Jane Doe 4 and Ms. 
23 
strike that, let me start over. 
24 
Do you recall looking at phone records prior 
25 
to June of 2005 to see if there veere any cross 
Min 
1 
BY MS. ARBOUR: 
2 
Q. And did Jane Doe 4 tell you if Mr. Epstein 
3 
ever touched her buttocks? 
4 
MR. PIKE Form. 
5 
THE WITNESS: Yes. 
6 
BY MS. ARBOUR: 
7 
Q. Did Jane Doe 4 tell you that Mr. Epstein 
8 
touched her breasts? 
9 
A. Yes. 
10 
MR. PIKE: Fonn. 
11 
BY MS. ARBOUR: 
12 
Q. Did Jane Doe 4 tell you that Mr. Epstein 
13 
touched her genitals? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: That, I don't recall. 
16 
BY MS. ARBOUR: 
17 
Q. Did Jane Doe 4 tell you that Mr. Epstein 
18 
performed oral sex on her? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: No. 
21 
BY MS. ARBOUR: 
22 
Q. Did Jane Doe 4 tell you that Mr. Epstein used 
23 
a vibrator or a vibrating massager on her? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: She claimed that the vibrator 
Page 613 
1 
references prior to Jane Doe 4 turning 187 
2 
A. I don't know. I can't recall the time frame 
3 
of the cell phone records. 
4 
Q. Do you recall if, at the time
 did End 
Jane Doe 4's number on Ms. ME records, Jane Doe 4 
6 
was under 187 
7 
A. Not - fin not sure because I don't know the 
8 
time frame I have the cell phone records from. 
9 
Q. Did Jane Doe 4 tell you that Mr. Epstein 
10 
touched her in a sexual manner on more than one 
11 
occasion? 
12 
A. Yes. 
13 
Q. Did she tell you that Mr. Epstein masturbated 
14 
in front of her? 
15 
MR. PIKE: Form to the last question, and fans 
16 
to this question. 
17 
THE WITNESS: Yes. 
18 
MR. PIKE: You're just too fast. 
19 
MR. GARCIA: I join. 
20 
BY MS. ARBOUR: 
21 
Q. Did Jane Doe 4 tell you that she was nude in 
22 
front of Mr. Epstein during the massages she gave him? 
23 
MR. PIKE: Form. 
24 
THE WITNESS: I believe down to her thong 
25 
underwear. 
Page 615 
1 
was not used on her. She knew of the vibrator, but 
2 
it was not used on her. 
3 
BY MS. ARBOUR: 
4 
Q. Is it your understanding that when — when 
5 
Jane Doe 4 — so going back to what she did tell you, 
6 
which is that he touched her buttocks and her breasts at 
7 
least, was it your understanding that those incidents 
8 
occurred when she was under the age of 18? 
9 
MR. PIKE: Form, move to strike. 
10 
THE WITNESS: Yes. 
11 
BY MS. ARBOUR: 
12 
Q. Did she tell you that the touching of the 
13 
buttocks and the touching of the breasts occurred before 
14 
she was 18? 
15 
MR. PIKE: Font 
16 
THE WITNESS: She had been going there since 
17 
the age of 16. I can't recall if she said she was 
18 
under 18 when he was touching her buttocks and 
19 
breasts. 
20 
BY MS. ARBOUR: 
21 
Q. When you interviewed Jane Doe 4, where did the 
22 
interview take place? 
23 
A. 
University. 
24 
Q. And was it in a particular place, in a 
25 
particular room, or — 
30 (L'ages 612 to 615) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Moduli (601 
Electronically signed by Jeana Riccluti (601 
bdcd1876-c72c432d-8cfrittga06561291 
EFTA00298370

rage 616 
1 
A. It was in a small office room within — next 
2 
to the PE room. 
3 
Q. And was anyone else present? 
4 
• 
A. Detective Dawson. 
) 
Q. And did Jane Doe 4 — during the course of 
6 
your interview, was Jane Doe 4 crying? 
A. She was shaken, nervous and occasionally she 
8 
would ay. 
9 
Q. Was that the first interview or the second 
10 
interview that took place —
11 
A. The first one. 
12 
Q. — in that room? 
13 
A. The first one. 
14 
Q. Where did the second interview take place? 
15 
A. She had just finished playing soccer. I want 
16 
to say — the second one, I believe, was in the PE area. 
17 
It was like a gym, like a gymnasium. 
18 
Q. And in that second interview, was she crying 
19 
when she spoke with you? 
20 
A. I can't recall if she was or if she wasn't. I 
21 
know the first one she was. 
22 
Q. Did she ever ask you if she was in trouble for 
23 
what happened at Mr. Epstein's house? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: I don't recall. 
Page 618 
1 
Q. The number that's on there, 635-3454, do you 
2 
see that? 
3 
A. Yes. 
4 
Q. Did you do any investigation into that number? 
5 
A. Yes. 
6 
Q. And what did you find it to be? 
7 
A. I believe that was Jane Doe 4's number. 
Q. And how about the other number that's on 
9 
there, 324-7996, did you investigate that number? 
10 
A. I believe I did request subscriber information 
11 
on that. I can't recall who that came back to, though. 
12 
MS. O'CONNER: Can we go off the record for .1 
13 
minute? 
14 
MS. ARBOUR: Sure. 
15 
(Discussion held off the record.) 
16 
BY MS. ARBOUR: 
17 
Q. Did you ask Jane Doe 4 about this note? 
18 
A. No. 
19 
Q. Why not? 
20 
A. I felt that she was holding back from Inc, so I 
21 
didn't want to let her know what I knew. I stressed to 
22 
her that I !mew a lot more than what I was letting on 
23 
to, but she continued with her limited story. 
24 
Q. At any point, did Jane Doe 4 tell you that she 
25 
bad told Mr. Epstein about the police investigation? 
Page 617 
1 
BY MS. ARBOUR: 
2 
Q. Do you recall if any of the witnesses that you 
3 
interviewed asked if they were in trouble for what 
4 
happened at Mr. Epstein's house or for what they say 
5 
happened at Mr. Epstein's house? 
6 
MR. PIKE: Rom. 
7 
THE WITNESS: I recall s was concerned that 
3 
she might have been — be getting into trouble. 
9 
BY MS. ARBOUR: 
10 
Q. Let me show you this, marked 30. 
11 
(Deposition Exhibit No. 30 was marked for 
12 
identification.) 
13 
BY MS. ARBOUR: 
14 
Q. Detective, have you seen that document before? 
15 
A. Yes. 
16 
Q. And what are you recognizing this document to 
17 
be? 
18 
A. It is from a memo pad, from Mr. Epstein's memo 
19 
pad. It's a sheet. 
20 
Q. Did you recover this document from a trash 
21 
pull that you did on Mr. Epstein's residence? 
22 
A. Yes. 
23 
Q. There's a name that's redacted on there. Do 
24 
you remember if that name was Jane Doe 4? 
25 
A. Yes. 
Page 619 
1 
MR. PIKE: Fonn. 
2 
THE WITNESS: I can't recall if she said 
3 
anything. 
4 
BY MS. ARBOUR: 
5 
Q. Do you recall if any of the witnesses that you 
6 
spoke with told you that they told Mr. Epstein about the 
7 
police investigation, your investigation? 
8 
MR. PIKE: Form. 
9 
THE WITNESS: I believe ■., when I 
10 
interviewed her in Orlando. 
11 
BY MS. ARBOUR: 
12 
Q. Did that interview take place before or after 
13 
Jane Doe 4's first interview? 
14 
A. After. 
15 
Q. And what did you and M. discuss about her 
16 
reporting to Mr. Epstein about your investigation? 
17 
MR. PIKE: Form. 
18 
THE WITNESS: That she had been contacted 
19 
prior to me by a private investigator and wanted to 
20 
know what she knew about the police investigation 
21 
and wanted her to call the investigator after I 
22 
would leave. 
23 
BY MS. ARBOUR: 
24 
Q. Did she tell you who this supposed 
25 
investigator worked for 
PROSE COURT 
31 (Pages 616 to 619) 
REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciuti (601 
Electronically signed by Jeana Ricciuti (601 
bdcd1876-c726-432dabilin666129f 
EFTA00298371

Page 620 
1 
MR. PIKE: Form. 
2 
BY MS. ARBOUR: 
3 
Q. — that had called her? 
4 
MR. PIKE: Same. 
5 
THE WITNESS: I want to say Mr. Black's 
6 
office. 
7 
BY MS. ARBOUR: 
Q. Do you recall the name of the investigator she 
9 
told you was trying to contact her? 
10 
MR. PIKE: Form. 
11 
THE WITNESS: I don't know. I can't recall. 
12 
There were so many PIs. 
13 
BY MS. ARBOUR: 
14 
Q. Dees the name Bill Reilly ring a boll? 
15 
A. Yes. 
16 
Q. Was he the investigator that M. said called 
17 
him — or called her, 
sorry? 
18 
A. I believe so, yes And they had met in an —
19 
MR. PIKE: Form. 
20 
THE WITNESS: — Applcbee's or like a 
21 
Chili's/Applebee's type restaurant. 
22 
BY MS. ARBOUR: 
23 
Q. Did an,y of the other witnesses that you 
24 
interviewed indicate that Mr. Reilly had tried to 
25 
contact them? 
Page 622 
1 
Q. What do you recognize this to be? 
2 
A. This came from a trash pull what it says lane 
3 
Doe 4 cannot come at 7:00 because of soccer. 
4 
Q. And so the name that's redacted on there is 
5 
Jane Doe 4? 
6 
A. Yes. 
7 
Q. Did you ever ask lane Doe 4 about this note? 
8 
A. No, I did not. 
9 
Q. For the same reason you didn't ask her about 
10 
the other one? 
11 
A. Correct. 
12 
Q. During the course of your investigation, did 
13 
you uncover any other alleged victims who were named 
14 
Jane Doe 4? 
15 
MR. PIKE: Form. 
16 
THE WITNESS: No, I did not. 
17 
BY MS. ARBOUR: 
18 
Q. Do you recall your interview with Jane Doe 2? 
19 
A. Yes. 
20 
Q. And you testified about it in the previous 
21 
deposition, so I want to ask you just a couple of 
22 
followup questions about that. 
23 
How did you know to speak with Jane Doe 2? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: Her name — 'think her name was 
I 
Page 621 
1 
MR. PIKE: Form. Form. It's hearsay, that's 
2 
alL 
3 
MS. ARBOUR: You said form twice. 
4 
MR. PIKE: Fm just making sure you're not 
5 
beating me to the punch with another fast question. 
6 
THE WITNESS: !Uteri had interviewed certain 
7 
people, I've gotten phone calls that the private 
8 
investigator had shown up and asking them questions 
9 
similar to the questions I was asking. 
10 
BY MS. ARBOUR: 
11 
Q. And of those phone calls that you've received, 
12 
were those all after the grand jury indictment in the 
13 
summer of 2006? 
14 
A. Prior. 
15 
Q. Prior to? Okay. 
16 
And do you recall if Jane Doe 4 ever told you 
17 
that she had been contacted by Mr. Reilly? 
18 
A. I can't recall if she did. 
19 
Q. Let me show you this one. Well mark this 31. 
20 
(Deposition Exhibit No. 31 was marked for 
21 
identification.) 
22 
THE WITNESS: Yes, I remember that. 
23 
BY MS. AREIOUR: 
24 
Q. Have you seen this document before? 
25 
A. Yes. 
Page 623 
1 
given by her name was given by another *male, 
2 
another of the witnesses. 
3 
BY MS. ARBOUR: 
4 
Q. Would it have been lane Doe 3 who told you her 
5 
name? 
6 
MFL PIKE; Form. 
7 
BY MS. ARBOUR: 
8 
Q. Do you recall? 
9 
A. I believe so. I'm not 100 percent certain, 
10 
though. 
11 
Q. If it would be in the PCA, if you want to take 
12 
a look, that's okay. I think she's page 18. 
13 
A. I believe so. 
14 
Q. Is it your understanding that Jane Doe 2 was 
15 
brought to Mr. Epstein's home prior to turning 18 in 
16 
order to provide him a massage? 
17 
A. Yes. 
18 
MR. PIKE: Form. 
19 
BY MS. ARBOUR: 
20 
Q. Did she tell you that during the course of a 
21 
massage with Mr. Epstein, she was touched in a sexual 
22 
manner by Mr. Epstein? 
23 
MR. PIKE Form. 
24 
11W WITNESS: Yes. 
25 
BY MS. ARBOUR: 
usaasiaLvar...iwniasa...
• 
.•••••••••••••• 
32 (Pages 620 to 623) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by ..leana Faceted (601 
Electronically signed by Jeans Ricciuti (801 
bdcd1876••c72o•432d 8cf0-blgae656129f 
EFTA00298372

Page 624 
1 
Q. Did she tell you that Mr. Epstein asked her to 
2 
remove her pants and her shin during that massage and, 
3 
in fact, she did remove her pants and shirt? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: That she did, yes. 
6 
BY MS. ARBOUR: 
7 
Q. Did Jane Doe 2 tell you if Mr. Epstein removed 
8 
her bra and touched her breasts? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: I believe so. 
11 
BY MS. ARBOUR: 
12 
Q. Did she tell you that Mr. Epstein masturbated 
13 
in front of her? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: Yes. 
16 
BY MS. ARBOUR: 
17 
Q. Did she toll you that Mr. Epstein touched her 
18 
vaginal area? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: Yes. 
21 
BY MS. ARBOUR: 
22 
Q. Did she — is this the one you were referring 
23 
to earlier where she told you that ho put his fingers 
24 
inside of her vagina? 
25 
MR. PIKE: Form. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 626 
Q. You testified earlier that you turned over a 
thumb drive to the FBI that had pictures of victims on 
it —
A. Correct 
Q. — is that what you said? 
A. Correct. 
Q. Do you recall what girls were on that thumb 
drive that you turned over? 
A. The girls that were mentioned in the report. 
I know I acquired yearbooks from the schools for what 
they looked like back then, compared to DL photos that 
we were able to save their image. Of course I went onto 
my thumb drive... 
Q. And now the FBI has that? 
A. Any and all information. 
Q. You said it was in the report, the girls would 
be listed in the report. What report are you within!,
to? 
A. The incident report. 
Q. Do you recall if there wore any pictures of 
Jane Doe 2 on that thumb drive? 
A. Yes, there was. 
Q. How about Jane Doe 4? 
A. Yes, there was. 
Q. How about Jane Doe 3? 
Page 623 
1 
THE WITNESS: Yes. 
2 
BY MS. ARBOUR: 
3 
Q. Did she tell you that Mr. Epstein made any 
4 
comments about her clitoris? 
5 
MR. PIKE: Form. 
6 
THE WITNESS: 1 believe he mentioned how large 
7 
it was. 
8 
BY MS. ARBOUR: 
9 
Q. Is it your understanding that from what Jane 
10 
Doe 2 told you, that these events happened before 
11 
Jane Doe 2 turned 18? 
12 
MR. PIKE: Fenn. 
13 
THE WITNESS: Yes. 
14 
BY MS. ARBOUR: 
15 
Q. Did Jane Doe 2 tell you she went there before 
16 
she turned 18? 
17 
MR. PIKE: Form. . 
18 
THE WITNESS: Yes, she told me she was, I 
19 
believe, 16 years of age. 
20 
MR. PIKE: Can we take a quick break? 
21. 
MS. ARBOUR: I'm almost done. 
22 
Just for the record, live got the most amount 
23 
of plaintiffs and I've been the quickest. 
24 
(A brief recess was taken.) 
25 
BY MS. ARBOUR: 
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 627 
A. Yes, there was. 
Q. How about Jane Doe?? 
A. Yes. 
Q. How about a girl that we haven't discussed 
named Jane Doe 5? 
A. No. 
Q. How about a girl named Jane Doe 6? 
A. No. 
Q. How about Jane Doe 8? 
A. No. 
Q. At any time during your investigation, did you 
speak to lane Doe 5? 
A. No. 
Q. Did you speak to a girl named Jane Doe 6? 
A. No. 
Q. Did you ever speak to a girl named Jane Doe 8? 
A. No. 
Q. You were asked some questions earlier about a 
private investigator following you and pulling your 
trash I believe you said. 
A. Yes. 
Q. Can you tell me more about that? 
MR. PIKES Form. 
THE WITNESS: Sometime during the 
investigation, it was discovered that we had 
I 
33 
rages 624 to 627) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricciuti (601 
Electronically signed by Jeana Ricciuti (601 
bdcd1876 c72o 432d.8ctg.b19ac656129f 
EFTA00298373

Page 628 
1 
private investigators following myself and former 
2 
• 
Chief Reiter. When I would leave work and I'd go 
3 
visit my children, I would notice a car two lengths 
4 
behind 'no doing the exact same moves I did. If 
5 
sped up, he sped up; if I slowed down, he slowed 
6 
down. 
7 
I purposely — purposely drove way under the 
8 
speed limit just to see if he would go around. No 
9 
cars around us and he stayed right behind me. 1 
10 
made several U-Hints, he did the same exact thing. 
11 
So it was clearly evident I was being followed. 
12 
I did manage to obtain a driver's license 
13 
plate number and it carne back to a private 
14 
investigator. 
15 
I was actually called by one of the Pls, which 
16 
the phone number came back to the Law Office of Roy 
17 
Black in Miami. 
18 
As far as my trash being pulled, it became 
19 
clearly evident the day after Thanksgiving where 
20 
there is no trash pickup in my neighborhood, at my 
21 
house, the day after Thanksgiving, it's a holiday, 
22 
everybody's cans were full and mine is empty. 
23 
MIL PIKE: Form. Move to strike. 
24 
BY MS. ARBOUR: 
25 
Q. Did you eves do any research to determine the 
Page 630 
1 
September'05 to May 2006 time period? 
2 
A. Yes. 
3 
Q. Did you ever speak with any of the other 
4 
witnesses who indicated to you that they believed they 
5 
were being followed? 
6 
A. Yes. 
7 
Q. What witnesses indicated they thought they 
8 
were being followed? 
9 
A. I received several phone calls from Jane Doe 
10 
103, indicating that she was — her neighbors were being 
11 
talked to. People were going to her door representing 
12 
themselves to be a police officer at first and then 
13 
later identifying themselves as a private investigator. 
14 
Q. And did that occur sometime in that same 
15 
September'05 to May 2006 time period? 
16 
A. Correct. 
17 
Q. Did any other witnesses that you can recall 
18 
express similar concerns about being followed or being 
19 
investigated? 
20 
A. Yes. Jane Doe II. I had received several 
21 
text messages and phone calls indicating similar, where 
22 
Pls were speaking to her friends, her family, previous 
23 
boyfriends and following her around. 
24 
MR. PIKE: Fenn. 
25 
BY MS. ARBOUR: 
Page 629 
1 
identity of the private investigators that you believed 
2 
were following you? 
3 
A. Yes. I did obtain — based on their license 
4 
plate, l was able to obtain who they were and which PI 
5 
firm they represent. 
6 
Q. Did you ever speak to any --
7 
MR. PIKE: Same objection. 
8 
BY MS. ARBOUR: 
. 9 
Q. Did you ever speak to any representatives of 
10 
that PI firm? 
11 
A. No. 
12 
Q. Do you have any information about who, if 
13 
anyone, hired them to follow you? 
14 
A. Aside from that one phone call that came back 
15 
to Roy Black's office. 
16 
Q. And that was the investigators calling you or 
17 
you were calling the investigators? 
18 
A. No. They actually called me by mistake. 
19 
Q. Okay. So you didn't actually speak to anyone? 
20 
A. No. They asked me who I was, and I said who 
21 
are you, and they hung up. I had the number on my 
22 
caller ID. I cross referenced the phone number and it 
23 
came back to it. 
24 
Q. And to the best of your recollection, all of 
25 
this occurred sometime in that September to May 2006 --
Page 631 
1 
Q. Did Jane Doe 7 ever express to you that she 
2 
was worried she was being followed or investigated by a 
3 
private investigator? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: Not that I can recall. 
6 
BY MS. ARBOUR: 
7 
Q. How about Jane Doe 3? 
8 
MR. PIKE: Form. 
9 
THE WITNESS: Not that I can recall. 
10 
BY MS. ARBOUR: 
11 
Q. How about Jane Doe 4, did she ever indicate Iti 
12 
you that she was worried that she was being followed t 
13 
investigated? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: Not that I can recall. 
16 
MS. ARBOUR: I think that's all I have. 
17 
CROSS (DETECTIVE JOE RECAREY) 
18 
BY MR. GARCIA: 
19 
Q. Just a couple of questions. Jane Doe II, you 
20 
just mentioned her, how many phone calls or how many 
21 
conversations did you have with her? 
22 
A. Probably less than a handful. 
23 
Q. By phone or in person or —
24 
A. By phone. 
25 
Q. And how did you meet Jane Doe II? 
1 
PROSE COURT REPORTING AGENCY, 
34 (Pages 628 to 631) 
INC. 
Electronically signed by Jeana Ricciuti (601 
Electronically signed by Jeana Rlcciuti (801 
bdcd1876•c72o•432c1.8c10-b19ae6561291 
EFTA00298374

Page 632 
Page 634 
A. Actually, she came to the police station and 
1 
already -- the discussion was occurring already with the 
2 
spoke with Detective Dawson once there was information 
2 
FBI, and there was original talk in the very beginning 
3 
pertaining to Mr. Epstein's arrest 
3 
with the State Attorney's office that they were going to 
4 
Q. After the arrest was made? 
4 
amend the charges, depending on the new victims that 
5 
A. Correct. 
5 
came forward and what they had to say. And then the 
6 
Q. Why was that assigned to Detective Dawson as 
6 
Feds came in and then... 
7 
opposed to yourself? 
7 
Q. And then that was that? 
8 
MR. PIKE: Fonn. 
8 
A. That was it. 
9 
THE WITNESS: I had taken a week vacation. 
9 
Q. Do you know a man named Charles or Gerald 
10 
BY MR. GARCIA: 
10 
Goldsmith? He ran for mayor or something. 
11 
Q. Was there any followup after Detective Dawson 
11. 
A. Yeah, I know of him, but.. 
12 
spoke to her? 
12 
Q. You've never met him? 
13 
A. Yes, I did make telephone contact with her, to 
13 
A. I mean,11cnow who he is if I see him, but he 
14 
let her know that I had the case, and that I was going 
14 
doesn't — we don't speak or... 
15 
to be looking into the case further. When the FBI took . 
15 
Q. Did Chief Reiter ever tell you or confide in 
16 
all the information, I notified her and let her know 
16 
you or report to you that Mr. Goldsmith was seeking 
17 
that the FBI was going to be looking into this as well. 
17 
information about the investigation of Mr. Epstein? 
18 
And then it was clearly evident to me that it was just 
18 
A. He had mentioned that to me. 
19 
going to be the FBI looking into this, so... 
19 
Q. And what did he tell you about that? 
20 
Q. And now, was the -- Pm trying to just piece 
20 
A. That he had received basically an inquiry from 
21 
together the sequence. You said she came to you after 
21 
Goldsmith and basically to back off the investigation. 
22 
Epstein was arrested, correct? 
22 
Q. Do you recall when Chief Reiter reported this 
23 
A. Correct. 
23 
to you? 
24 
Q. Had the FBI already taken your files at that 
24 
A. No. 
25 
point? 
25 
MR. PIKE: Form. 
Page 633 
Page 635 
A. Negative. 
1 
BY MR. GARCIA: 
2 
Q. So there was an arrest. And the plea deal, 
2 
Q. Was there any issue about any donations that 
3 
was that struck shortly after the arrest? 
3 
Mr. Epstein had made to the Police Department? 
4 
A. The plea deal didn't get struck until further 
4 
A. You know, I heard he had made a donation and 
5 
down the road. 
5 
it was returned to him, but I don't know any of that 
6 
Q. But it was after the FBI took all your 
6 
infonnation at all. 
7 
documents? 
7 
Q. Regarding the conversations that you had with 
8 
A. When she came in? 
8 
Jane Doe II, you said there were some text messages or 
9 
Q. No, in terms of the plea deal. 
9 
phone calls. Did you make any reports of those 
10 
A. Oh, yeah, it was after, way after. 
10 
conversations? 
11 
Q. And other — I have one statement that she 
11 
A. No, I did not The text messages was because 
12 
gave to detective — Pm sorry, Sergeant Dawson, 
12 
she was concerned that her family, her boyfriend were 
13 
apparently. It's dated — can you tell me what the date 13 
being questioned by PIs, they were being told certain 
14 
of that report is? 
14 
things about the case, and she was concerned that it was 
15 
A. 7/28/06. 
15 
like a harassment type of thing. 
16 
Q. Do you know if there are any other reports 
16 
Q. Was she able to ascertain the names of the 
17 
that were taken of Jane Doe ll's involvement in this 
17 
investigators? 
18 
case from the Palm Beach Police Department? 
18 
A. I believe she did. I believe it was on the 
19 
A. Not that I'm aware of. 
19 
text message she sent me. 
20 
Q. That's the only one? Okay. 
20 
MR. GARCIA: Okay, that's alit have. 
21 
Did you ever present her information to the 
21. 
MS. ARBOUR: Can I just ask one more? Is that 
22 
State Attorney's office for a criminal prosecution? 
22 
all right? 
23 
A. No. 
23 
RECROSS (DETECTIVE JOE RECAREY) 
24 
Q. Do you know why? 
24 
BY MS. ARBOUR: 
25 
A. Prior to me getting into the case, there was 
25 
Q. Detective, during the course of your 
35 (Pages 632 to 635) 
PROSE COURT REPORTING AGENCY INC. 
Electronically signed by Jeana RIcclutl (601 
Electronically signed by Jeana Rlcclutl (601 
bdcd1876-c72o-432d-Bcf0-blilae656129f 
EFTA00298375

10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 636 
1 
investigation, would you say that it was absolutely 
2 
critical that you knew the amount of limes a girl went 
3 
to Mr. Epstein's house? 
4 
MR. PIKE: Form. 
5 
THE WITNESS: Would I say it was critical? 1 
6 
wanted to know if it was once or twice, more than 
7 
10, more than 15, more than 20. 
8 
BY MS. ARBOUR: 
9 
Q. Would it be fair to say it was more important 
to you, during the course of your investigation, to get 
a general sense of what happened and approximately how 
many times it happened rather than an exact number of 
times? 
A. Correct. 
MS. ARBOUR: That's all I have. 
RECROSS (DETECTIVE JOE RECAREY) 
BY MR. GARCIA: 
Q. I'm sorry, I forgot to ask you something. The 
Assistant State Attorney that you were working with on 
this case --
A. Yes. 
Q. -- I keep forgetting her name. What's her 
name a.? 
A. 
Q. Now, is she an attorney who tried a lot of 
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 638 
Q. Did she know that it was a federal crime to 
solicit tmderaged women for prostitution? 
MR. PIKE: Form. 
BY MR. GARCIA: 
Q. Or did she appear to know that? 
MR. PIKE: Same. 
THE WITNESS: I have no idea. 
MR. GARCIA: All right Thanks. 
MR. PIKE: Any followup? Okay. 
MS. O'CONNER: So we're concluded, right? 
MR. PIKE: We are concluded. 
MS. O'CONNER: We're going to read. 
(Witness excused.) 
(Deposition was concluded.) 
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 637 
cases for the State Attorney's office or did she work 
more in the intake section of the State Attorney's 
office, if you know? 
A. I don't know exactly how many times she's been 
to tried, but --1 couldn't tell you. 
Q. And did she make the presentation to the grand 
:WY? 
A. Yes. 
Q. By herself? 
A. Yes. 
Q. Did you ever participate in any cases where 
she was the trial attorney for the State Attorney's 
office? 
A. No. No, I did not. 
Q. And did she explain to you why she thought 
that these minor girls who were lured, in exchange for 
compensation to perform sex acts on Mr. Epstein, were 
not victims in her mind? 
MR. WEINBERG: Form. 
THE WITNESS: Based on the MySpace pages that 
she viewed, she had mate that determination. 
BY MR. GARCIA: 
Q. Just based on that? 
A. That was my — that's what she basically told 
me. 
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 639 
CERTIFICATE OF OA114 
THE STATI3OF FLORIDA 
cowry OF PALM BEAM 
1, the undersigned authority, certify that 
DE,7BCFIVE 1OE RECAREY personally appeared below int tn.! 
was duly swan on the 27th day of April, 2010. 
Dated this 27th day of April, 2010. 
C 
hams Ricciuti, RPR, 1TR, Cllr"
Notary Public- Star of Florida 
My Commission Expires: 2/172013 
My Commission No.: DD 854778 
1
 
PROSE COURT REPORTING AGENCY, 
Electronically signed by Jeana Ftleclud (601 
Electronically signed by Jeana Rleelutl (601 
 
s 
36 (Pages 636 to 639) 
INC. 
bded1876 c72o.432d•8ef0-b19ae6561291 
EFTA00298376

Page Bd 
Page 642 
1 
CERTIFICATE 
2 
THE STATE OF FLORIDA 
3 
COUNTY OF PALM BEACH 
4 
5 
Llama Ricciuti, Rq3istcrcd Professional 
Repeater and Notary Public in and for the State of 
6 
Makin at lame, do hereby ecetiy that I was 
authoi mai to and did report staid deposition in 
7 
stenotype. and that the fon-vain pages ore a true and 
correct trainer :Sion of my shorthand notes of said 
8 
deposition. 
9 
I further comfy that said deposition wri 
taken at the time and place hereinabon act forth and 
10 
thee the taking of said deposition was canoe cord and 
completed as hereinabovc set out 
11. 
I Rather certify that I ant not an attorney or 
12 
counsel arty of the partia, not ant I a relative or 
employee of any atUrney cr counsel of party connected 
13 
nith the action, nor am I fituincially irterated in the 
Mien. 
14 
The romping certification of this tronsuipt 
15 
does not apply to any reproduction of the same by any 
means unless under the direct control taid/or direction 
16 
of the certifying reporter. 
17 
Dated tins I 1th day of May, 2010. 
18 
19 
20 
21 
22 
23 
24 
25 
C... 
451:20t
41
gonna Rieciuti, 
EPP, CLR 
1 
CERTIFICATE 
2 
3 
THE STATE OF FLORIDA 
4 
COUNTY OF PALM BEACH 
5 
I hereby certify that I have read the 
6 
foregoing deposition by me given, and that the 
7 
statements contained herein are true and correct to the 
8 
best of my knowledge and belief, with the exception of 
9 
any corrections or notations made on the errata sheet, 
10 
if one was executed. 
11 
12 
Dated this 
day of 
13 
2010. 
14 
15 
16 
17 
18 
19 
DEFECTIVE JOE RECAREY 
20 
21. 
22 
23 
24 
25 
Page 641 
1 
DATE: 
May11.2010 
2 
TR 
DEfECTIVE10ERECAREY 
doJoann:1A Orator Esquire 
3 
JONES, Bus I tit, JOHNSTON At STUBBS 
505 Sooth Hagler Ent. Suite 1100 
4 
West Palm Beach. Florida 33401 
5 
IN RE: lane Doe 2 v. Pprtein 
6 
Ham take notice that on Tuesday, the 27th 
of Apil, 2010, yea pot your depoition in the 
olison cla nal pastel. AT that now, you did out went 
siimattec. It is now non:trythat you sip your 
8 
rlopinition 
As deviously speed to the tneseript will 
9 
be finished to you through Emo ccwnd Plane read 
the following instnictices earthily: 
10 
At the and affix transcript you %nil Rod an 
coatis shed. As you read your demcwoon: eny (lunges 
11 
or conections Ihrt you oish to coke shoil4 be noted on 
1hµ al du Steel, citing Luba am1 line :Amax/ or um 
12 
change. DONUT write M ILK illinalF4 Olt: Once 
you bee mad the oniony end WWI nay changes, be 
11 
due to sign and date the dram Ad/ and mum these 
pones to nte. 
14 
If wet do ad mad end acei the &Porn,
within a tenonatik time 
,
days unless aliay.ise 
15 
directed) the cuirthal, %Ain has already beat forwarded 
to the ordering attorney, may be filed nth the Oak of 
16 
the Coon. If yru wish to waiw yow sitarist, aim 
your come in the Nankai the bittern of this hoer rid 
17 
retro it tons. 
18 
Very may yours, 
19 
Scam Ricciati, RPR IPA CLR 
PRIM 001111 Reporting Amoy. In. 
20 
250 S. Auslralin Avenue, Ste 1500 
Wert Palm Reath, Florida 33401 
21 
22 
I do botchy waive my *entre 
23 
24 
DU tut WE ICE RECAREY 
25 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
II 
12 
13 
14 
15 
16 
17 
18 
:9 
20 
21 
22 
23 
24 
25 
Page 643 
ERRATA SHEET 
IN RE JANE00B2 v. EPSIE114 CR: NANA RICOUIT 
DEPOSITION OP: DEFECIIVEJOERECAREY 
TAKEN: Apnl 27. 2010 
DO mar von cennansaurr -Dust CHANGES HERE 
PAGES W181 CHANGE 
REASON 
Please thorns(' tic miginfl sided 011111 aka to this 
office so dot copes may be donihred to all panics. 
Utak: penalty of perjury, I declare that I hem read my 
deposition and Poi it es tor and coned subject to 
any damps in form or substheve atered bac. 
DATEt 
SIONATUREOF DEPONEWP 
37 (Pages 640 to 64 
) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Riccluti (601 
Electronically signed by Jeana Ricciutl (601 
bdcd1876-c720-437d-800-619nc6561791 
EFTA00298377