EFTA00598945

IN THE COURT OF THE FIFTEENTH 
JUDICIAL CIRCUIT, IN AND FOR PALM 
BEACH COUNTY, FLORIDA 
B.B., 
CASE NO. 502008CA0373193OOOCMB AB 
Plaintiff, 
v. 
and 
Defendants 
NOTICE OF TAKING DEPOSITION 
DUCES TECUM 
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition duces 
tecum (See attached Exhibit "A") of: 
DEPONENT 
Det. Joseph Recarey 
do Joanne M. O'Conner, Esq. 
Jones, Foster, Johnson 
& Stubbs, P.A. 
505 S. Flagler Drive, #1100 
West Palm Beach, FL 33401 
DATE & TIME LOCATION OF DEPOSITION 
February 25, 2010 
at 9:30 AM 
Prose Court Reporting 
One Clearlake Centre 
250 Australian Avenue South 
West Palm Beach, FL 33401 
upon oral examination, before Prose Court Reporting, a Notary Public, or any other officer 
authorized by law to take depositions in the State of Florida. The oral examination is being taken for 
the purpose of discovery, for use at trial, or for such other purposes as are permitted under the 
applicable Statutes of Rules of Court. 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S 
following addressees on this 3rd day of February, 2010: 
Theodore J Leopold, Esq.
Spencer T. Kuvin, Esq. 
Leopold-Kuvin, P.A. 
2925 PGA Blvd., Suite 200 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
Mail to the 
EFTA00598945

B.B v. Epstein, et al 
Page 2 
Palm Beach Gardens, FL 33410 
Fax: 561 697 2383 
Counsel for Plaintiff 
West Palm Beach, FL 33401-5012 
Fax: 561-835-8691 
Co-Counsel for Defendant Jeffrey Epstein 
BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 
515 N. Flagler Drive, Suite 400 
Wet a 
ch, FL 33401 
(561)515-3148 Fax 
Robe 
. Critton, Jr. 
Florida Bar #224162 
Mi mel I Pike 
Florida Bar #617296 
(Colonel for Defendant Jeffrey Epstein) 
EFTA00598946

EXHIBIT "A" 
1 
Any and all written reports, notes, memoranda or other papers authored by you or any 
other member of the Palm Beach Police Department, whether in hard-copy or electronic form, 
that relate to any law enforcement investigation of Jeffrey Epstein including but not limited to 
the investigation that resulted in the filing of State criminal charges against Mr. Epstein This 
request includes any written communications between you and any members of the Palm Beach 
Police Department, any member of any Federal Law Enforcement Agency, any member of the 
Unites States Attorney's Office, any member of the Office of the State Attorney, any 
representatives of the media, any civil parties, any civilian witnesses and/or any lawyers or 
representatives of any parents of any civilian witnesses. 
2. 
Any and all electronic communications (EMAIL) between yo any of the following 
relating to any law enforcement investigation of Jeffrey Epstein including but not limited to the 
investigation that resulted in the filing of State criminal charges against him: (A) any member of 
the Palm Beach Police Department, (13) any member of any Federal Law Enforcement Agency, 
(C) any member of the Untied States Attorney's Office, (D) any member of the Office of the 
State Attorney (E) any member of any print, television, or radio media outlet, (F) any attorney 
representing any civilian witness or civil party who has filed or may potentially file a civil 
complaint against Mr Epstein. 
3 
Any and all notes, memoranda or reports reflecting any communications between you 
and counsel on behalf of Mr. Epstein, including but not limited to any request for exculpatory 
evidence. 
4. 
Any and all notes, memoranda or reports reflecting any attempts by you to initiate or 
encourage a federal review of any facet/aspect of the Epstein investigation or State prosecution 
of Epstein 
5 
Any and all notes, memoranda or reports reflecting any complaints made to the Palm 
Beach Police Department from any person, parent, or lawyer for any person or parent claiming to 
have been a victim of any conduct of Mr Epstein or from any other private citizen of Palm 
Beach County relating to any conduct of Epstein from January 1, 2000 — October 22, 2009. 
6. 
Any and all notes, memoranda, or reports reflecting any communication between you or 
and any other member of the Palm Beach Police Department with "A H." in relation to her 
being subpoenaed to testify before or her requested attendance before a State Grand Jury, 
including but not limited to any discussions regarding what she would testify to and/or any 
preparation that any law enforcement officer provided her with prior to any testimony. 
7. 
Any and all notes, memoranda, or reports reflecting any communication between you or 
any other member of the Palm Beach Police Department with "A H."* or referencing "A.H "* in 
relation to her being subpoenaed to testify before or her requested attendance before a State 
Grand Jury where you  or any Palm Beach police officer or official sought to discourage her or 
influence her not to testify or to testify in a certain manner at any Grand Jury proceeding 
involving Mr. Epstein. 
EFTA00598947

8. 
Any and all agreements, memoranda, and/or notes of any kind, electronic or otherwise, 
between you and any member of the Palm Beach Police Department, any member of the Office 
of the State Attorney, and/or any member of the United States Attorney's Office relating to any 
criminal charges, formal or otherwise, regarding "A II " at any time. 
9. 
Any and all notes, memoranda, or reports of meetings or communications between you 
and "S.G "*, her parents, or any lawyers who represent "S.G_"• 
10. 
Any and all records of expenditures made or incurred by you, and all requests for 
expenditures relating to the criminal investigation of Mr. Epstein. 
11. 
Any and all logs, pictures, videos, digital information, reports, memoranda or notes, and 
any record of expenditure, which relate to the institution of and/or maintenance of any video 
surveillance of Mr. Epstein, his residence, or his visitors during the following time periods: 
a 
January 1, 2004-December 31, 2004 
b. 
January 1, 2005-December 31, 2005 
c 
January 1, 2006-December 31, 2006 
d. 
January 1, 2007-December 31, 2007 
e. 
January 1, 2008-December 31, 2008 
f. 
January 1, 2009-today's date. 
12. 
Any and all reports, logs, pictures, videos, notes, records of expenditures or any other 
memoranda relating to any physical surveillance of Mr. Epstein, his residence, his visitors, or 
any individual who was believed to be a potential witnesses or co-conspirator other than the 
information relating to video surveillance that is requested in request number 11 
13. 
Any and all reports (including forensic reports), memoranda, notes, and reports of any 
examination of any computer seized fiom Mr. Epstein's residence in October 2005 or on any 
other occasion. 
14. 
Any and all reports, memoranda, or notes reflecting a criminal theft or burglary 
investigation of Mr. Epstein or his residence on any occasion prior to October 2005. 
15. 
All cell phone records, both official cell phone and personal cell phone, used by you 
between during the following time periods: 
a. 
January 1, 2004-December 31, 2004 
b. 
January 1, 2005-December 31, 2005 
c. 
January 1, 2006-December 31, 2006 
d. 
January I, 2007-December 31, 2007 
e 
January 1, 2008-December 31, 2008 
f. 
January 1, 2009-today's date. 
16.. 
All calendars or diaries, electronic or hard-copy, kept for the periods between October 1, 
2004 up through and including today, reflecting your schedules, activities, meeting, etc. 
EFTA00598948

17. 
Any and all reports, memoranda, and notes of any communication between Los and any 
member of the Office of the State Attorney relating to the criminal investigation and subsequent 
prosecution of Mr. Epstein from October 1, 2004 up through and including today. 
18. 
All policies and procedures of the Palm Beach Police Department setting forth the 
procedures for police officers, including the Chief, any detective and officers when commenting 
to any media outlets, including but not liming to the local news, the national media, print outlets, 
and any web-based media format. 
19. 
All personal notes contained either on your personal computer, work computer, and those 
that are handwritten containing any witnesses that you, or any other member of the Palm Beach 
Police Department interviewed or attempted to interview with regard to the Epstein investigation 
from January 1, 2004, up thorough and including today. 
20. 
Any and all audio tapes of any witnesses that You or any member of the Palm Beach 
Police Department obtained statements or interviews from, either sworn or informal, with regard 
to the Epstein investigation 
21. 
Any and all audio tapes, notes (hand-written or typed), memoranda, reports, messages, 
and/or any communications obtained or generated by you  or any member of the Palm Beach 
Police Department, either sworn or informal, that relate to Jane Doe #4**, who is the Plaintiff in 
a Federal Civil Case No. 08-80380 filed against Jeffrey Epstein. 
* The initials Ail. and S.R. refer to the individuals identified in the Palm Beach County 
Probable Cause Affidavit ns it relates to the Jeffrey Epstein investigation. Should ou 
re uire the complete name of the individuals, please contact Jessica Cadwell at 
** Should you need the full identity of Jane Doe #4, please contact Jessica Cadwell at ■ 
EFTA00598949