EFTA00726182

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 10-80309 
JANE DOE NO. 103 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
RE-NOTICE OF TAKING DEPOSITION DUCES TECUM 
(As to Location ONLY) 
PLEASE TAKE NOTICE that at the below listed time and place the Plaintiff, JANE DOE 
NO. 103, by and through undersigned counsel, will take the depositions of: 
NAME OF DEPONENT 
Detective Joseph Recary 
do Joanne M. O'Conner, Esq. 
Jones, Foster, 
Stubbs, P.A. 
505 South Flagler Drive, # 1100 
West Palm Beach, FL 33401 
DATE AND TIME 
Tuesday 
April 27, 2010 
10:00 a.m. 
PLACE OF DEPOSITION 
Joanne M. O'Connor Esq. 
Jones, Foster, 
& 
Stubbs, P.A. 
505 South Flagler Drive 
Suite 1100 
West Palm Beach, FL 33401 
upon oral examination before PROSE COURT REPORTING, a Notary Public, or any other notary 
public or officer authorized by law to take depositions in the State of Florida. The oral examination 
will continue from day to day until completed. This deposition is being taken for the purpose of 
Podhurst Orsecls, P.A. 
25 West Flagler Street. Suite 800, Miami, FL 33130, MIMI 305 358.2900 Fax 305.3582382 • Fort Lauderdale 954.4634346 1 
www.podluustorn 
EFTA00726182

CASE NO.: 10-80309 
discovery, for use at trial, or for such other purposes as are permitted under the rules of Court. The 
deponent is further directed to bring with him or her to the deposition documents described in 
Exhibit "A" attached. 
DATED this 19th day of April, 2010. 
Respectfully submitted, 
PODHURST ORSECK, P.A. 
Attorneys for Plaintiff Jane Doe No. 103 
By: 
C.Jo66fsberg 
Fla. Bar No. 040856 
Katherine W. Ezell 
Fla. Bar No. 114771 
City National Bank Building 
25 W. Flagler Street, Suite 800 
Miami, FL 33130 
Telephone: 
Facsimile: ( 
- 2 - 
Podhurst Orsedc, P.A. 
25 West Flagler Street. Suite 800, ?Aunt FL 33130, Muni X6358.2800 Fax 305.35&2382 • Fort Lauderdale 951.463A316 I 
www.podhurst.caus 
EFTA00726183

CASE NO.: 10-80309 
CERTIFICATE OF SERVICE 
WE HEREBY CERTIFY that on this 19th day of April, 2010, a copy of the foregoing was 
served this day on all counsel of record on the attached Service List via e-mail transmission. 
Respectfully submitted, 
PODHURST ORSECK, P.A. 
Attorneys for Plaintifflane Doe No. 103 
By: 
C. J6§efsberg 
Fla. Bar No. 040856 
Fla. Bar No. 114771 
City National Bank Building 
25 W. Flagler Street, Suite 800 
Miami, FL 33130 
Telephone: (305) 358-2800 
Facsimile: (305) 358-2382 
- 3 - 
Podhurst Orseck, 
25 West Meer Street. Suite 800, Miami. FL 33130, Miami 386358.2800 Fax 305.3562382 • Fat Lauderdale 954463.4346 
www.podIstust.com 
EFTA00726184

CASE NO.: 10-80309 
SERVICE LIST 
JANE DOE NO. 103 v. JEFFREY EPSTEIN 
Case No.: 10-80309 
United States District Court, Southern District of Florida 
Critton, Esq. 
Michael 3. Pike, Esq. 
Burman, Critton, Luttier & Coleman LLP 
303 Banyan Boulevard, Suite 400 
West Palm Beach, FL 33401 
Phone: (561) 842-2820/Fax: (561) 515-3148 
ounse 
e ant, Jerey Epstein 
Jack Goldberger, Esq. 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, FL 33401 
Phone: (561) 659-8300/Fax: (561) 835-8691 
Co-Counsel for Defendant, Jeffrey Epstein 
Bruce E. Reinhart, Esq. 
Bruce E. Reinhart, P.A. 
250 South Australian Avenue, Suite 1400 
West Palm Beach, FL 33401 
Phone: 561 202-6360/Fax: (561) 828-0983 
ounse or o- e en ant, 
Adam Horowitz, Esq. 
Stuart Mermelstein, Esq. 
Mennelstein & Horowitz, P,A. 
18205 Biscayne Blvd., Suite 2218 
Miami, FL 33160 
Phone: (305) 931-2200/Fax: (305) 931-0877 
- 4 - 
Podhurst Orseck, P.A. 
25 West Hagler Street Suite 800, Miami, Ft 33130, Miami 3053582800 Fax 3053582382 • Fort Lauderdale 95{463.4346 
www.podhurst.com 
EFTA00726185

CASE NO.: 10-80309 
Counsel for Plain:lb in Related Cases Nos. 08-80069, 08-80119,08-80232, 08-80380 08-80381, 
08-80993,08-80994 
Spencer Todd Kuvin, Esq. 
Theodore Jon Leopold, Esq. 
Leopold Kuvin, P.A. 
2925 PGA Boulevard, Suite 200 
Palm Beach Gardens, FL 33410 
61) 515-1401 
Counsel for Plaintiff in Related Case No. 0848804 
Edwards, Esq. 
Farmer, Jaffe, Weissing, Edwards, 
Fistos & Lehrman, P.L. 
425 North Andrews Avenue, Suite 2 
Fort Lauderdale, FL 33301 
Phone: (954) 524-2820/Fax: (954) 524-2822 
Counsel for Plaintiff in Related Case No. 08-80893 
Isidro Manuel M, 
Esq. 
Elkins & Boehringer 
224 Datura Avenue, Suite 900 
West Palm Beach, FL 33401 
Phone: (561) 832-8033/Fax: (561) 832-7137 
Counsel for Plaintiff in Related Case No. 0840469 
- 5 - 
Podhurst Orseck, P.A. 
25 West Hagler Street, Suite 800, Miami, FL 33150, Miami 305.358.1300 Fax 305-3582382 • Fort Lauderdale 954463.4346 
www.podlutrd.cOm 
EFTA00726186

WONT "A" 
1. 
Any and all written reports, notes, memoranda or other papers authored by ygn 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 mend 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 inn 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, (B) 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 (B) 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 fo 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 retailing 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 "AB:* 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 "Ali." or referencing "AIL" in 
relation to her being subpoenaed to testify before or hex requested attendance before a State 
Grand Jury where y_
 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. 
EFTA00726187

8. 
Any and all agreements, memoranda, and/or notes of any kind, electronic or otherwise, 
between mond any member of the Palm B each 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.H." at any time. 
9., 
y and all notes, memoranda, or reports of ineetbas or communications between nu 
and mg-I% her parents, or any lawyers who represent 'ire 
10. 
Any and all records of expenditures made or incurred by xi.% 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 I, 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 from 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. 
Jemmy 1, 2006-December 31, 2006 
d. 
January 1, 2007-Deoeenbesr 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, 
EFTA00726188

17. 
Any and all reports, memoranda, and notes of any communication between att 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. 
AU 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 
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 handy/nth:a containing any witnesses that ym or any other member of the Palm Beach 
Police Department interviewed or attempted to interview with regard to the Epstein investigation 
from January I, 2004, up thorough and including today. 
20. 
Any and all audio tapes of any witnesses that ygg or any member of the Palm Beach 
Police Department obtained statements or interviews from, either man. 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 vs 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 A.11. and S.R. refer to the individuals identified in the Palm Beach County 
Probable Cause Affidavit as it relates to the Jeffrey Epstein investigation. Should you 
require 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 MIN 
IMMES 
EFTA00726189