gov.uscourts.nysd.447706.1201.27.pdf

Case 1:15-cv-07433-LAP Document 1201-27 Filed 01/27/21 Page 1 of 8 EXHIBIT 11 (Filed Under Seal) Case 1:15-cv-07433-LAP Document 1201-27 Filed 01/27/21 Page 2 of 8 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 21, 2016 9:17 a.m. C O N F I D E N T I A L Deposition of JOSEPH RECAREY, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 1:15-cv-07433-LAP Document 1201-27 Filed 01/27/21 Page 3 of 8 Page 29 1 JOSEPH RECAREY - CONFIDENTIAL 2 Ghislane Maxwell? 3 A. I wanted to speak with everyone related to 4 this home, including Ms. Maxwell. My contact was 5 through Gus, Attorney Gus Fronstin, at the time, who 6 initially had told me that he would make everyone 7 available for an interview. And subsequent 8 conversations later, no one was available for 9 interview and everybody had an attorney, and I was 10 not going to be able to speak with them. 11 Q. Okay. During your investigation, what did 12 you learn in terms of Ghislane Maxwell's 13 involvement, if any? 14 MR. PAGLIUCA: Object to form and 15 foundation. 16 THE WITNESS: Ms. Maxwell, during her 17 research, was found to be Epstein's long-time 18 friend. During the interviews, Ms. Maxwell was 19 involved in seeking girls to perform massages 20 and work at Epstein's home. 21 MR. PAGLIUCA: Object to form and 22 foundation. 23 BY MR. EDWARDS: 24 Q. Did you interview -- how many girls did 25 you interview that were sought to give or that Case 1:15-cv-07433-LAP Document 1201-27 Filed 01/27/21 Page 4 of 8 Page 33 1 JOSEPH RECAREY - CONFIDENTIAL 2 house for the massages? 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 THE WITNESS: Correct. 6 BY MR. EDWARDS: 7 Q. And, as well, certain people that were 8 friends or girlfriends or assistants of Jeffrey 9 Epstein would recruit girls under the pretense of 10 giving a massage? 11 MR. PAGLIUCA: Object to form and 12 foundation. 13 THE WITNESS: Correct. 14 BY MR. EDWARDS: 15 Q. Is that what your investigation revealed 16 in terms of the system of getting these girls over 17 to the house? 18 MR. PAGLIUCA: Object to form and 19 foundation. 20 THE WITNESS: Yes. 21 BY MR. EDWARDS: 22 Q. Okay. Talking about the massages, when -- 23 when these -- the various girls that you interviewed 24 described the massages, was there a pattern of what 25 occurred during these massages? Case 1:15-cv-07433-LAP Document 1201-27 Filed 01/27/21 Page 5 of 8 Page 73 1 JOSEPH RECAREY - CONFIDENTIAL 2 of the -- that the house appeared to be -- I don't 3 remember the word you used -- sanitized, for lack of 4 a better word? 5 MR. PAGLIUCA: Object to form and 6 foundation. 7 BY MR. EDWARDS: 8 Q. How did you know that? 9 A. The computers had been removed from the 10 home. 11 Q. How did you know the computers were 12 removed? 13 A. Based on -- based on the dangling wires 14 left behind, the monitors left, but the actual CPU 15 of it was missing. 16 When you went into the bedroom of Jeffrey 17 Epstein, everything was removed from the -- the 18 shelves, from the armoire. 19 Q. Did you find nude photographs of girls? 20 A. Yes. 21 Q. All right. 22 And what did you do with that evidence? 23 A. That was collected and placed into our 24 crime scene unit. 25 Q. And where is that evidence today? Case 1:15-cv-07433-LAP Document 1201-27 Filed 01/27/21 Page 6 of 8 Page 74 1 JOSEPH RECAREY - CONFIDENTIAL 2 A. Any evidence that was not returned to its 3 rightful owner was turned over to the FBI. 4 Q. And evidence which would be nude 5 photographs of girls would be evidence not turned 6 back over to Epstein? 7 A. Correct. 8 MR. PAGLIUCA: Object to form and 9 foundation. 10 THE WITNESS: Some of the items that were 11 collected were later found to be personal items 12 of the houseman, Janush. I recall reviewing 13 his personal photographs on -- on a micro SD 14 card for, like, photos of him and his wife or 15 girlfriend at the time. 16 BY MR. EDWARDS: 17 Q. And the underaged girls that you had 18 spoken with during your investigation, had they 19 described seeing photographs of naked girls in the 20 house? 21 MR. PAGLIUCA: Object to form and 22 foundation. 23 THE WITNESS: Yes, they did. 24 BY MR. EDWARDS: 25 Q. That's something that ran consistent with Case 1:15-cv-07433-LAP Document 1201-27 Filed 01/27/21 Page 7 of 8 Page 83 1 JOSEPH RECAREY - CONFIDENTIAL 2 BY MR. EDWARDS: 3 Q. In these messages, did you see messages 4 that were taken by Ghislane Maxwell or left for 5 Ghislane Maxwell? 6 MR. PAGLIUCA: Object to form and 7 foundation. 8 THE WITNESS: I do recall seeing messages 9 utilizing her pad, her stationery. 10 BY MR. EDWARDS: 11 Q. Okay. Do you remember messages 12 specifically that Ms. Maxwell, she is home, or calls 13 for Ms. Maxwell, or indicating that the person 14 taking the message is GM? Do you remember those? 15 A. Yes. 16 MR. PAGLIUCA: Object to form and 17 foundation. 18 BY MR. EDWARDS: 19 Q. And did that give you further reason to 20 want to speak to Ghislane Maxwell? 21 MR. PAGLIUCA: Object to form and 22 foundation. 23 THE WITNESS: Correct. I wanted to speak 24 with everyone in the home and everyone 25 associated with Jeffrey Epstein. Case 1:15-cv-07433-LAP Document 1201-27 Filed 01/27/21 Page 8 of 8 Page 363 2 AFFIDAVIT 3 STATE OF FLORIDA ) COUNTY OF ) 4 5 I, , being first 6 duly sworn, do hereby acknowledge that I did read a true and certified copy of my deposition 7 which was taken in the case of GIUFFRE V. MAXWELL, taken on the 24th day of September, 8 2016, and the corrections I desire to make are as indicated on the attached Errata Sheet. 9 10 CERTIFICATE 11 12 STATE OF FLORIDA ) COUNTY OF ) 13 14 Before me personally appeared 15 ________________________________________, to me well known / known to me to be the 16 person described in and who executed the foregoing instrument and acknowledged to and 17 before me that he executed the said instrument in the capacity and for the purpose therein 18 expressed. 19 20 Witness my hand and official seal, this ______ day of ________________, _____. 21 22 23 __________________________ (Notary Public) 24 25 My Commission Expires: