EFTA00298293.pdf
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-CIV-80119-MARRA/JOHNSON
JANE DOE NO. 2,
Plaintiff,
-vs- VOLUME II OF II
JEFFREY EPSTEIN,
Defendant.
Related cases:
08-80232, 08-08380, 08-80381, 08-80994
08-80993, 08-80811, 08-80893, 09-80469
09-80591, 09-80656, 09-80802, 09-81092
DEPOSITION OF
DETECTIVE JOSEPH RECAREY
Friday, March 19, 2010
9:37 - 5:12 p.m.
-250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
Job No.: 1509
au&
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by eynthla hopkins (601
Electronically signed by cynthia bodkins (601
Electronically signed by cynthia hopkins (601 ea2stiddbfaB1-4f16-b3b7deda51494142
EFTA00298293
EFTA00298294
Page 131 Page 133
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL t APPEARANCES
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 On bead( cflbe Plaintiffs, B3.CL
2 CASE No.502038CA0373I9/000CMB AB 3 SPENCER T. KUM!. ESQUIRE
3 LEOPOLD KUVIN
4 2925 PGA Bodevard
B.B. Suite 200
4 5 Pam flaida 33410
Plaintiff Phone.
S 6
6 -vs- VOLUMBIIOFII 7 On behalf et the Pin:dirk Ltd E.W and
7 Jane Doe:
A
j121.11 9 BRADLEY J. EDWARDS, ESQUIRE
8 FARMER, JAFFE, WEISSING, EDWARDS
Defendants. 10 FISTOS & LEHRMAN, P.L.
9 425 Rath Anikens Avenue
10 11 Stile 2
11 Fat 33301
12 DEPOSITION OF 12 Maw
13 On behalf ace a I Drench 8.
DETECTIVE JOSEPH RECAREY 14 JESSICA ARDOUR. ESQUIRE
13 MERMELS1131N k HOROW112., P.A.
14 Friday, March 19, 2010 15 16205 Biscayne Boulevard
15 9:37 - 5:12 p.m. Suite 2218
16 250 Australian Avenue South 16 Miami, 3 60
Suite 1500 nom
17 West Palm Beach, Florida33401 17 &mad
18 18 Onbelsalf, t e 3Ulli..S s , and
103.
19 19
20 20 KAI/691M W EZELL, ESQUIRE
21 PODHURST ORSEOC
22 Reported By. 21 25 Wen Hagler Street
Cynthia Hopkins, RPR, FPR SAC 800
23 Notary Public, State ofFlorida 22
Prose Court Reporting Moe:
24 23 (Via one)
Job No.: 1509 24
25 25
Page 132
1 Appearances oonimued
2 UNITED STATES DISTRICT COURT 2 On behalf of the FlairditT, Ina Doe No.11:
3 IDDRO MANUEl. °ARM, ESQUIRE
SOUITIIRN DISTRICT OF FLORIDA GARCIA ELKINS& BOEHRINCER
3 4 224 Diva Ann, Sale 900
CASE NO. 10.80309 Wen PUS& 33401
4 5 Phe
6 and
5 JANE DOE NO. 103, 7 TARA A FDDILGAN, ESQUIRE
6 Plabtiff, TARA A MINICAR. P A
7 -vs- VOLUMEII OF II 8 224 Dina Street
8 JEFFREY EPSTEIN, Suite 900
9 Defendant. 9 West tide 3340!
Mae:
10
10 1/. Cte tehalfof the Defendant inlay Epstein:
11 12 MICHAEL PIKE, ESQUIRE
12 DEPOSITION OF BURMAN, ORITTON, LUIT1ER & COLEMAN, U.1)
DETECTIVE JOSEPH RECAREY 13 303 Barn Bouienad
Suite 4t0
13 14 West tads. 33401
14 Friday, March 19, 2010 Phone-
IS 9-37 - 5:12 pm. 15
16 250 Australian Avenue South 16 and
17 AO; ALAN GOUAERGER, ESQUIRE
Suite 1500 ATTERBURY, GOLDBERGER & WELSS, PA
17 West Palm Beach, Florida 33401 10 250 AttuWine Avenue Sash
18 Suite 1400
19 19 west P • 'dm 334014012
20 Phan'
20
21 21 and
22 Reported By: 22 lifiLTON G. wrgramo. ESQUIRE
Cynthia Hopkins, RPR, FPR LAW OFFICE OF MILTON 0. WEIMER°
23 Notary Public, State ofFlorida 23 20 Pat Plaza
Sine I COO,
Prose Court Reporting 24 Boston. 02116
24 Mb No.: 1509 Phone
25 25
2 (Pages 131 to 134)
PROSE COURT REPORTING AGENCY, INC.
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Page 135 Page 137 g
Appearances continued... CONTINUED DIRECT EXAMINATION
2 On behalf of the Witness: BY MR. KUVIN:
3 JOANNE M. O'CONNOR. ESQUIRE 3 Q. All right. We were going over the
JONES,}vs eft, JOHNSON & STUBBS, P.A. 4 property receipts for the search warrant when we
4 505 South Elegies Drive, Suite 1100
West Nitride 33401 5 left off. And specifically we were at Page 2. We
5 Phone: 6 were looking at some of the things that you took in.
6 7 Each item that you took dining the search warrant
7 Also Present: Jeffrey Epstein 8 was numbered; is that correct?
8. 9 A. Correct
9 INDEX 10 MR. PIKE: Foram.
10
11 BY MR. KUVIN:
12 EXAMINATION DIRECT CROSS REDIRECT 12 Q. And the item number appears where?
13 CONTINUED EXAMINATION BY 13 MR. PIKE: Form.
14 het ICUVIN 134 14 THE WITNESS: Under item number.
15 BY MR. EDWARDS 243 15 BY MR. KUVIN:
16 16 Q. All right And this is a standard form
17 •
18 EXHIBITS 17 wed by the police department?
19 18 A. That's correct.
20 19 MR. PIKE: Fonm
21 EXHIBIT DESCRIPTION PAGE 20 BY MR. KUVIN:
22 21 Q. All right If we look at Item Number 24,
23 PLARTI1FF'S EX. S SUPPLEMENT FOR CHAIN 151 22 what MS that?
OF CUSTODY LOG 23 MR. PIKE: Form.
24 PLAINTIFFS EX. 6 PAGE FROM MESSAGE PAD 196
PLAINTIFFS EX. 7 PHONE MESSAGE 204 24 THE WITNESS: It was a twin torpedo in a
25 25 brown box.
Page 136 Page 138
1 BY MR. KUVIN:
EXHIBITS CCeITINUED
2 2 Q. What is that?
3 MONT DESCRIPTION PAGE 3 MR. PIKE: Form.
4 PLANETS EX S PHONE MESSAGE 205
PLAINTIFFS Ex 9 PHONE MESSAGE 208 4 THE WITNESS: It is a synthetic penis,
$ PLAINTIFFS EC 10 PHONE MESSAGE 209 5 double, double sided.
PLAINTIFFS EC 11 PHONE MESSAGE 211
6 PLAINTIFFS EX 12 PHONE MESSAGE 212 6 BY MR. KUVIN:
PLAINTIFFS EX 13 PHONE MESSAGE 213 7 Q. Okay. Double sided meaning it has, what,
7 PLAINTIFF'S EX 14 PHONE MESSAGE 215
PLA/NIIFF'S EC 15 PHONE MESSAGE 215 8 two heads on it?
8 FIAINTIFFS EC 16 PHONE MESSAGE 217' 9 A. Yes.
PLAINTIFFS EX 17 PHONE MESSAGE 219
9 PLAINTIFFS EX IS PHONE MESSAGE 220 10 MR. PIKE: Fonm.
PLAINTIFFS EC. I9 PHONE MESSAGE 221 11 BY MR. KUVIN:
10 PLAINTIFFS DC 20 PHONE MESSAGE 222
PLAINTIFFS DC 21 PHONE MESSAGE 223 12 Q. How big is this?
11, PLAINTIFFS EC 22 PHONE MESSAGE 22$ 13 A. About 12 inches, 10, 12 inches.
PLAINTIFFS DC. 23 AND 24 PHOTOS 227
12 PLAINTIFFS EX. 2$ PHo GE 230 14 MR. PIKE: Objection to the form of that
PLABTTIFFSFX. 26MS. 240 15 question.
13 CELLINIONE LOG
PLAINTIFF'S EC 27 LETTER DATED JULY 24, 241 16 BY MR KUVIN:
14 2006 17 Q. Do you know where it was taken from?
PLAINTIFFS DC 28 INTELLIGENCE REPORT 243
15 DATED maw 18 MR. PIKE: Form.
16 19 THE WITNESS: It was in one of the
17
18 20 bedrooms.
19 21 BY MR. KUVIN:
29
• 21
22 Q. Do you know if any DNA analysis was done
22 23 on that?
23
24
24 MR. PIKE: Form.
25 25 THEE WITNESS: Not that I am aware of.
r.), 1,1 .f7
01.1•1•11W*1 CFA,
3 (Pages 135 to 138
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EFTA00298296
Page 139 Page 141
1 (Mr. Epstein returned the deposition 1 THE WITNESS: I believe so.
2 mom.) MR. PIKE: Move to strike.
3 BY MR. KUVIN: BY MR.!MIN:
4 Q. All right. Let's take a look at the next 4 . Q. Where in the house was this transcript
5 page. Item 27, what was that? 5 kelt
6 A. It was a high school transcript — 6 MR. PIKE: Form.
7 MR. PIKE: Form. 7 THE WITNESS: In the desk, the desk drawer
8 THE WITNESS: that was located in the 8 of the — there was a desk in the master
9 master bedroom. 9 bedroom.
10 ' BY MR. KUVIN: 10 BY MR. KUVIN:
11 Q. Appears to be something blacked out. What 11 Q. Okay; So, in the master bedroom?
12 is blacked out? 12 MR. PUCE: Form.
13' . A. The name of Jane Doe No. 103. 13 THE WITNESS: Yes, sir.
14 MR. PIKE: Form. 14 BY MR. KUVIN:
15 BY MR. KUVIN: 15 Q. Was there an office downstairs as well?
16 Q. Okay. Did you actually see this? 16 A. Yes.
17 A. Yes, I did. 17 Q. It was not found in the office?
18 Q. And can you describe for me what it was? 18 MR. PIKE: Form.
19 MR. PIKE: Form. 19 THE WITNESS: No..
20 THE WITNE • was h hi school 20 BY MR. KUVIN:
21 transcript from High School. 21. . Q. The next thing, Item 28, what was that?
22 BY MR. KUVIN: .. 22. A. That was a bottle ofJoy Jelly.
23 Q. Now, it says "VALUE not" What does that• 23 Q Did you determine what that is?
24. mean? 24 MR. PIKE: Form.
25 MR. PIKE: Form. 25 THE WITNESS: It's a lubricant
Page 140 Page 142
THE WITNESS: That was written by Greg 1 MR. KUVIN: Sexual lubricant?
Parkinson, our crime scene manager, who was 2 MR. PUCE: Form.
3 filling the form as to, when we identified the •3 • THE WITNESS: That's correct
4 object we wanted to take, you would put it on . 4 BY MR. KUVIN:
5 the property receipt 5 Q. Where was that found?
6 BY MR. KUVIN: 6 A. In the credenza in the master bedroom.
7 Q. Okay. With respect to this particular 7 MR. PIKE Form.
8 transcript, was this taken by the FBI when they took' 8 BY MR. KUVIN:
9 all the evidence? 9 Q. Item 29 appears to be a bunch of
10 A. Yes. 10 videotapes?
11 MR. PIKE: Form. 11 A. Yes.
12 BY MR. KUVIN: 12 Q. There is one there called "I Love Lesbians
13 Q. Did you ever determine why her high school 13 Four." Do you see that?
14 transcript was found in Mr. Epstein's home? 14 A. Yes.
15 MR. PIKE: Form. 15 Q. Where was that found?
16 ME WITNESS: During my interview with' , 16 MR. PUCE: Form.
17 : het, she claimed that Mr. Epstein had said that 17 THE WITNESS: The master bedroom.
18. he was going to help her get into a good • 18 BY MR. KUVIN:
19. college and when she graduated to give him a 19 Q. Did you find massage tables during the
20 copy of the transcript to assist her in getting 20 search of the home?
21'. into a college. 21 MR. PIKE: Form. .
22 BY MR. KUVIN: 22 THE. WITNESS: Yes, we did. We found a
23 Q. Did the high school transcript show her 23 couple ofmassage tables.
24 date ofbirth? 24 BY MR. KUVIN:
25 MR. PIKE: Form. 25 Eyhere?
4 (Pages 139 to 142)
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EFTA00298297
Page 143 Page 145
MR. PIKE: Form. 1 in any format that you felt was useful evidence for
THE WITNESS: One was in the master 2 Mr. Epstein's prosecution that was currently being
3 bedroom area. There was another one found in 3 investigated?
4 another bedroom area. There were different .4 MR. PIKE: Form.
colors. There was like a green one, a white '5 THE WITNESS: There was a CPU that was in
one, a peach one but -- 6. an office like the assistant's office.
7 BY MR. KUVIN: 7 MR. KUVIN: Okay.
8 Q. Okay. Did you, yourself, personally see 8 THE WITNESS: That was not connected. It
9 the massage tables in the home when you were-there 9 was an Older CPU which was taken to the
10. for the warrant? 10 Sheriffs Office for — to be analyzed.
11 MR. PIKE: Form. 11 MR. KUVIN: Okay.
12 THE WITNESS: That is correct. 12 THE WITNESS: They were able to retrieve
13 BY MR. KUVIN: 13 some images off that computer from that covert
14 Q. It appears that Item 34 was a number of 14 camera in the living room, in that office
15 CD's? 15 living room area.
16 A. Correct. 16 BY MR. KUVIN:
17 Q. Did you ever determine what was on them? 17 Q. And what did those images show?
18 A. Everything was viewed, some of the CD's were 18 MR. PIKE: Form.
19 empty. But at the time we didn't know, we just had to 19. THE WITNESS: It showed Mr. Epstein
20 take it and view it. 20 sitting at his desk. It was basically motion
21 Q. Items 34 through 40 on the list appears to 21 activated. When there was motion, it would
22 be a bunch of different medias such as ZIP CD's and 22 start to record. So, there was, there were
23 eight millimeter video, flash cards, ZIP CD's and 23 images of Epstein at his desk. There was
24 CD's. Did you view all those materials? 24 images of his assistant with Mr. Epstein
25 A. That is correct. 25 sitting at the desk. There were images of what
Page 144 Page 14.
1 MR. PIKE: Form. 1. I believe to be also shown as
2 BY MR. KUVIN: 2 well.
3 Q. Was there anything on these materials that 3 Again, the lighting was poor so a, I
4 are listed on here, 34 through 40, that showed any 4 couldn't positively say 100 percent, okay,
5 girls that you determined to be underage? 5 that's so-and-so. I could say that was
6 MR. PIKE: Form. 6 Mr. Epstein because I have seen Mr. Epstein. I
7 THE WITNESS: Some of the items that we 7 know what he looks like. You know I can say
8 took from the guesthouse area were determined the female did appear to be one
9 to be Janusz's, the houseman, live-in houseman, 9 of the assistants appeared to be
10 items which was returned to him once we 10 You know, that kind of thing.
11. determined that it was his. 11 BY MR. KUVIN:
12 BY MR. KUVIN: 12 Q. All right. Did you see any other girls in
13 Q. Okay. Anything else that you found on 13 that video that was on the CPU?
14 there that you felt was of value for the prosecution 14 MR. PIKE: Form.
15 of Mr. Epstein? 15 THE WITNESS: There was someone else but
16 MR. PIKE: Form. 16 just can't recall who it was.
17 BY MR. KUVIN: 17 BY MR. KUVIN:
18 Q. That you can recall. 18 Q. Where is that CPU now if you knovfl
19 MR PIKE: Same. 19 A. With the FBI.
20 THE WITNESS: From the guesthouse? 20 Q. Was there any other digital information
21 BY MR. KUVIN: 21 that was seized that you were able to see that you
22 Q. Well let me ask it this way, a little bit 22 felt was helpful in any way to the investigation?
23 broader: Based on the information that you 23 MR. PIKE: Form.
24 confiscated from the home during the warrant, search 24 THE WITNESS: Not off the computer.
25 warrant, did you find any cons uterized r nf
5 (Pages 143 to 146)
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Page 147 Page 149
1 BY MR. KUVIN: 1 BY MR. KUVIN:
2 Q. What about on any of the CD's or 2 Q. I want to come back to that fora minute.
3 flashcards that were taken? 3 How many CPU's did it appear to you were missing?
4 MR. PIKE: Form. 4 MR. PIKE: Form and speculation.
5 THE WITNESS: There was a video. It 5 THE WITNESS: There was one missing from
6 appears to be, it appears to be in the private 6 the desk area in the living room with the power
7 island of Mr. Epstein when you see a helicopter 7 cords — all the cords were there. The CPU was
8 coming in, and there was some females there gone.
9 dancing 9 MR KUVIN: Okay.
10 BY MR KUVIN: 10 THE WITNESS: There was one from the pool
11 Q. Was this on a computer format like a CD or 11 house where the cords were there, the monitor
12 a flash drive or — 12 was there, the keyboard, the mouse. The CPU
13 A.. I believe it was an — 13 was gone. I would say two.
14 Q. — an eight millimeter? 14 BY MR. KUVIN:
15 A. I might have been an — 15 Q. Okay. Did you ever come to team during
16 MR. PIKE: Form. 16 the investigation where those CPU units were?
17 THE WITNESS: Eight millimeter. 17 MR. PIKE: Form.
18 BY MR. KUVIN: 18 THE WITNESS: I believe I was told that
19 Q. Okay. Any other media information that 19 those CPUs were actually sitting in an
20 you can recall after having reviewed all of the 20 attorneys safe.
21 things that you confiscated from the home that you 21 BY MR. KUVIN:
22 found was helpful in the investigation? 22 Q. Okay. Did you come to learn that they,
23 MR. PIKE: Form. 23 that Guy Fronstin had actually taken possession of
24 THE WITNESS: Not that I can recall. 24 those? Does that refresh your recollection at all,
25 25 or was it another attorney?
Page 148 Page 150
1 BY MR. KUVIN: 1 MR. PIKE: Forst
2 Q. Now, it appears that you confiscated as 2 THE WITNESS: I was told it was Roy
3 part of the search warrant a number of CPUs and 3 Black's office that had them.
4 their power cords; is that correct? 4 BY MR. KUVIN:
5 A. Yes. 5 Q. Gotchat. All right. Let's keep going
6 MR. PIKE: Form. What page are you on? 6 here. Item 58 was another massage table that was
7 MR. KUVIN: It looks like 43 and 44. 7 taken as evidence?
8 Items 43 and 44 are the first power cords and 8 A. Correct.
' 9 CPU. Items 54 and 55 are the second power cord 9 MR_ PIKE: Form.
10 and CPU. 10 BY MR. KUVIN:
11 BY MR. KUVIN: 11 Q. You saw that massage table?
12 Q Do you recall how many CPUs you took into 12 A. Yes, sir.
13 custody? 13 Q: Okay. La look at the next page, six of
14 • A. We took a couple but obviously one of them 14 six. It says a green photograph with a naked girl.
15 was positive that it belonged to Janusz because it had 15 Do you recall where that was taken from?
16 all his personal stuff; his personal photographs of he 16 A. That was taken out of the, I believe, master
17 and his wife. So those were returned to him. 17 bedroom.
18 Q. Okay. 18 MR. PIKE: Form.
19 MR. PIKE: Form to that question. 19 BY MR. KUVIN:
20 BY MR. KUVIN: 20 ' Q. Could you tell by looking at the
21 Q You mentioned at the beginning when you 21 photograph whether it was an underage girl?
22 executed the search warrant that you felt in your 22 MR. PIKE: Form.
23. opinion the house had been sanitized because you 23 BY MR. KUVIN:
24 noticed things that appeared to be missing. 24 Q. I mean, was it a young girl, a mature
25 MR. PIKE: Form. 25 girl, old?
•••••••••••sts•n eV1---, 204aV vie lS4LS .o.,...,
6 (Pages 147 to 150 )
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Page 151 Page 153
A. No, it was a young girl. 1 touched on this briefly in the beginning, but what
2 MR. PIKE: Same objection. 2 happened with the investigation once you filed the
3 THE WITNESS: Very young girl. 3 probable cause affidavit and got the warrant? At
4 BY MR. KUVIN: 4 what point did you turn it over to the State
5 Q. Could you tell the age from the photo? 5 Attorney's Office?
MR. PIKE: Form. 6 A. Once I filed the arrest warrant for
.7 THE WITNESS: Younger than ten. 7 Mr. Epstein, there were actually three warrant requests
8 BY MR. KUVIN: to be honest with you. There was a warrant raLmt for
Q. Could you find any photographs of girls 9 Je in, I want to say =, and
10 that were victims during the investigation? Did you 10
11 find any photographs of girls that were victims 11 Q. Okay. What happened with those arrest
12 during the investigation? 12 warrants for all three of them?
13 MR. PIKE: FOUR 13 MR. PIKE: Form.
14 THE WITNESS: There were photographs taken 14 THE WITNESS: Once they were turned over
15 during the search warrant, topless females that 15 to the State Attorney's office, I was notified
16 were taken. But no, I did not locate one of 16 several days later that they were going to be
17 the victims in the photos. 17 requesting a grand jury to listen to the case.
18 MR. KUVIN: Okay. If we look at what 18 BY MR. KUVIN:
19 we'll mark as Exhibit 5, appears to be a 19 Q. Okay. And did a grand jury hear the case
20 supplement of the chain of custody log. two 20 as far as you know?
21 pages. Make sure I have got it. Ifs three 21 A. Eventually they did.
22 pages actually. 22 Q. And do you know what occurred after the
23 (Plaintiffs Exhibit No. 5 was marked for 23 grand jury heard the case?
24 identification.) 24 MR. PIKE: Form.
25 25 THE WITNESS: It was true bill.
Page 152 Page 154
1 BY MR. KUVIN: 1 BY MR. KUVIN:
2 Q. We have got what appears to be a four-page Against?
3 document which happens to be called a chain of 3 A. Mr. Epstein.
4 custody. I just have a couple quick questions about 4 Q Just for people that may not know what a
5 this. 5 true bill is, can you explain briefly what that
If you would look at the last entry in the 6 means?
7 • chain of custody, I just wanted to coafum where all 7 A. Grand jury found sufficient evidence to charge
8 the evidence went according to the documentation. 8 Mr. Epstein.
9 A. Everything went TOT, to the FBI. 9 Q What was he charged with?
10 Q. I am sorry, what were the initials? 10 MR. PIKE: Form.
11 A. TOT. THE WITNESS: I think it was, it was a
12 Q. What does that mean? 12 procurement for prosecution.
13 A. Given to the FBI. 13 BY MR. KUVIN: ' .
14 Q Okay. So the chain of custody which we 14 Q. Have to do with minors?
15 have marked as Exhibit 5 shows that all the evidence 15 A. Yes.
16 you had in this case was given over to the FBI; is 16 MR. PIKE: Form.
17 that correct? 17 BY MR. KUVIN:
18 MR. PIKE: Form. 18 Q All right. After the execution of the
19 THE WITNESS: The items that were returned 19 search warrant, your investigation continued; is
20 to Janusz were returned to Janusz (sic). The 20 that correct?
21 items that were not returned were given to the 21 A. Correct
22 FBI. 22 Q. And during the investigation, did you have
23 BY MR. KUVIN: 23 occasion to speak with or meet with a gentleman by
24 Q. Okay. Great. All right. Ultimately what 24 the name of Juan Alessi?
25 happened with respect to the investigation, and I 25 A. Juan Alessi, yes.
7 (Pages 151 to 154)
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Page 155 Page 157
1 Q. Who was that? 1 THE W/TNESS: No.
2 A. He was the former houseman of Mr. Epstein. 2 BY MR. KUVIN:
3 MR. PIKE: Form. 3 Q. Narrative 18, it looks like you matte
4 BY MR. KUVIN: 4 telephone contact with another white, looks like WF,
5 Q. Did he give you information that you felt 5 I assume it means white female, on November 8. Do
6 was helpful in the prosecution of Mr. Epstein? 6 you recall which girl that may have been?
7 MR. PIKE: Form. 7 MR. PIKE: Form.
8 THE WITNESS: He described, he described 8 BY MR. KUVIN:
9 washing off the vibrator massagers after the 9 Q. Let me ask it this way: Was this a
10 massage incidents. He recalled having young 10 recounting of the incident with Ms. Jane Doe No.
11. girls coming in to do the massages. 11 103?
12 BY MR. KUVIN: 12 A. No.
13 Q. Did he mention that he, whether he 13 Q. This is a different girl?
14 witnessed that? 14 A. Ibis is a different girl.
15 MR. PIKE: Move to strike witness's last 15 MR. PACE: Form to both questions.
16 statement pending hearsay and form. 16 THE WITNESS: This was a different girl
17 Mr. Kuvin, next question if he has 17 and I am trying to remember who it was.
18 completed it. 18 BY MR. KUVIN:
19 BY MR KUVIN: 19 Q. Do you recall the name M?
20 Q. Did he mention whether or not he had 20 A. Yes.
21 witnessed young girls coming to the house? 21 Q. Is that who this was?
22 MR. PIKE: Same objection. 22 MR. PIKE: Form.
23 THE WITNESS: Yes. 23 THE WITNESS: Yes, it was.
24 BY MR. KUVIN: 24 BY MR. KUVIN:
25 Q. If we look back at the incident report 25 Q. Okay. And apparently she had reported
Page 156 Page 158
1 Page 47 — got it there — it looks like you made 1 sexual intercourse with Mr. Epstein?
2 contact, telephone contact with another girl on 2 A. That is correct.
3 November 7 of 2005, and took another taped 3 MR. PIKE: Form, leading.
4 statement, sworn taped statement. Can you determine 4 BY MR. KUVIN:
by looking at your swnmary there in Narrative 16 of 5 Q. Did she report any sexual contact with
6 November 7,2005, which girl that was? 6 Mr. Epstein?
7 MR. PIKE: Form. 7 A. Yes, she did.
8 THE WITNESS: I believe that was■ 8 Q. What type?
9 MR. KUVIN: 9. MR. PIKE: Form.
10 THE WITNESS: 10 THE WI NESS: She was paid to have vaginal
BY MR. KUVIN: 11 intercourse.
11
12 Q. Do you recall wha.s state of mind or 12 MR. PIKE: Form, move to strike.
13 emotional condition was when she spoke to you about 13 BY MR. KUVIN:
14 this event? 14 Q. Did you determine how old she was when she
15 MR. PIKE: Form. 15 reported having this vaginal intercourse with
16 THE WITNESS: I can't recall. 16 Mr. Epstein?
17 BY MR. KUVIN: 17 MR. PIKE: Form.
18 Q. Let's take a look at Narrative 17. It 18 THE WITNESS: Sixteen years of age.
19 looks like you made contact with someone else, you 19 MR. PIKE: Spencer, can you hold on?
20 along with Detective Dawson made contact with 20 MR. KUVIN: Yes, sir.
21 somebody and left a business card at the front door. 21 MR. PIKE: Letts go off the record for a
22 Do you see that? 22 second.
23 A. Yes. Yes,' do see it. 23 (A discussion was held off the record.)
24 Q. Do you recall which girl that was? 24 MS. EZELL: If I could interject, I was
25 MR. PIKE: Form. 25 fumblin on mute and I wanted to move to strike
•••••••••••••
8 (Pages 155 to 158)
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1 the witness's comment that she was paid to have 1 MR. PIKE: Form.
2 vaginal intercourse with Mr. Epstein. 2 BY MR. KUVIN:
3 MR. KUVIN: Okay. 3 Q. Does she describe whether or not she had
4 BY MR. KUVIN: 4 gone to Mr. Epstein's home?
5 Q. Do you recall the demeanor ofM when 5 A. Yes.
6 she was recounting this for you? 6 MR. PIKE: Form.
7 MR. PIKE: Form. 7 BY MR. KUVIN:
8 BY MR. KUVIN: 8 Q. Did she describe whether or not she
9 Q. Was she upset, calm? How did she appear brought anyone with her during that time?
10 to you? 10 MR. PIKE: Form.
11 MR. PIKE: Form. 11 THE WITNESS: If I can read —
12 THE WITNESS: She did — I recall her 12 MR. KUVIN: Yes. You can refer back to it
13 being upset, talking to me. Occasionally 13 if you need to.
14 crying. It wasn't like a hysterical cry but MR. PIKE: For the record you're referring
15 she was visibly upset 15 back to Exhibit 1, correct?
16 BY MR. KUVIN: 16 THE WITNESS: Correct. Yes, she did.
17 Q. Okay. Do you recall Ms. Ms date of 17 BY MR. KUVIN:
18 birth? 18 Q. Okay. Now, if we look at Page 16 of 22
19 A. Not off the top of my head. 19 there with respect to Ms.■ it mentions
20 MR. KUVIN: All right. Let me see if I 20 something about a Christmas bonus. Do you see that?
21 can help you here. It looks like we have an 21 A. Yes.
22 unredacted copy of the PC affidavit That will 22 Q Can you explain to us what she told you
23 help. This document will remain sealed 23 about that?
24 pursuant to all previous agreements in the case 24 MR. PIKE: Form.
25 with respect to any documents that we referred 25 THE WITNESS: She received a wire, a
Page 160 Page 162
to. 1 Western Union wire to what she referred to as a
2 THE WITNESS: That's Exhibit 1? 2 Christmas bonus.
3 MIt KUVIN: Bingo. Do you have a copy? 3 Q. Who did it come from?
4 MR. PIKE: Than
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-CIV-80119-MARRA/JOHNSON
JANE DOE NO. 2,
Plaintiff,
-vs- VOLUME II OF II
JEFFREY EPSTEIN,
Defendant.
Related cases:
08-80232, 08-08380, 08-80381, 08-80994
08-80993, 08-80811, 08-80893, 09-80469
09-80591, 09-80656, 09-80802, 09-81092
DEPOSITION OF
DETECTIVE JOSEPH RECAREY
Friday, March 19, 2010
9:37 - 5:12 p.m.
-250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
Job No.: 1509
au&
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by eynthla hopkins (601
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Page 131 Page 133
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL t APPEARANCES
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 On bead( cflbe Plaintiffs, B3.CL
2 CASE No.502038CA0373I9/000CMB AB 3 SPENCER T. KUM!. ESQUIRE
3 LEOPOLD KUVIN
4 2925 PGA Bodevard
B.B. Suite 200
4 5 Pam flaida 33410
Plaintiff Phone.
S 6
6 -vs- VOLUMBIIOFII 7 On behalf et the Pin:dirk Ltd E.W and
7 Jane Doe:
A
j121.11 9 BRADLEY J. EDWARDS, ESQUIRE
8 FARMER, JAFFE, WEISSING, EDWARDS
Defendants. 10 FISTOS & LEHRMAN, P.L.
9 425 Rath Anikens Avenue
10 11 Stile 2
11 Fat 33301
12 DEPOSITION OF 12 Maw
13 On behalf ace a I Drench 8.
DETECTIVE JOSEPH RECAREY 14 JESSICA ARDOUR. ESQUIRE
13 MERMELS1131N k HOROW112., P.A.
14 Friday, March 19, 2010 15 16205 Biscayne Boulevard
15 9:37 - 5:12 p.m. Suite 2218
16 250 Australian Avenue South 16 Miami, 3 60
Suite 1500 nom
17 West Palm Beach, Florida33401 17 &mad
18 18 Onbelsalf, t e 3Ulli..S s , and
103.
19 19
20 20 KAI/691M W EZELL, ESQUIRE
21 PODHURST ORSEOC
22 Reported By. 21 25 Wen Hagler Street
Cynthia Hopkins, RPR, FPR SAC 800
23 Notary Public, State ofFlorida 22
Prose Court Reporting Moe:
24 23 (Via one)
Job No.: 1509 24
25 25
Page 132
1 Appearances oonimued
2 UNITED STATES DISTRICT COURT 2 On behalf of the FlairditT, Ina Doe No.11:
3 IDDRO MANUEl. °ARM, ESQUIRE
SOUITIIRN DISTRICT OF FLORIDA GARCIA ELKINS& BOEHRINCER
3 4 224 Diva Ann, Sale 900
CASE NO. 10.80309 Wen PUS& 33401
4 5 Phe
6 and
5 JANE DOE NO. 103, 7 TARA A FDDILGAN, ESQUIRE
6 Plabtiff, TARA A MINICAR. P A
7 -vs- VOLUMEII OF II 8 224 Dina Street
8 JEFFREY EPSTEIN, Suite 900
9 Defendant. 9 West tide 3340!
Mae:
10
10 1/. Cte tehalfof the Defendant inlay Epstein:
11 12 MICHAEL PIKE, ESQUIRE
12 DEPOSITION OF BURMAN, ORITTON, LUIT1ER & COLEMAN, U.1)
DETECTIVE JOSEPH RECAREY 13 303 Barn Bouienad
Suite 4t0
13 14 West tads. 33401
14 Friday, March 19, 2010 Phone-
IS 9-37 - 5:12 pm. 15
16 250 Australian Avenue South 16 and
17 AO; ALAN GOUAERGER, ESQUIRE
Suite 1500 ATTERBURY, GOLDBERGER & WELSS, PA
17 West Palm Beach, Florida 33401 10 250 AttuWine Avenue Sash
18 Suite 1400
19 19 west P • 'dm 334014012
20 Phan'
20
21 21 and
22 Reported By: 22 lifiLTON G. wrgramo. ESQUIRE
Cynthia Hopkins, RPR, FPR LAW OFFICE OF MILTON 0. WEIMER°
23 Notary Public, State ofFlorida 23 20 Pat Plaza
Sine I COO,
Prose Court Reporting 24 Boston. 02116
24 Mb No.: 1509 Phone
25 25
2 (Pages 131 to 134)
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Page 135 Page 137 g
Appearances continued... CONTINUED DIRECT EXAMINATION
2 On behalf of the Witness: BY MR. KUVIN:
3 JOANNE M. O'CONNOR. ESQUIRE 3 Q. All right. We were going over the
JONES,}vs eft, JOHNSON & STUBBS, P.A. 4 property receipts for the search warrant when we
4 505 South Elegies Drive, Suite 1100
West Nitride 33401 5 left off. And specifically we were at Page 2. We
5 Phone: 6 were looking at some of the things that you took in.
6 7 Each item that you took dining the search warrant
7 Also Present: Jeffrey Epstein 8 was numbered; is that correct?
8. 9 A. Correct
9 INDEX 10 MR. PIKE: Foram.
10
11 BY MR. KUVIN:
12 EXAMINATION DIRECT CROSS REDIRECT 12 Q. And the item number appears where?
13 CONTINUED EXAMINATION BY 13 MR. PIKE: Form.
14 het ICUVIN 134 14 THE WITNESS: Under item number.
15 BY MR. EDWARDS 243 15 BY MR. KUVIN:
16 16 Q. All right And this is a standard form
17 •
18 EXHIBITS 17 wed by the police department?
19 18 A. That's correct.
20 19 MR. PIKE: Fonm
21 EXHIBIT DESCRIPTION PAGE 20 BY MR. KUVIN:
22 21 Q. All right If we look at Item Number 24,
23 PLARTI1FF'S EX. S SUPPLEMENT FOR CHAIN 151 22 what MS that?
OF CUSTODY LOG 23 MR. PIKE: Form.
24 PLAINTIFFS EX. 6 PAGE FROM MESSAGE PAD 196
PLAINTIFFS EX. 7 PHONE MESSAGE 204 24 THE WITNESS: It was a twin torpedo in a
25 25 brown box.
Page 136 Page 138
1 BY MR. KUVIN:
EXHIBITS CCeITINUED
2 2 Q. What is that?
3 MONT DESCRIPTION PAGE 3 MR. PIKE: Form.
4 PLANETS EX S PHONE MESSAGE 205
PLAINTIFFS Ex 9 PHONE MESSAGE 208 4 THE WITNESS: It is a synthetic penis,
$ PLAINTIFFS EC 10 PHONE MESSAGE 209 5 double, double sided.
PLAINTIFFS EC 11 PHONE MESSAGE 211
6 PLAINTIFFS EX 12 PHONE MESSAGE 212 6 BY MR. KUVIN:
PLAINTIFFS EX 13 PHONE MESSAGE 213 7 Q. Okay. Double sided meaning it has, what,
7 PLAINTIFF'S EX 14 PHONE MESSAGE 215
PLA/NIIFF'S EC 15 PHONE MESSAGE 215 8 two heads on it?
8 FIAINTIFFS EC 16 PHONE MESSAGE 217' 9 A. Yes.
PLAINTIFFS EX 17 PHONE MESSAGE 219
9 PLAINTIFFS EX IS PHONE MESSAGE 220 10 MR. PIKE: Fonm.
PLAINTIFFS EC. I9 PHONE MESSAGE 221 11 BY MR. KUVIN:
10 PLAINTIFFS DC 20 PHONE MESSAGE 222
PLAINTIFFS DC 21 PHONE MESSAGE 223 12 Q. How big is this?
11, PLAINTIFFS EC 22 PHONE MESSAGE 22$ 13 A. About 12 inches, 10, 12 inches.
PLAINTIFFS DC. 23 AND 24 PHOTOS 227
12 PLAINTIFFS EX. 2$ PHo GE 230 14 MR. PIKE: Objection to the form of that
PLABTTIFFSFX. 26MS. 240 15 question.
13 CELLINIONE LOG
PLAINTIFF'S EC 27 LETTER DATED JULY 24, 241 16 BY MR KUVIN:
14 2006 17 Q. Do you know where it was taken from?
PLAINTIFFS DC 28 INTELLIGENCE REPORT 243
15 DATED maw 18 MR. PIKE: Form.
16 19 THE WITNESS: It was in one of the
17
18 20 bedrooms.
19 21 BY MR. KUVIN:
29
• 21
22 Q. Do you know if any DNA analysis was done
22 23 on that?
23
24
24 MR. PIKE: Form.
25 25 THEE WITNESS: Not that I am aware of.
r.), 1,1 .f7
01.1•1•11W*1 CFA,
3 (Pages 135 to 138
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Page 139 Page 141
1 (Mr. Epstein returned the deposition 1 THE WITNESS: I believe so.
2 mom.) MR. PIKE: Move to strike.
3 BY MR. KUVIN: BY MR.!MIN:
4 Q. All right. Let's take a look at the next 4 . Q. Where in the house was this transcript
5 page. Item 27, what was that? 5 kelt
6 A. It was a high school transcript — 6 MR. PIKE: Form.
7 MR. PIKE: Form. 7 THE WITNESS: In the desk, the desk drawer
8 THE WITNESS: that was located in the 8 of the — there was a desk in the master
9 master bedroom. 9 bedroom.
10 ' BY MR. KUVIN: 10 BY MR. KUVIN:
11 Q. Appears to be something blacked out. What 11 Q. Okay; So, in the master bedroom?
12 is blacked out? 12 MR. PUCE: Form.
13' . A. The name of Jane Doe No. 103. 13 THE WITNESS: Yes, sir.
14 MR. PIKE: Form. 14 BY MR. KUVIN:
15 BY MR. KUVIN: 15 Q. Was there an office downstairs as well?
16 Q. Okay. Did you actually see this? 16 A. Yes.
17 A. Yes, I did. 17 Q. It was not found in the office?
18 Q. And can you describe for me what it was? 18 MR. PIKE: Form.
19 MR. PIKE: Form. 19 THE WITNESS: No..
20 THE WITNE • was h hi school 20 BY MR. KUVIN:
21 transcript from High School. 21. . Q. The next thing, Item 28, what was that?
22 BY MR. KUVIN: .. 22. A. That was a bottle ofJoy Jelly.
23 Q. Now, it says "VALUE not" What does that• 23 Q Did you determine what that is?
24. mean? 24 MR. PIKE: Form.
25 MR. PIKE: Form. 25 THE WITNESS: It's a lubricant
Page 140 Page 142
THE WITNESS: That was written by Greg 1 MR. KUVIN: Sexual lubricant?
Parkinson, our crime scene manager, who was 2 MR. PUCE: Form.
3 filling the form as to, when we identified the •3 • THE WITNESS: That's correct
4 object we wanted to take, you would put it on . 4 BY MR. KUVIN:
5 the property receipt 5 Q. Where was that found?
6 BY MR. KUVIN: 6 A. In the credenza in the master bedroom.
7 Q. Okay. With respect to this particular 7 MR. PIKE Form.
8 transcript, was this taken by the FBI when they took' 8 BY MR. KUVIN:
9 all the evidence? 9 Q. Item 29 appears to be a bunch of
10 A. Yes. 10 videotapes?
11 MR. PIKE: Form. 11 A. Yes.
12 BY MR. KUVIN: 12 Q. There is one there called "I Love Lesbians
13 Q. Did you ever determine why her high school 13 Four." Do you see that?
14 transcript was found in Mr. Epstein's home? 14 A. Yes.
15 MR. PIKE: Form. 15 Q. Where was that found?
16 ME WITNESS: During my interview with' , 16 MR. PUCE: Form.
17 : het, she claimed that Mr. Epstein had said that 17 THE WITNESS: The master bedroom.
18. he was going to help her get into a good • 18 BY MR. KUVIN:
19. college and when she graduated to give him a 19 Q. Did you find massage tables during the
20 copy of the transcript to assist her in getting 20 search of the home?
21'. into a college. 21 MR. PIKE: Form. .
22 BY MR. KUVIN: 22 THE. WITNESS: Yes, we did. We found a
23 Q. Did the high school transcript show her 23 couple ofmassage tables.
24 date ofbirth? 24 BY MR. KUVIN:
25 MR. PIKE: Form. 25 Eyhere?
4 (Pages 139 to 142)
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Page 143 Page 145
MR. PIKE: Form. 1 in any format that you felt was useful evidence for
THE WITNESS: One was in the master 2 Mr. Epstein's prosecution that was currently being
3 bedroom area. There was another one found in 3 investigated?
4 another bedroom area. There were different .4 MR. PIKE: Form.
colors. There was like a green one, a white '5 THE WITNESS: There was a CPU that was in
one, a peach one but -- 6. an office like the assistant's office.
7 BY MR. KUVIN: 7 MR. KUVIN: Okay.
8 Q. Okay. Did you, yourself, personally see 8 THE WITNESS: That was not connected. It
9 the massage tables in the home when you were-there 9 was an Older CPU which was taken to the
10. for the warrant? 10 Sheriffs Office for — to be analyzed.
11 MR. PIKE: Form. 11 MR. KUVIN: Okay.
12 THE WITNESS: That is correct. 12 THE WITNESS: They were able to retrieve
13 BY MR. KUVIN: 13 some images off that computer from that covert
14 Q. It appears that Item 34 was a number of 14 camera in the living room, in that office
15 CD's? 15 living room area.
16 A. Correct. 16 BY MR. KUVIN:
17 Q. Did you ever determine what was on them? 17 Q. And what did those images show?
18 A. Everything was viewed, some of the CD's were 18 MR. PIKE: Form.
19 empty. But at the time we didn't know, we just had to 19. THE WITNESS: It showed Mr. Epstein
20 take it and view it. 20 sitting at his desk. It was basically motion
21 Q. Items 34 through 40 on the list appears to 21 activated. When there was motion, it would
22 be a bunch of different medias such as ZIP CD's and 22 start to record. So, there was, there were
23 eight millimeter video, flash cards, ZIP CD's and 23 images of Epstein at his desk. There was
24 CD's. Did you view all those materials? 24 images of his assistant with Mr. Epstein
25 A. That is correct. 25 sitting at the desk. There were images of what
Page 144 Page 14.
1 MR. PIKE: Form. 1. I believe to be also shown as
2 BY MR. KUVIN: 2 well.
3 Q. Was there anything on these materials that 3 Again, the lighting was poor so a, I
4 are listed on here, 34 through 40, that showed any 4 couldn't positively say 100 percent, okay,
5 girls that you determined to be underage? 5 that's so-and-so. I could say that was
6 MR. PIKE: Form. 6 Mr. Epstein because I have seen Mr. Epstein. I
7 THE WITNESS: Some of the items that we 7 know what he looks like. You know I can say
8 took from the guesthouse area were determined the female did appear to be one
9 to be Janusz's, the houseman, live-in houseman, 9 of the assistants appeared to be
10 items which was returned to him once we 10 You know, that kind of thing.
11. determined that it was his. 11 BY MR. KUVIN:
12 BY MR. KUVIN: 12 Q. All right. Did you see any other girls in
13 Q. Okay. Anything else that you found on 13 that video that was on the CPU?
14 there that you felt was of value for the prosecution 14 MR. PIKE: Form.
15 of Mr. Epstein? 15 THE WITNESS: There was someone else but
16 MR. PIKE: Form. 16 just can't recall who it was.
17 BY MR. KUVIN: 17 BY MR. KUVIN:
18 Q. That you can recall. 18 Q. Where is that CPU now if you knovfl
19 MR PIKE: Same. 19 A. With the FBI.
20 THE WITNESS: From the guesthouse? 20 Q. Was there any other digital information
21 BY MR. KUVIN: 21 that was seized that you were able to see that you
22 Q. Well let me ask it this way, a little bit 22 felt was helpful in any way to the investigation?
23 broader: Based on the information that you 23 MR. PIKE: Form.
24 confiscated from the home during the warrant, search 24 THE WITNESS: Not off the computer.
25 warrant, did you find any cons uterized r nf
5 (Pages 143 to 146)
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Page 147 Page 149
1 BY MR. KUVIN: 1 BY MR. KUVIN:
2 Q. What about on any of the CD's or 2 Q. I want to come back to that fora minute.
3 flashcards that were taken? 3 How many CPU's did it appear to you were missing?
4 MR. PIKE: Form. 4 MR. PIKE: Form and speculation.
5 THE WITNESS: There was a video. It 5 THE WITNESS: There was one missing from
6 appears to be, it appears to be in the private 6 the desk area in the living room with the power
7 island of Mr. Epstein when you see a helicopter 7 cords — all the cords were there. The CPU was
8 coming in, and there was some females there gone.
9 dancing 9 MR KUVIN: Okay.
10 BY MR KUVIN: 10 THE WITNESS: There was one from the pool
11 Q. Was this on a computer format like a CD or 11 house where the cords were there, the monitor
12 a flash drive or — 12 was there, the keyboard, the mouse. The CPU
13 A.. I believe it was an — 13 was gone. I would say two.
14 Q. — an eight millimeter? 14 BY MR. KUVIN:
15 A. I might have been an — 15 Q. Okay. Did you ever come to team during
16 MR. PIKE: Form. 16 the investigation where those CPU units were?
17 THE WITNESS: Eight millimeter. 17 MR. PIKE: Form.
18 BY MR. KUVIN: 18 THE WITNESS: I believe I was told that
19 Q. Okay. Any other media information that 19 those CPUs were actually sitting in an
20 you can recall after having reviewed all of the 20 attorneys safe.
21 things that you confiscated from the home that you 21 BY MR. KUVIN:
22 found was helpful in the investigation? 22 Q. Okay. Did you come to learn that they,
23 MR. PIKE: Form. 23 that Guy Fronstin had actually taken possession of
24 THE WITNESS: Not that I can recall. 24 those? Does that refresh your recollection at all,
25 25 or was it another attorney?
Page 148 Page 150
1 BY MR. KUVIN: 1 MR. PIKE: Forst
2 Q. Now, it appears that you confiscated as 2 THE WITNESS: I was told it was Roy
3 part of the search warrant a number of CPUs and 3 Black's office that had them.
4 their power cords; is that correct? 4 BY MR. KUVIN:
5 A. Yes. 5 Q. Gotchat. All right. Let's keep going
6 MR. PIKE: Form. What page are you on? 6 here. Item 58 was another massage table that was
7 MR. KUVIN: It looks like 43 and 44. 7 taken as evidence?
8 Items 43 and 44 are the first power cords and 8 A. Correct.
' 9 CPU. Items 54 and 55 are the second power cord 9 MR_ PIKE: Form.
10 and CPU. 10 BY MR. KUVIN:
11 BY MR. KUVIN: 11 Q. You saw that massage table?
12 Q Do you recall how many CPUs you took into 12 A. Yes, sir.
13 custody? 13 Q: Okay. La look at the next page, six of
14 • A. We took a couple but obviously one of them 14 six. It says a green photograph with a naked girl.
15 was positive that it belonged to Janusz because it had 15 Do you recall where that was taken from?
16 all his personal stuff; his personal photographs of he 16 A. That was taken out of the, I believe, master
17 and his wife. So those were returned to him. 17 bedroom.
18 Q. Okay. 18 MR. PIKE: Form.
19 MR. PIKE: Form to that question. 19 BY MR. KUVIN:
20 BY MR. KUVIN: 20 ' Q. Could you tell by looking at the
21 Q You mentioned at the beginning when you 21 photograph whether it was an underage girl?
22 executed the search warrant that you felt in your 22 MR. PIKE: Form.
23. opinion the house had been sanitized because you 23 BY MR. KUVIN:
24 noticed things that appeared to be missing. 24 Q. I mean, was it a young girl, a mature
25 MR. PIKE: Form. 25 girl, old?
•••••••••••sts•n eV1---, 204aV vie lS4LS .o.,...,
6 (Pages 147 to 150 )
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Page 151 Page 153
A. No, it was a young girl. 1 touched on this briefly in the beginning, but what
2 MR. PIKE: Same objection. 2 happened with the investigation once you filed the
3 THE WITNESS: Very young girl. 3 probable cause affidavit and got the warrant? At
4 BY MR. KUVIN: 4 what point did you turn it over to the State
5 Q. Could you tell the age from the photo? 5 Attorney's Office?
MR. PIKE: Form. 6 A. Once I filed the arrest warrant for
.7 THE WITNESS: Younger than ten. 7 Mr. Epstein, there were actually three warrant requests
8 BY MR. KUVIN: to be honest with you. There was a warrant raLmt for
Q. Could you find any photographs of girls 9 Je in, I want to say =, and
10 that were victims during the investigation? Did you 10
11 find any photographs of girls that were victims 11 Q. Okay. What happened with those arrest
12 during the investigation? 12 warrants for all three of them?
13 MR. PIKE: FOUR 13 MR. PIKE: Form.
14 THE WITNESS: There were photographs taken 14 THE WITNESS: Once they were turned over
15 during the search warrant, topless females that 15 to the State Attorney's office, I was notified
16 were taken. But no, I did not locate one of 16 several days later that they were going to be
17 the victims in the photos. 17 requesting a grand jury to listen to the case.
18 MR. KUVIN: Okay. If we look at what 18 BY MR. KUVIN:
19 we'll mark as Exhibit 5, appears to be a 19 Q. Okay. And did a grand jury hear the case
20 supplement of the chain of custody log. two 20 as far as you know?
21 pages. Make sure I have got it. Ifs three 21 A. Eventually they did.
22 pages actually. 22 Q. And do you know what occurred after the
23 (Plaintiffs Exhibit No. 5 was marked for 23 grand jury heard the case?
24 identification.) 24 MR. PIKE: Form.
25 25 THE WITNESS: It was true bill.
Page 152 Page 154
1 BY MR. KUVIN: 1 BY MR. KUVIN:
2 Q. We have got what appears to be a four-page Against?
3 document which happens to be called a chain of 3 A. Mr. Epstein.
4 custody. I just have a couple quick questions about 4 Q Just for people that may not know what a
5 this. 5 true bill is, can you explain briefly what that
If you would look at the last entry in the 6 means?
7 • chain of custody, I just wanted to coafum where all 7 A. Grand jury found sufficient evidence to charge
8 the evidence went according to the documentation. 8 Mr. Epstein.
9 A. Everything went TOT, to the FBI. 9 Q What was he charged with?
10 Q. I am sorry, what were the initials? 10 MR. PIKE: Form.
11 A. TOT. THE WITNESS: I think it was, it was a
12 Q. What does that mean? 12 procurement for prosecution.
13 A. Given to the FBI. 13 BY MR. KUVIN: ' .
14 Q Okay. So the chain of custody which we 14 Q. Have to do with minors?
15 have marked as Exhibit 5 shows that all the evidence 15 A. Yes.
16 you had in this case was given over to the FBI; is 16 MR. PIKE: Form.
17 that correct? 17 BY MR. KUVIN:
18 MR. PIKE: Form. 18 Q All right. After the execution of the
19 THE WITNESS: The items that were returned 19 search warrant, your investigation continued; is
20 to Janusz were returned to Janusz (sic). The 20 that correct?
21 items that were not returned were given to the 21 A. Correct
22 FBI. 22 Q. And during the investigation, did you have
23 BY MR. KUVIN: 23 occasion to speak with or meet with a gentleman by
24 Q. Okay. Great. All right. Ultimately what 24 the name of Juan Alessi?
25 happened with respect to the investigation, and I 25 A. Juan Alessi, yes.
7 (Pages 151 to 154)
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Page 155 Page 157
1 Q. Who was that? 1 THE W/TNESS: No.
2 A. He was the former houseman of Mr. Epstein. 2 BY MR. KUVIN:
3 MR. PIKE: Form. 3 Q. Narrative 18, it looks like you matte
4 BY MR. KUVIN: 4 telephone contact with another white, looks like WF,
5 Q. Did he give you information that you felt 5 I assume it means white female, on November 8. Do
6 was helpful in the prosecution of Mr. Epstein? 6 you recall which girl that may have been?
7 MR. PIKE: Form. 7 MR. PIKE: Form.
8 THE WITNESS: He described, he described 8 BY MR. KUVIN:
9 washing off the vibrator massagers after the 9 Q. Let me ask it this way: Was this a
10 massage incidents. He recalled having young 10 recounting of the incident with Ms. Jane Doe No.
11. girls coming in to do the massages. 11 103?
12 BY MR. KUVIN: 12 A. No.
13 Q. Did he mention that he, whether he 13 Q. This is a different girl?
14 witnessed that? 14 A. Ibis is a different girl.
15 MR. PIKE: Move to strike witness's last 15 MR. PACE: Form to both questions.
16 statement pending hearsay and form. 16 THE WITNESS: This was a different girl
17 Mr. Kuvin, next question if he has 17 and I am trying to remember who it was.
18 completed it. 18 BY MR. KUVIN:
19 BY MR KUVIN: 19 Q. Do you recall the name M?
20 Q. Did he mention whether or not he had 20 A. Yes.
21 witnessed young girls coming to the house? 21 Q. Is that who this was?
22 MR. PIKE: Same objection. 22 MR. PIKE: Form.
23 THE WITNESS: Yes. 23 THE WITNESS: Yes, it was.
24 BY MR. KUVIN: 24 BY MR. KUVIN:
25 Q. If we look back at the incident report 25 Q. Okay. And apparently she had reported
Page 156 Page 158
1 Page 47 — got it there — it looks like you made 1 sexual intercourse with Mr. Epstein?
2 contact, telephone contact with another girl on 2 A. That is correct.
3 November 7 of 2005, and took another taped 3 MR. PIKE: Form, leading.
4 statement, sworn taped statement. Can you determine 4 BY MR. KUVIN:
by looking at your swnmary there in Narrative 16 of 5 Q. Did she report any sexual contact with
6 November 7,2005, which girl that was? 6 Mr. Epstein?
7 MR. PIKE: Form. 7 A. Yes, she did.
8 THE WITNESS: I believe that was■ 8 Q. What type?
9 MR. KUVIN: 9. MR. PIKE: Form.
10 THE WITNESS: 10 THE WI NESS: She was paid to have vaginal
BY MR. KUVIN: 11 intercourse.
11
12 Q. Do you recall wha.s state of mind or 12 MR. PIKE: Form, move to strike.
13 emotional condition was when she spoke to you about 13 BY MR. KUVIN:
14 this event? 14 Q. Did you determine how old she was when she
15 MR. PIKE: Form. 15 reported having this vaginal intercourse with
16 THE WITNESS: I can't recall. 16 Mr. Epstein?
17 BY MR. KUVIN: 17 MR. PIKE: Form.
18 Q. Let's take a look at Narrative 17. It 18 THE WITNESS: Sixteen years of age.
19 looks like you made contact with someone else, you 19 MR. PIKE: Spencer, can you hold on?
20 along with Detective Dawson made contact with 20 MR. KUVIN: Yes, sir.
21 somebody and left a business card at the front door. 21 MR. PIKE: Letts go off the record for a
22 Do you see that? 22 second.
23 A. Yes. Yes,' do see it. 23 (A discussion was held off the record.)
24 Q. Do you recall which girl that was? 24 MS. EZELL: If I could interject, I was
25 MR. PIKE: Form. 25 fumblin on mute and I wanted to move to strike
•••••••••••••
8 (Pages 155 to 158)
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by cynthla hopkins (601
Electronically signed by cynthia hopkins (601
Electronically signed by cynthia hopkins (601 aa2a6ddb•fa81-4ff6•b3b7-dcda51494142
EFTA00298301
Page 159 Page I(_
1 the witness's comment that she was paid to have 1 MR. PIKE: Form.
2 vaginal intercourse with Mr. Epstein. 2 BY MR. KUVIN:
3 MR. KUVIN: Okay. 3 Q. Does she describe whether or not she had
4 BY MR. KUVIN: 4 gone to Mr. Epstein's home?
5 Q. Do you recall the demeanor ofM when 5 A. Yes.
6 she was recounting this for you? 6 MR. PIKE: Form.
7 MR. PIKE: Form. 7 BY MR. KUVIN:
8 BY MR. KUVIN: 8 Q. Did she describe whether or not she
9 Q. Was she upset, calm? How did she appear brought anyone with her during that time?
10 to you? 10 MR. PIKE: Form.
11 MR. PIKE: Form. 11 THE WITNESS: If I can read —
12 THE WITNESS: She did — I recall her 12 MR. KUVIN: Yes. You can refer back to it
13 being upset, talking to me. Occasionally 13 if you need to.
14 crying. It wasn't like a hysterical cry but MR. PIKE: For the record you're referring
15 she was visibly upset 15 back to Exhibit 1, correct?
16 BY MR. KUVIN: 16 THE WITNESS: Correct. Yes, she did.
17 Q. Okay. Do you recall Ms. Ms date of 17 BY MR. KUVIN:
18 birth? 18 Q. Okay. Now, if we look at Page 16 of 22
19 A. Not off the top of my head. 19 there with respect to Ms.■ it mentions
20 MR. KUVIN: All right. Let me see if I 20 something about a Christmas bonus. Do you see that?
21 can help you here. It looks like we have an 21 A. Yes.
22 unredacted copy of the PC affidavit That will 22 Q Can you explain to us what she told you
23 help. This document will remain sealed 23 about that?
24 pursuant to all previous agreements in the case 24 MR. PIKE: Form.
25 with respect to any documents that we referred 25 THE WITNESS: She received a wire, a
Page 160 Page 162
to. 1 Western Union wire to what she referred to as a
2 THE WITNESS: That's Exhibit 1? 2 Christmas bonus.
3 MIt KUVIN: Bingo. Do you have a copy? 3 Q. Who did it come from?
4 MR. PIKE: Than