EFTA00298214.pdf

Page 320 Page 322 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 1 APPEARANCES: INAND FORPALMBEACHCOUNTY,FLORIDA 2 On behalf°flaw Dora 1 through 8: 3 JESSICA ARBOURESQUIRE 2 CASE No.50200SCA0373193000CMB AB utatmusitirt & P.A. 3 1820513ismne Boulevard B.B. Susie 2218 4 Miami, Plaintiff Phone S 1, 7 Oa behalf of the Plaintiff, Jame Doe No. IL 6 ws- VOLUME al OF IV 8 ISIDRO MAKIJEI.GARCIA, ESQUIRE GARCIA, MAINS& BOO-RINGER 9 224 Dan Awnuo Suite 90) West tilde 33401 Dcfaxlinta. 10 Phan( 9 11 ind 10 12 TARA A. MORGAN. ESQUIRE. TARA A. P124141GAN. PA 11 13 224 Datum SEM 12 DEPOSITION OF SAW 900 DETECTIVE JOSEPH RECAREY 14 West ids 33401 13 Plan. 14 Tuesday, April 27, 2010 Is 16 Oo bd./gelthe De /W. Setiney Epsiesn: 15 1003 - 5:23 p.m. 17 MEIIAN PIKE. 18QUIRE 16 505 South Hagler Drive BURMAN, CRUTCH, Lunrout COLEMAN, LIP Suite 1100 14 303 Rearm nadorsrel 17 West Palm Beach, Florida 33401 Sage 400 18 19 West Pligarida 33401 19 Phone 20 20 and 21 21 22 Reported By: mTI:PON 0. WITINRF.R.G. mot BRE Jena Riociuti, RPR, PPR, CLR 22 LAW OFFICE OF MILTON G. WEINBERG 23 Notary Public. Siam of Florida 20 Park Plant 23 Suite 1008. Prose CourtReporting 02116 Bea Mir 24 Job No.: 1509 24 Thaw 25 25 Page 321 Page 323 1 1 Appearances continued... 2 UNITED STATES DISTRICT COURT 2 On behalfof the Witness: SOUTHERNDISTRICT OP FLORIDA 3 3 JOANNE M. O'CONNOR, ESQUIRE CASENO. 10-80309 JONES, FOSTER, JOHNSON & STUBBS, P.A. 4 505 South Flagler Drive, Suite 1100 5 JANE DOENO. 103. West Pa rida 33401 Pkbdiff; Phone: 7 VOLUMEDI OFIV JEFFREY EPSTEIN, 9 Degltlallt 7 Also Present: Jeffrey Epstein 8 10 9 11 10 12 DEPOSITION OP 11 DETECTIVE JOSEPH RECAREY 12 13 13 14 Tuesday, April 27,2010 15 10:03 - 5:23 p.m. 14 16 505 South Hagler Drive 15 Suite 1100 16 17 West Palm Beach, Florida 33401 17 18 18 19 20. 19 ,21 20 22 Reported By. 21 Jeana Rkciuti, RPR, IFPR, CLR 22 23 Notary Public, State of Florida 23 Prose Court Reporting 24 24 25 25 2 (Pages 320 to 323) • PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricclutl Electronically signed by Jeana Ricciutl (4082837-abal-482e4836-be014441447a EFTA00298214  Page 324 Page 326 1 PROCEEDINGS 1 Q. And you would type the report into a computer? 2 2 A. Yes. 3 Deposition taken before Jeana Ricciuti, Registered 3 Q. And that would be essentially signed by you, 4 Professional Reporter and Notary Public in and for the 4 that would be your personal summary of the interview 5 State ofI•lorida at Large, in the above cause. 5 that you were conducting with one of the many people 6 6 that gave you information about Mr. Epstein? 7 Thereupon, A. Correct. 8 (JOSEPH RECAREY) 8 Q. And it was always your practice in this case 9 having been fast duly sworn or affirmed, was examined 9 to then destroy the notes that you used as a basis for 10 and testified as follows: 10 that typed summary; is that correct? 11 THE WITNESS: I do. A. Correct. 12 CROSS (JOSEPH RECAREY) 12 Q. And on other cases, is it always your practice 13 BY MR. WEINBERG: 13 to destroy the notes that you would take during the 14 Q. Good morning, Detective. 14 interviews? 15 A. Good morning. 15 A. Correct. 16 Q. You've been a detective for the Palm Beach 16 Q. So you have no notes of any case that you've 17 Police Department for how long? 17 ever memorialized into a computer or a typed summary; is 18 A. Approximately, 15 years. 18 that correct? 19 Q. Some ofit is as a detective and some of it in 19 A. That is correct. 20 another capacity, or always as a detective? 20 Q. And is that a practice that you've discussed 21 A. I've been with the Town for 19 yews, but I 21 with other detectives in the Palm Beach Police 22 did time on the road and then moved up to the detective 22 Department? 23 bureau. 23 A. Ifs just a practice that I've done all along. 24 Q. And do they have a written practice in teams 24 Q. And what is the purpose of your destroying the 25 of whether or not you're required to preserve rough 25 rough notes? Page 325 Page 327 1 notes or interview notes of different witnesses? 1 A. There's no need to keep them once you've 2 A. No policies, no practice. 2 transcribed than into your supplemental. 3 Q. Do you have personal practice as to whether or 3 Q. And again, the transcription into the 4 not you would retain rough notes that you are 4' supplemental is done X number of days after the 5 contemporaneously taking of interviews with the 5. interview? 6 witnesses? 6 A. If not the same day. 7 A. I take my notes, transcribe them into my 7 Q. Sometimes a week after, sometimes the same 8 supplements and then shred them. 8 day? 9 Q. So that you have no rough notes or no 9 A. I wouldn't say a week after. I would say 10 handwritten notes — 10 either the same day or the day after. 11 A. Correct. 11 Q. So within 24 hours, you would have a typed 12 Q. ofany of the many interviews you took 12 summary of the interview, is that correct? 13 during your investigation of Jeffrey Epstein? 13 A. Approximately. 14 A. Correct. 14 Q. And would you just type your rough notes or 15 Q. It was your practice to take notes while you 15 would you summarize from your rough notes when you 16 were interviewing people? 16 • engaged in the process of — 17 A. On occasion,1did, yes. 17 A. Summarize. 18 Q. Would you take notes even if you were tape 18. Q. — your report? 19 recording the people with whom you were conducting an 19 So the notes would have more than a summary? 20 interview? 20 A. Obviously, if it was taped, everything would 21 A. On occasion. 21 be on the tape recorder. As fir as my note-taking 22 Q. And at some point thereafter, you would use 22 concerns, I would jot down things that sparked my 23 those notes as a basis of writing a report; is that 23 curiosity or things I wanted to go back and reinterview 24 correct? 24 the person - and go back and reinterview the person. 25 A. Correct. 25 Q. So the summary that you typed into a computer 3 (Pages 324 to 327) PROSE COURT REPORTING. AGENCY, INC. Electronically signed by Jeana Ricciuti (601 Electronically signed by Jeana Ricciuti (601 c6062637-abel-452c-a836-bc614e314d7a EFTA00298215  Page 328 Page 330 1 would be, in part, your notes, part in memory of 1 surveillances of Mr. Epstein's residence as El Brillo on 2 different statements made to you based on the jottings 2 Palm Beach, correct? 3 in your notes? 3 A. Correct 4 A. I would basically go over what the interview 4 Q. And who made that assignment, if you know? 5 transcribed, you know, into my supplement. S A. I can't recalL That was back when 6 Q. But the basis of the supplemental, and I don't 6 Officer Pagan had the case. But they were also 7 mean to torture the subject, but the basis of the 7 utilizing it for various functions. They were primarily 8 supplement would be, in part, your memory, correct? 8 the surveillance units used. 9 A. Correct 9 Q. And did they surveille residences to try to 10 Q. And then, in part, what your notes refreshed 10 stop burglaries as well as stuveilling Mr. Epstein, 11 your memory into recalling from the interview that was 11 right? 12 conducted either at that time, the same day or the day 12 A. And other fractions as well. 13 before? 13 Q. Sure. And in 2005, there was not any kind of 14 A. Correct 14 burglary investigation dealing with his residence; is 15 Q. Did you listen to the tape before you wrote a 15 that correct? 16 supplemental report into a computer? 16 A. Correct. 17 A. Are you saying every time or arc you just 17 Q. So to the extent the Burglary Task Force was 18 saying — 18 involved in investigating Mr. Epstein prior to your 19 Q. Asa regular practice, would you, at the time 19 first involvement in September, it was simply an 20 that you typed in your supplemental report into a 20 assignment made of them to assist Officer Pagan, 21 computer, have the tape recording going? 21 correct? 22 A. See, I have done that on other cases, 22 A. Correct. 23 especially lengthy interviews, interviews that last 23 Q. And if you know, did the Burglary Task Force 24 several hours. 24 use video surveillance in investigating Mr. Epstein? 25 Q. But it's not a standard practice, it's 25 A. I know that there were some videos taken, but Page 329 Page 331 1 something you would do on an occasional basis; is that 1 I don't believe from the video — from the Burglary 2 correct? 2 Strike Force. 3 A. Correct 3 Q. Was there videos taken by others in the Palm 4 Q. Now, let me ask you in particular, on your 4 BeachPolice Department ofMr. Epstein's residence? 5 incident report, in essence, is a combination of all the 5 A. There was. There were several tapes. Yes, 6 different supplemental reports that you typed; is that 6 there was. 7 correct? 7 Q. Did you ever direct video surveillance of 8 A. I typed, and other officers as well. 8 Mr. Epstein's residence? 9 Q. Because you came to this investigation at 9 A. What do you mean "direct"? 10 least six months after it began; is that right? 10 Q. In other words, was there any video 11 A. Approximately, yes. 11 surveillance ofMr. Epstein's residence on or after the 12 Q. Again, March of 2005? 12 time that you became the ease agent in the 2005 13 A. Yes. 13 investigation? 14 Q. And it began with Officer Michele Pagan being 14 A. I can't recall. If I did, it would be in the 15 the case agent, if I could call her that? 15 incident report. 16 A. Correct. 16 • Q. But you know that there was such video 17 Q. And it began with surveillances that were 17 surveillance of Mr. Epstein's residence before you 18 conducted by the Burglary Task Force? 18 became the case agent in charge of the investigation? 19 A. Correct 19 ' A. I can't recall if it was before I took over 20 Q. And the Burglary Task Force was a component of 20 the case or after I took over the case. I know that 21 the Palm Beach Police Department designed to try to 21 there was tapes, but i don't know the exact time frame. 22 prevent citizens from being the victims of burglaries; 22 Q. Let me ask you and — let me ask Mr. Pike for 23 . is that correct? 23 one second. 24 A. Correct. 24 MR. WEINBERG: Do we need to use the real 25 Q. And yet, they were assigned the task of doing 25 names? 4 (Pages 328 to 331) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RIcciuti (801 Electronically signed by Jeana Ricciuti (801 c6062637-abol-462c-a836-bc614.314d7a EFTA00298216  Page 332 Page 334 1 MR. PIKE: Yes, pursuant to the agreement that 1 yoinself? 2 was entered last time, the real names can be used. 2 A. NO, sir. 3 MR. WEINBERG: Chuck is not going to be in 3 Q. Did you ever discuss with anyone the fact that 4 agreement, but i can use the real names, and then 4 there was such a victim list that had been generated out 5 they will be convened in the transcript to the 5 of the United States Attorneys Office? 6 applicable abbreviations. 6 A. There was a list, I believe, that was given to 7 BY MR. WEINBERG: 7 chief — former ChiefReiter. I never got to actually 8 Q. Jane Doe, do you know that name? 8 physically hold it and look at it i mean, it was one 9 A. Not that I recall. 9 of those things where he showed me the list, but I never 10 Q. So that it's fair that as you sit here today, 10 got a chance to... 11 in 2010, you have no recollection ofever interviewing a 11 Q. Did the Chief represent to you that that list 1.2 woman, a young woman at the time named Jane Doe? 12 originated with the United States Attorneys Office? 13 A. i don't recall, no. 13 A. I believe so. 14 15 Q. n, interviewingM.? d:r eciu have any recollection ofever 14 15 Q. Did he explain that he had received it from them? 16 A. I went to her home. 16 A. I believe so. 17 Q. And what do you recall of going to her home? 17 Q. And did he explain ho received it from them 18 A. She did not ward to speak to me. 18 with the directive that it should be reviewed and then 19 Q. And did she tell you why she didn't want to 19 destroyed? 20 speak to you? 20 A. I recall the destroying part I'm sure he 21 A. She was in love with Mr. Epstein and she was 21 reviewed it 22 not going to speak to me. 22 Q. What do you recall of the destroying part? 23 Q. And how did you come to go to her home? Do 23 A. I remember him telling me that he was given 24 you wall, you lawny, what led you to M.? 24 the copy but it must be destroyed immediately 25 A. Her name came up in the investigation either 25 thereafter. Page 333 Page 335 1 by interviews or — I believe it was interviews. 1 Q. And did he tell you who directed him to 2 Q. And do you recall who was interviewed, who 2 destroy it? 3 would have given you for the first time the name of 3 A. No. 4 M.? 4 Q. Did he tell you whether or not that directive 5 A. There were so many interviews then. I would 5 was in writing or verbal? 6 have documented it in the incident of who supplied what 6 A. No. 7 name. 7 Q. Have you ever seen — other than seeing him in 8 Q. So independent of what's documented in an 8 the physical possession of the list, have you ever seen 9 incident report that was largely authored, what's now 9 it again? 10 five years ago, you have no otrecollection of who 10 A. No. 11 would have first toM you about ? 11 Q. Do you have any reason to believe that he 12 A. Lilco I said, it would be documented in the 12 didn't destroy it? 13 incident report You know, we're talking five years 13 A. No. If he says he was going to destroy it, he 14 ago. You know, tons of interviews. 14 would destroy it. 15 Q. And with Jane Doe, similarly, do you you 15 Q. And do you recall when that was in terms of 16 don't remember interviewing her. Do you remember 16 the evolution of the State case? 17 interviewing anybody else about Jane Doe? 17 A. It would have been around December or January 18 A. Jane Doe does not ring a bell. 18 time Same of like '06, 107. 19 Q. Did you ever see her name on any report? 19 Q. So either the end of '06, beginning of '07? 20 A. No, I don't remember. 20 A. I believe so. 21 Q. Did you ever see her name on any list of 21 Q. Or at the time period that would be after the 22 different complainants, victims, witnesses? 22 State grand jury met and returned charges against 23 A. No. 23 Mr. Epstein? 24 Q. Did you eva sec a list of victims or 24 A. It would have been, yes, much after. 25 witnesses that was prepared by someone other than 25 Q. Would it have bear before there was 5 (Pages 332 to 335) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana FtIcclutl (601 Electronically signed by Jeana Moduli (601 c6062637-abel-452c-a836-bc6144/314d7a EFTA00298217  Page 336 Page 338 1 sum-ceding information that brought in the charges? 1 Q. And you certainly don't recall him ever saying 2 A. It would have been — again, I'm going off of 2. that on any other occasion that he had been directed by recollection here. 3 any Federal or State prosecutor - 4 Q. And again, I understand this is four years ago 4. A. Not with me, no. 5 and we're just trying to get your best unrefreshed 5 Q. — to destroy a document? recollection. 6 A. Not with me. 7 A I'm trying to think back. It would have 7 Q. And just so we're clear, this docwnent was 8 been — it would have been — see, I would be guessing. 8 being destroyed, not in the regular course of business, 9 Q. We don't want you to guess. 9 but as a result of the directive from the Federal 10 A That's the thing, I would be guessing. 10 prosecutor, correct, according to — 11 Q. Did the Chief ask you to come to his office? 11 A. I would assume so, yeah. 12 A Yes, he did ask me. He said the — the list 12 Q. And there was no other copy that you knew of 13 was not going to leave his office, most assured, and 13 this document? 14 I — at that point, I was like, you know, don't even 14 A. No. 15 show me. Liman, it was for your eyes only, that's 15 Q. And you have never seen one thereafter? 16 fine. 16 A. N sir. 17 Q. And did he explain to you why he was directed 17 Q. you went to ha house; is that correct? M. , 18 to destroy the list? 18 A. Correct 19 A. No. 19 Q. Did you speak to either ofher parents? 20 Q. Has the Chief ever before invited you to his 20 A. No, I did not. 21 office to discuss a document that he thereafter told you 21 Q. Was she 18 at the time you went to her house? 22 he was directed to destroy? 22 A. I believe so. 23 A. I mean, I've been many times at the Chiefs 23 Q. Was your practice that when somebody was over 24 office — 24 18, you would feel Otte it was appropriate to interview 25 Q. Sure. 25 them directly, but if somebody was under It, you would Page 337 Page 339 1 A. — but not — leant recall if there was ever 1 try to give some parental notification? 2 a time that he showed me a document that he must 2 A. Correct. 3 destroy. 3 Q. And your best recollection with is she 4 Q. And have you ever been, yourself, directed by 4 was over 18 and, therefore, you went directly to her? 5 either a State attorney or a US attorney to destroy your 5 A. Correct 6 document? 6 Q. What would you have told her when you rang on 7 A. No. 7 her doorbell and she answered the door? 8 Q. And has the Chief ever told you, on any other 8 A. I would have identified who I am, my purpose 9 occasion that you currently recall, that he was directed 9 for being there. 10 by a Federal or State prosecutor to destroy a document? 10 Q. And what would you have said your purpose for 11• A. I don't know. 11. . being there was? 12 Q. And other than destroying documents in the. 12 A. I was conducting an investigation. 13 regular course of business, you don't recall the Chief 13 Q. And wonld.you tell her of who? 14 ever before or ever after saying he had been directed by 14 A. Yes. 15 any third party to destroy a document that was relevant 3.5 Q. And would you tell her the subject matter of 16 to the investigation, correct? 16 the investigation? 17 A. Fro sorry, can you ask the question again? 17 A. Yes, absolutely. 18 Q. Oh, sure. Fm sorry. Other than this 18 Q. And her answer was that she did not wish to 19 occasion when the Chiefinvited you to his office and 19 cooperate with you? 20 specifically said that he was in possession of a 20 A. I never got to the point to explain to her my 21 document, relevant to the Epstein investigation that he 21' purpose of being there. Obviously, she knew why I was 22 had been directed to destroy, do you recall any other 22 .- . there. Once I identified myself, l told her I was a . • 23 occasion where the Chief told you that he was destroying 23 police officer from Palm Beach and I was here to speak 24 a document relevant to an investigation? 24- to her in regards to Jeffrey Epstein. At that point, 25- A. No. 25. • . she stopped me and said, I have nothing to say about 6 (Pages 336 to 339) PROSE COURT REPORTING AGENCY,..INC. Electronically signed by Jeana Fticciuti (601 Electronically signed by Jeana Ricciuti (601 c5062637-abol-452c-a836-bc6140140a EFTA00298218  Page 34C Page 342 1 him, nothing negative to say about him. She is in love 1 Q. Do you recall who that was? 2 with the man, and... 2. • A. Yes, I do. 3 Q. So that was literally a 30-second 3 Q. Who was that? 4 conversation? 4 A. 5. A. Pretty much. Pretty much. 5 Q. And tell me what you remember of that 6 Q. Were you with anyone? 6 attempted interview. 7 A. Yes, I was. 7 A. I went up to interview her with Detective •8 Q. Who were you with? 8 Caristo, at her boyfriend's place of employment was 9 A. I want to say either Sergeant Dawson, who was 9 where she was at. And she didn't wish to speak to me at 10 a detective at the time. 10 that point. 11 Q. Did you follow that tip at all by attempting to 11 Q. And did she tell you why? 1.2 reinterview her on any other occasion? 12 - A. If l can refer to it. 13 A. No. 13 Q. Sure, go ahead. 14 Q. So your sum total experience with was 14 A. She said that she knew there was an 15 essentially a 30-second conversation at her house where 15 investigation and that 1had spoken to other people and, 16 she declined your invitation to disciKS Jeffrey Epstein 16 therefore, I should know what had happened at 17 with her? 17 Mr. Epstein's house. 18 A. Correct. 18 Q. And did she make any other further explanation 19 Q. Okay. And you do recall her saying, "fin in 19 for her declining your request for an interview? 20 love with him*? 20 A. No. 21 A. Yes. 21 Q. Did she tell you that she, likeM., had 22 Q. And you're assuming but don't know that she 22 positive regard for Mr. Epstein? 23 • had been essentially tipped off that this investigation 23 A. I don't recall any positive regard. 24 was ongoing; is that correct? 24 ti.3icylou take notes ofyour conversation with 25 A. Pretty much. I mean, she didn't know why I — 25 Ms. Page 341 Page 343 1 allegedly why 1was there, but yet she... 1 A. No. 2 Q. Well, you told her why you were there, and she 2 O fild you take notes of your conversation with 3 then said, I'm in love with Jeffrey Epstein and have 3 Ms. M.? 4 nothing negative to say about him? 4 A. No. A. Correct. 5 Q. Did you write any supplemental report 6 7 Q. And so am I correct that she didn't say that she knew why you were there, that you're assuming that, 6 7 regarding your interview attempts with Ms. A. I believe I did. • 5? 8 because of the timing of that interview, that she had 8 Q. And likewise, you have before you a 9 discussed the investigation with others? 9 supplemental 1.1 that reflects your attempts to 10 A. It's possible. 10 interview Ms. 11 Q. You don't recall anybody telling you — 11 A. Yes. 12 . A. No. 12. Q. Did you ever attempt to interview a woman 13 Q. — at this time, that they had talked toM. 13 nulleda? 14 about your investigation? 14 A. Yes, I did? 15 A. No. 15 Q. What do you recall of that interview? 16 Q. Was there more than one such person, meaning 16 A. She was a masseuse. I remember going to her 17 did anybody else that you attempted to interview about . 17 home and interviewing her at her home. And If I recall 18. Jeffrey Epstein decline to be interviewed, to your 18 correctly, she stated that what happened betwom her and 19 current recollection? 19 Mr. Epstein were between consenting adults, that she was 20 A. No. I believe she's the only one. 20 over 18 at that time. 21 Q. Can I ask you to look at page 81, paragraph 1 21 Q. And did you write a report on that inns-view 22 ofyour incident report, and ask whether or not that • . 22 attempt? • 23 refreshes your recollection about the events of • . 23 A. I believe so. 24 February 15, 2006. 24. Q. And in fact, you interviewed a writs of women 25 A. Yes. 25 - who were over 18 years old,not only at the time of the 7 (Pages 390 to 343) PROSE COURT 'REPORTING. AGENCY, ,INC. . . • (- Electronically signed by Jeana Ricclutl (601 Electronically signed by Jeana Ricciu0 (601 a062637-abel-452c-a836-13c614e314d7a EFTA00298219  Page 344 Page 346 1 interview, but also at the time of the events between THE WITNESS: Right. Some girls wart under n 2 them and Mr. Epstein, correct? 2 different ruse. They thought they were going to 3 A. Correct. 3 either model or get a chance to be in Victoria Q. And you would incorporate those interviews 4 Secrets or that kind of thing, but... within the overall 87-page incident report is that 5 BY MR. WEINBERG: correct? 6 Q. That was the exception to the rule. A Correct A. Nobody was bound and gagged to go to the 8 Q. So that the focus of this broad investigation 8 house. 9 was not restricted to women under 18 and also included 9 Q. And those that told you that they thought they 10 women who were over IS; is that correct? 10 were going there for some other purpose were the 11 A. Correct 11 exception to the rule that was disclosure by whoever 12 Q. Now, some of the girls that you interviewed, I 12 invited them, correct? 13 don't mean to be disrespectful, but some of the minors 13 MS. ARBOUR: Object to the fonn. 14' you interviewed were emotional at the time of your 14 THE WITNESS: Some girls, again, told me that 15 interview, is that correct? 15 they were going there to give massages, and some 16 A. Correct 16 girls went there for other reasons. 17 Q. And if they were under 18 at the time of their 17 BY MR. WEINBERG: 18 interview, it WAS your practice to precede that 18 Q. Well, let's take one of them who claimed to 19 • interview with some notification to their parents; is 19 have gone there for another reason. Do recall 20 that correct? 20 interviewing n young woman namedM.? 21 A. Correct 21 A. Yes. 22 Q. And what would that notification be? In other 22 Q. And when did you interview her? Would the 23 words, what would you tell the mother or father of a 23 date of January 9, 2006 be consistent with your memory 24 minor? 24 as to when you interviewed 25 A. That their daughter was a possible victim 25 A. It would have been, yeah, about that time. 1 Page 345 Page 347 1 and/or witness in a police investigation involving a 1 know 1attempted it once before and she was emotional gentleman that lives in the Town of Palm Beach. 2 and, plus, I needed to get her father's consent because 3 Q. And had you, at the time ofsay by October of 3 she was still underage. 4 2005, within 30 days of your commencing of your 4 Q. When you went to visit with her father, her responsibilities in this investigation, concluded that, S father talked to you, did he not? as to these minors, that they would not be prosecuted; 6 A. Either 1telephoned him or spoke to him 7 that they were either victims or witnesses but not 7 directly. I believe I might have tel oned him. 8 targets? 8 Q. And the father told you that M. had told him 9 A. Rephrase your question one more time, Tm 9 that she had been hired to model lingerie; is that 10 sorry. 10 correct? 11 Q. Sure. Let me give you a predicate. Many, if 11 A. 1believe so. Pm not 100 percent certain on 12 not all, of the people you interviewed were paid sums of 12 that one. I know I recall the modeling part. I don't 13 money to give Mr. Epstein a massage at the bottom level, 13 know if it was exactly lingerie or... 14 correct? 14 Q. Okay. The father had communicated to you that 15 A. Correct 15 his daughter had told him that her connection to Jeffrey 16 Q. And that they went to his house, correct? 16 Epstein was that she went to see him as a model? -17 A. Yes. 17 A. Yes. 18 Q. And that they went to his house voluntarily; 18 Q. In other words, what you took from talking to 19 is that era met? 19 the father is that M. had likely lied to him regarding 20 MS. ARBOUR Object to the form. 20 her experiences with Mr. Epstein, correct? 21 311E WITNESS: Yes. 21 A. I wouldn't say "lied to him," because that's 22 BY MR. WEINBERG: 22 what she claimed to me, that that was the purpose ofher 23 Q. In other words, they weren't kidnapped or . 23 going to the house. 24 coerced into going to his house. 24 Q. But the father said that that's what she said 25. MS. ARBOUR: Object to the form. 25 was the relationship between him [sic] and Mr. Epstein, 8 (Pages 344 to 347) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RIccluti (601 Electronically signed by Jeana Ricciuti (601 c6062637-abo1-452c-a836-bc6141,314d7a EFTA00298220  Page 348 Page 350 1 that she went there as a model. 1 came tome and said that something bad happened to her 2 A I recall that that's what the father knew of 2 in relation to Jeffrey Epstein. 3 her going over there. 3 A. No. 4 Q. Sure. And this isn't the first parent that 4 Q. And no teacher ever came to you and said, my 5 you interviewed that didn't know what his daughter would God, I have a student who is saying that something bad 6 later claim occurred to you; is that right? 6 or improper happened in relation to her and Jeffrey 7 A. What do you mem? 7 Epstein, correct? 8 Q. In other words, many of the parents that you 8 A. Correct. 9 sought permission to interview their daughters did not 9 Q. And no religious figure ever came to you and 10 know the details of what had transpired between their 10 asked you to investigate Mr. Epstein as a result of some 11 daughters and Mr. Epstein, correct? 11 confessional or some complaint that he received from 12 A. Correct. 12 either a minor or from a parent of a minor? 13 Q. And in fact, no parent called you up 13 A. Correct. 14 uninvited, uninitiated and said, I want to complain 14 Q. And from that, you concluded that — strike 15 about something that's happening in Palm Beach regarding 15 that. 16 Mr. Epstein? 16 No doctor ever came to you and said that they 17 A. That's how the case first became originated, 17 had a patient that had been harmed by Jeffrey Epstein 18 but not me directly. 18 during the time period of your 2005/'6 investigation, 19 Q. Not you. 19 correct? 20 A. Not me directly. 20 A. Correct. 21 Q. So of all of the witnesses that you 21 Q. No psychiatrist or social worker or mental 22 interviewed, there wasn't a single parent that came to 22 health professional ever came to you and said, I have a 23 you as contrasted to you going to them? 23 patient or client that claims to have been banned by 24 A. No, not tome. I know that 24 Mr. Epstein? 25 Q. I understand and — 25 A. Correct Page 349 Page 351 1 A. -- Officer Pagan — 1 Q. And no minor ever came herself to the Palm 2 Q. -- we'll get there. Because you never 2 Beach Policy Department and claimed to have been alnico(' 3 yourself