EFTA00598945.pdf

IN THE COURT OF THE FIFTEENTH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
B.B.,
CASE NO. 502008CA0373193OOOCMB AB
Plaintiff,
v.


and

Defendants


NOTICE OF TAKING DEPOSITION
DUCES TECUM

PLEASE TAKE NOTICE that the undersigned attorney will take the deposition duces
tecum (See attached Exhibit "A") of:

DEPONENT DATE & TIME LOCATION OF DEPOSITION

Det. Joseph Recarey February 25, 2010 Prose Court Reporting
do Joanne M. O'Conner, Esq. at 9:30 AM One Clearlake Centre
Jones, Foster, Johnson 250 Australian Avenue South
& Stubbs, P.A. West Palm Beach, FL 33401
505 S. Flagler Drive, #1100
West Palm Beach, FL 33401


upon oral examination, before Prose Court Reporting, a Notary Public, or any other officer
authorized by law to take depositions in the State of Florida. The oral examination is being taken for
the purpose of discovery, for use at trial, or for such other purposes as are permitted under the
applicable Statutes of Rules of Court.

Certificate of Service

I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S Mail to the

following addressees on this 3rd day of February, 2010:

Theodore J Leopold, Esq. Jack Alan Goldberger, Esq.
Spencer T. Kuvin, Esq. Atterbury Goldberger & Weiss, P.A.
Leopold-Kuvin, P.A. 250 Australian Avenue South
2925 PGA Blvd., Suite 200 Suite 1400




EFTA00598945
B.B v. Epstein, et al
Page 2

Palm Beach Gardens, FL 33410 West Palm Beach, FL 33401-5012
Fax: 561 697 2383 Fax: 561-835-8691
Counsel for Plaintiff Co-Counsel for Defendant Jeffrey Epstein

BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
515 N. Flagler Drive, Suite 400
Wet a ch, FL 33401

(561)515-3148 Fax



Robe . Critton, Jr.
Florida Bar #224162
Mi mel I Pike
Florida Bar #617296
(Colonel for Defendant Jeffrey Epstein)




EFTA00598946
 EXHIBIT "A"
red by you or any
1 Any and all written reports, notes, memoranda or other papers autho
in hard-copy or electronic form,
other member of the Palm Beach Police Department, whether
in including but not limited to
that relate to any law enforcement investigation of Jeffrey Epste
es against Mr. Epstein This
the investigation that resulted in the filing of State criminal charg
members of the Palm Beach
request includes any written communications between you and any
t Agency, any member of the
Police Department, any member of any Federal Law Enforcemen
the State Attorney, any
Unites States Attorney's Office, any member of the Office of
sses and/or any lawyers or
representatives of the media, any civil parties, any civilian witne
representatives of any parents of any civilian witnesses.
of the following
2. Any and all electronic communications (EMAIL) between yo any
in including but not limited to the
relating to any law enforcement investigation of Jeffrey Epste
s against him: (A) any member of
investigation that resulted in the filing of State criminal charge
Federal Law Enforcement Agency,
the Palm Beach Police Department, (13) any member of any
member of the Office of the
(C) any member of the Untied States Attorney's Office, (D) any
radio media outlet, (F) any attorney
State Attorney (E) any member of any print, television, or
or may potentially file a civil
representing any civilian witness or civil party who has filed
complaint against Mr Epstein.
any communications between you
3 Any and all notes, memoranda or reports reflecting
d to any request for exculpatory
and counsel on behalf of Mr. Epstein, including but not limite
evidence.
attempts by you to initiate or
4. Any and all notes, memoranda or reports reflecting any
igation or State prosecution
encourage a federal review of any facet/aspect of the Epstein invest
of Epstein
laints made to the Palm
5 Any and all notes, memoranda or reports reflecting any comp
for any person or parent claiming to
Beach Police Department from any person, parent, or lawyer
other private citizen of Palm
have been a victim of any conduct of Mr Epstein or from any
y 1, 2000 — October 22, 2009.
Beach County relating to any conduct of Epstein from Januar
ion between you or
6. Any and all notes, memoranda, or reports reflecting any communicat
with "A H." in relation to her
and any other member of the Palm Beach Police Department Grand Jury,
before a State
being subpoenaed to testify before or her requested attendance
would testify to and/or any
including but not limited to any discussions regarding what she
with prior to any testimony.
preparation that any law enforcement officer provided her
communication between you or
7. Any and all notes, memoranda, or reports reflecting any
"A H."* or referencing "A.H "* in
any other member of the Palm Beach Police Department with
requested attendance before a State
relation to her being subpoenaed to testify before or her
l sought to discourage her or
Grand Jury where you or any Palm Beach police officer or officia
any Grand Jury proceeding
influence her not to testify or to testify in a certain manner at
involving Mr. Epstein.




EFTA00598947
 electronic or otherwise,
8. Any and all agreements, memoranda, and/or notes of any kind,
Department, any member of the Office
between you and any member of the Palm Beach Police
Attorney's Office relating to any
of the State Attorney, and/or any member of the United States
any time.
criminal charges, formal or otherwise, regarding "A II " at
communications between you
9. Any and all notes, memoranda, or reports of meetings or
"•
and "S.G "*, her parents, or any lawyers who represent "S.G_
you, and all requests for
10. Any and all records of expenditures made or incurred by
Epstein.
expenditures relating to the criminal investigation of Mr.
s, memoranda or notes, and
11. Any and all logs, pictures, videos, digital information, report
of and/or maintenance of any video
any record of expenditure, which relate to the institution
during the following time periods:
surveillance of Mr. Epstein, his residence, or his visitors
a January 1, 2004-December 31, 2004
b. January 1, 2005-December 31, 2005
c January 1, 2006-December 31, 2006
d. January 1, 2007-December 31, 2007
e. January 1, 2008-December 31, 2008
f. January 1, 2009-today's date.
expenditures or any other
12. Any and all reports, logs, pictures, videos, notes, records of
in, his residence, his visitors, or
memoranda relating to any physical surveillance of Mr. Epste
or co-conspirator other than the
any individual who was believed to be a potential witnesses
request number 11
information relating to video surveillance that is requested in
notes, and reports of any
13. Any and all reports (including forensic reports), memoranda,
nce in October 2005 or on any
examination of any computer seized fiom Mr. Epstein's reside
other occasion.
or burglary
14. Any and all reports, memoranda, or notes reflecting a criminal theft
prior to October 2005.
investigation of Mr. Epstein or his residence on any occasion
cell phone, used by you
15. All cell phone records, both official cell phone and personal
between during the following time periods:
a. January 1, 2004-December 31, 2004
b. January 1, 2005-December 31, 2005
c. January 1, 2006-December 31, 2006
d. January I, 2007-December 31, 2007
e January 1, 2008-December 31, 2008
f. January 1, 2009-today's date.
periods between October 1,
16.. All calendars or diaries, electronic or hard-copy, kept for the
activities, meeting, etc.
2004 up through and including today, reflecting your schedules,




EFTA00598948
17. Any and all reports, memoranda, and notes of any communication between Los and any
member of the Office of the State Attorney relating to the criminal investigation and subsequent
prosecution of Mr. Epstein from October 1, 2004 up through and including today.

18. All policies and procedures of the Palm Beach Police Department setting forth the
procedures for police officers, including the Chief, any detective and officers when commenting
to any media outlets, including but not liming to the local news, the national media, print outlets,
and any web-based media format.

19. All personal notes contained either on your personal computer, work computer, and those
that are handwritten containing any witnesses that you, or any other member of the Palm Beach
Police Department interviewed or attempted to interview with regard to the Epstein investigation
from January 1, 2004, up thorough and including today.

20. Any and all audio tapes of any witnesses that You or any member of the Palm Beach
Police Department obtained statements or interviews from, either sworn or informal, with regard
to the Epstein investigation

21. Any and all audio tapes, notes (hand-written or typed), memoranda, reports, messages,
and/or any communications obtained or generated by you or any member of the Palm Beach
Police Department, either sworn or informal, that relate to Jane Doe #4**, who is the Plaintiff in
a Federal Civil Case No. 08-80380 filed against Jeffrey Epstein.



* The initials Ail. and S.R. refer to the individuals identified in the Palm Beach County
Probable Cause Affidavit ns it relates to the Jeffrey Epstein investigation. Should ou
re uire the complete name of the individuals, please contact Jessica Cadwell at


** Should you need the full identity of Jane Doe #4, please contact Jessica Cadwell at ■




EFTA00598949