EFTA00298214

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Page 320 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE No.50200SCA0373193000CMB AB 
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Page 322 
APPEARANCES: 
On behalf °flaw Dora 1 through 8: 
JESSICA ARBOURESQUIRE 
utatmusitirt & 
P.A. 
1820513ismne Boulevard 
B.B. 
Susie 2218 
4 
Plaintiff 
Miami, 
Phone 
S 
1,
6 
ws- 
VOLUME al OF IV 
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8 
Oa behalf of the Plaintiff, Jame Doe No. IL 
ISIDRO MAKIJEI. GARCIA, ESQUIRE 
GARCIA, MAINS& BOO-RINGER 
9 
224 Dan Awnuo Suite 90) 
West 
33401 
Dcfaxlinta. 
10 
tilde 
Phan( 
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ind 
10 
12 
TARA A. MORGAN. ESQUIRE. 
TARA A. P124141GAN. PA 
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13 
224 Datum SEM 
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DEPOSITION OF 
SAW 900 
DETECTIVE JOSEPH RECAREY 
14 
West 
ids 33401 
13 
Plan. 
14 
15 
Tuesday, April 27, 2010 
1003 - 5:23 p.m. 
Is 
16 
17 
Oo bd./gelthe De 
/W. Setiney Epsiesn: 
MEI IAN 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 
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West Pligarida 
33401 
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Phone 
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and 
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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 
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Prose Court Reporting 
Job No.: 1509 
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Suite 1008. 
Bea Mir 
02116 
Thaw 
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Page 321 
Page 323 
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1 
Appearances continued... 
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UNITED STATES DISTRICT COURT 
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On behalf of the Witness: 
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SOUTHERN DISTRICT OP FLORIDA 
3 
JOANNE M. O'CONNOR, ESQUIRE 
CASE NO. 10-80309 
JONES, FOSTER, JOHNSON & STUBBS, P.A. 
4 
505 South Flagler Drive, Suite 1100 
5 
JANE DOE NO. 103. 
West Pa
rida 33401 
Pkbdiff; 
Phone: 
7 
VOLUME DI OFIV 
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JEFFREY EPSTEIN, 
Degltlallt 
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Also Present: Jeffrey Epstein 
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10 
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DEPOSITION OP 
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DETECTIVE JOSEPH RECAREY 
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Tuesday, April 27,2010 
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10:03 - 5:23 p.m. 
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505 South Hagler Drive 
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Suite 1100 
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West Palm Beach, Florida 33401 
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20. 
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,21 
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Reported By. 
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Jeana Rkciuti, RPR, IFPR, CLR 
22 
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Notary Public, State of Florida 
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Prose Court Reporting 
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2 (Pages 320 to 323) 
• PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Jeana Ricclutl 
Electronically signed by Jeana Ricci utl 
(4082837-a bal-482e4836-be014441447a 
EFTA00298214

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Page 324 
PROCEEDINGS 
Deposition taken before Jeana Ricciuti, Registered 
Professional Reporter and Notary Public in and for the 
State of I•lorida at Large, in the above cause. 
Thereupon, 
(JOSEPH RECAREY) 
having been fast duly sworn or affirmed, was examined 
and testified as follows: 
THE WITNESS: I do. 
CROSS (JOSEPH RECAREY) 
BY MR. WEINBERG: 
Q. Good morning, Detective. 
A. Good morning. 
Q. You've been a detective for the Palm Beach 
Police Department for how long? 
A. Approximately, 15 years. 
Q. Some of it is as a detective and some of it in 
another capacity, or always as a detective? 
A. I've been with the Town for 19 yews, but I 
did time on the road and then moved up to the detective 
bureau. 
Q. And do they have a written practice in teams 
of whether or not you're required to preserve rough 
Page 326 
1 
Q. And you would type the report into a computer? 
2 
A. Yes. 
3 
Q. And that would be essentially signed by you, 
4 
that would be your personal summary of the interview 
5 
that you were conducting with one of the many people 
6 
that gave you information about Mr. Epstein? 
A. Correct. 
8 
Q. And it was always your practice in this case 
9 
to then destroy the notes that you used as a basis for 
10 
that typed summary; is that correct? 
A. Correct. 
12 
Q. And on other cases, is it always your practice 
13 
to destroy the notes that you would take during the 
14 
interviews? 
15 
A. Correct. 
16 
Q. So you have no notes of any case that you've 
17 
ever memorialized into a computer or a typed summary; is 
18 
that correct? 
19 
A. That is correct. 
20 
Q. And is that a practice that you've discussed 
21 
with other detectives in the Palm Beach Police 
22 
Department? 
23 
A. Ifs just a practice that I've done all along. 
24 
Q. And what is the purpose of your destroying the 
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rough notes? 
Page 325 
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notes or interview notes of different witnesses? 
2 
A. No policies, no practice. 
3 
Q. Do you have personal practice as to whether or 
4 
not you would retain rough notes that you are 
5 
contemporaneously taking of interviews with the 
6 
witnesses? 
7 
A. I take my notes, transcribe them into my 
8 
supplements and then shred them. 
9 
Q. So that you have no rough notes or no 
10 
handwritten notes —
11 
A. Correct. 
12 
Q. 
of any of the many interviews you took 
13 
during your investigation of Jeffrey Epstein? 
14 
A. Correct. 
15 
Q. It was your practice to take notes while you 
16 
were interviewing people? 
17 
A. On occasion, 1 did, yes. 
18 
Q. Would you take notes even if you were tape 
19 
recording the people with whom you were conducting an 
20 
interview? 
21 
A. On occasion. 
22 
Q. And at some point thereafter, you would use 
23 
those notes as a basis of writing a report; is that 
24 
correct? 
25 
A. Correct. 
Page 327 
1 
A. There's no need to keep them once you've 
2 
transcribed than into your supplemental. 
3 
Q. And again, the transcription into the 
4' 
supplemental is done X number of days after the 
5. 
interview? 
6 
A. If not the same day. 
7 
Q. Sometimes a week after, sometimes the same 
8 
day? 
9 
A. I wouldn't say a week after. I would say 
10 
either the same day or the day after. 
11 
Q. So within 24 hours, you would have a typed 
12 
summary of the interview, is that correct? 
13 
A. Approximately. 
14 
Q. And would you just type your rough notes or 
15 
would you summarize from your rough notes when you 
16 • 
engaged in the process of —
17 
A. Summarize. 
18. 
Q. 
— your report? 
19 
So the notes would have more than a summary? 
20 
A. Obviously, if it was taped, everything would 
21 
be on the tape recorder. As fir as my note-taking 
22 
concerns, I would jot down things that sparked my 
23 
curiosity or things I wanted to go back and reinterview 
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the person - and go back and reinterview the person. 
25 
Q. So the summary that you typed into a computer 
PROSE COURT 
3 (Pages 324 to 327) 
REPORTING. AGENCY, INC. 
Electronically signed by Jeana Ricciuti (601 
Electronically signed by Jeana Ricciuti (601 
c6062637-abel-452c-a836-bc614e314d7a 
EFTA00298215

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Page 330 
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would be, in part, your notes, part in memory of 
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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 
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Q. And then, in part, what your notes refreshed 
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stop burglaries as well as stuveilling Mr. Epstein, 
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your memory into recalling from the interview that was 
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right? 
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conducted either at that time, the same day or the day 
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A. And other fractions as well. 
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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 
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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 
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saying — 
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involved in investigating Mr. Epstein prior to your 
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Q. Asa regular practice, would you, at the time 
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first involvement in September, it was simply an 
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that you typed in your supplemental report into a 
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assignment made of them to assist Officer Pagan, 
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computer, have the tape recording going? 
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correct? 
22 
A. See, I have done that on other cases, 
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A. Correct. 
23 
especially lengthy interviews, interviews that last 
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Q. And if you know, did the Burglary Task Force 
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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 
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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 
Beach Police Department of Mr. 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 
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there was. 
7 
correct? 
7 
Q. Did you ever direct video surveillance of 
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A. I typed, and other officers as well. 
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Mr. Epstein's residence? 
9 
Q. Because you came to this investigation at 
9 
A. What do you mean "direct"? 
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least six months after it began; is that right? 
10 
Q. In other words, was there any video 
11 
A. Approximately, yes. 
11 
surveillance of Mr. Epstein's residence on or after the 
12 
Q. Again, March of 2005? 
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time that you became the ease agent in the 2005 
13 
A. Yes. 
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investigation? 
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Q. And it began with Officer Michele Pagan being 
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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 
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conducted by the Burglary Task Force? 
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became the case agent in charge of the investigation? 
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A. Correct 
19 
' 
A. I can't recall if it was before I took over 
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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 
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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? 
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one second. 
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A. Correct. 
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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 
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MR. PIKE: Yes, pursuant to the agreement that 
2 
was entered last time, the real names can be used. 
3 
MR. WEINBERG: Chuck is not going to be in 
4 
agreement, but i can use the real names, and then 
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they will be convened in the transcript to the 
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applicable abbreviations. 
7 
BY MR. WEINBERG: 
8 
Q. Jane Doe, do you know that name? 
9 
A. Not that I recall. 
10 
Q. So that it's fair that as you sit here today, 
11 
in 2010, you have no recollection of ever interviewing a 
1.2 
woman, a young woman at the time named Jane Doe? 
13 
A. i don't recall, no. 
14 
Q. n, 
d:
e
r ciu have any recollection of ever 
15 
interviewing M.? 
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A. I went to her home. 
17 
Q. And what do you recall of going to her home? 
18 
A. She did not ward to speak to me. 
19 
Q. And did she tell you why she didn't want to 
20 
speak to you? 
21 
A. She was in love with Mr. Epstein and she was 
22 
not going to speak to me. 
23 
Q. And how did you come to go to her home? Do 
24 
you wall, you lawny, what led you to M.? 
25 
A. Her name came up in the investigation either 
Page 334 
1 
yoinself? 
2 
A. NO, sir. 
3 
Q. Did you ever discuss with anyone the fact that 
4 
there was such a victim list that had been generated out 
5 
of the United States Attorneys Office? 
6 
A. There was a list, I believe, that was given to 
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chief — former Chief Reiter. I never got to actually 
8 
physically hold it and look at it i mean, it was one 
9 
of those things where he showed me the list, but I never 
10 
got a chance to... 
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Q. Did the Chief represent to you that that list 
12 
originated with the United States Attorneys Office? 
13 
A. I believe so. 
14 
Q. Did he explain that he had received it from 
15 
them? 
16 
A. I believe so. 
17 
Q. And did he explain ho received it from them 
18 
with the directive that it should be reviewed and then 
19 
destroyed? 
20 
A. I recall the destroying part I'm sure he 
21 
reviewed it 
22 
Q. What do you recall of the destroying part? 
23 
A. I remember him telling me that he was given 
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the copy but it must be destroyed immediately 
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thereafter. 
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Page 333 
by interviews or — I believe it was interviews. 
Q. And do you recall who was interviewed, who 
would have given you for the first time the name of 
M.? 
A. There were so many interviews then. I would 
have documented it in the incident of who supplied what 
name. 
Q. So independent of what's documented in an 
incident report that was largely authored, what's now 
five years ago, you have no otrecollection of who 
would have first toM you about 
? 
A. Lilco I said, it would be documented in the 
incident report You know, we're talking five years 
ago. You know, tons of interviews. 
Q. And with Jane Doe, similarly, do you you 
don't remember interviewing her. Do you remember 
interviewing anybody else about Jane Doe? 
A. Jane Doe does not ring a bell. 
Q. Did you ever see her name on any report? 
A. No, I don't remember. 
Q. Did you ever see her name on any list of 
different complainants, victims, witnesses? 
A. No. 
Q. Did you eva sec a list of victims or 
witnesses that was prepared by someone other than 
Page 335 
1 
Q. And did he tell you who directed him to 
2 
destroy it? 
3 
A. No. 
4 
Q. Did he tell you whether or not that directive 
5 
was in writing or verbal? 
6 
A. No. 
7 
Q. Have you ever seen — other than seeing him in 
8 
the physical possession of the list, have you ever seen 
9 
it again? 
10 
A. No. 
11 
Q. Do you have any reason to believe that he 
12 
didn't destroy it? 
13 
A. No. If he says he was going to destroy it, he 
14 
would destroy it. 
15 
Q. And do you recall when that was in terms of 
16 
the evolution of the State case? 
17 
A. It would have been around December or January 
18 
time Same of like '06,107. 
19 
Q. So either the end of '06, beginning of '07? 
20 
A. I believe so. 
21 
Q. Or at the time period that would be after the 
22 
State grand jury met and returned charges against 
23 
Mr. Epstein? 
24 
A. It would have been, yes, much after. 
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 
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sum-ceding information that brought in the charges? 
2 
A. It would have been — again, I'm going off of 
recollection here. 
4 
Q. And again, I understand this is four years ago 
5 
and we're just trying to get your best unrefreshed 
recollection. 
7 
A I'm trying to think back. It would have 
8 
been — it would have been — see, I would be guessing. 
9 
Q. We don't want you to guess. 
10 
A That's the thing, I would be guessing. 
11 
Q. Did the Chief ask you to come to his office? 
12 
A Yes, he did ask me. He said the — the list 
13 
was not going to leave his office, most assured, and 
14 
I — at that point, I was like, you know, don't even 
15 
show me. Liman, it was for your eyes only, that's 
16 
fine. 
17 
Q. And did he explain to you why he was directed 
18 
to destroy the list? 
19 
A. No. 
20 
Q. Has the Chief ever before invited you to his 
21 
office to discuss a document that he thereafter told you 
22 
he was directed to destroy? 
23 
A. I mean, I've been many times at the Chiefs 
24 
office — 
25 
Q. Sure. 
Page 338 
1 
Q. And you certainly don't recall him ever saying 
2. 
that on any other occasion that he had been directed by 
3 
any Federal or State prosecutor -
4. 
A. Not with me, no. 
5 
Q. — to destroy a document? 
6 
A. Not with me. 
7 
Q. And just so we're clear, this docwnent was 
8 
being destroyed, not in the regular course of business, 
9 
but as a result of the directive from the Federal 
10 
prosecutor, correct, according to —
11 
A. I would assume so, yeah. 
12 
Q. And there was no other copy that you knew of 
13 
this document? 
14 
A. No. 
15 
Q. And you have never seen one thereafter? 
16 
A. N sir. 
17 
Q. 
M
.
,
 
you went to ha house; is that correct? 
18 
A. Correct 
19 
Q. Did you speak to either of her parents? 
20 
A. No, I did not. 
21 
Q. Was she 18 at the time you went to her house? 
22 
A. I believe so. 
23 
Q. Was your practice that when somebody was over 
24 
18, you would feel Otte it was appropriate to interview 
25 
them directly, but if somebody was under It, you would 
Page 337 
1 
A. — but not — leant recall if there was ever 
2 
a time that he showed me a document that he must 
3 
destroy. 
4 
Q. And have you ever been, yourself, directed by 
5 
either a State attorney or a US attorney to destroy your 
6 
document? 
7 
A. No. 
8 
Q. And has the Chief ever told you, on any other 
9 
occasion that you currently recall, that he was directed 
10 
by a Federal or State prosecutor to destroy a document? 
11 • 
A. I don't know. 
12 
Q. And other than destroying documents in the. 
13 
regular course of business, you don't recall the Chief 
14 
ever before or ever after saying he had been directed by 
15 
any third party to destroy a document that was relevant 
16 
to the investigation, correct? 
17 
A. Fro sorry, can you ask the question again? 
18 
Q. Oh, sure. Fm sorry. Other than this 
19 
occasion when the Chief invited you to his office and 
20 
specifically said that he was in possession of a 
21 
document, relevant to the Epstein investigation that he 
22 
had been directed to destroy, do you recall any other 
23 
occasion where the Chief told you that he was destroying 
24 
a document relevant to an investigation? 
25- 
A. No. 
Page 339 
1 
try to give some parental notification? 
2 
A. Correct. 
3 
Q. And your best recollection with 
is she 
4 
was over 18 and, therefore, you went directly to her? 
5 
A. Correct 
6 
Q. What would you have told her when you rang on 
7 
her doorbell and she answered the door? 
8 
A. I would have identified who I am, my purpose 
9 
for being there. 
10 
Q. And what would you have said your purpose for 
11.. 
being there was? 
12 
A. I was conducting an investigation. 
13 
Q. And wonld.you tell her of who? 
14 
A. Yes. 
3.5 
Q. And would you tell her the subject matter of 
16 
the investigation? 
17 
A. Yes, absolutely. 
18 
Q. And her answer was that she did not wish to 
19 
cooperate with you? 
20 
A. I never got to the point to explain to her my 
21' 
purpose of being there. Obviously, she knew why I was 
22 .- . 
there. Once I identified myself, l told her I was a . • 
23 
police officer from Palm Beach and I was here to speak 
24- 
to her in regards to Jeffrey Epstein. At that point, 
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 
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him, nothing negative to say about him. She is in love 
2 
with the man, and... 
3 
Q. So that was literally a 30-second 
4 
conversation? 
5. 
A. Pretty much. Pretty much. 
6 
Q. Were you with anyone? 
7 
A. Yes, I was. 
• 8 
Q. Who were you with? 
9 
A. I want to say either Sergeant Dawson, who was 
10 
a detective at the time. 
11 
Q. Did you follow that tip at all by attempting to 
1.2 
reinterview her on any other occasion? 
13 
A. No. 
14 
Q. So your sum total experience with 
was 
15 
essentially a 30-second conversation at her house where 
16 
she declined your invitation to disci KS Jeffrey Epstein 
17 
with her? 
18 
A. Correct. 
19 
Q. Okay. And you do recall her saying, "fin in 
20 
love with him*? 
21 
A. Yes. 
22 
Q. And you're assuming but don't know that she 
23 • 
had been essentially tipped off that this investigation 
24 
was ongoing; is that correct? 
25 
A. Pretty much. I mean, she didn't know why I — 
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Page 342 
Q. Do you recall who that was? 
• 
A. Yes, I do. 
Q. Who was that? 
A. 
Q. And tell me what you remember of that 
attempted interview. 
A. I went up to interview her with Detective 
Caristo, at her boyfriend's place of employment was 
where she was at. And she didn't wish to speak to me at 
that point. 
Q. And did she tell you why? 
- 
A. If l can refer to it. 
Q. Sure, go ahead. 
A. She said that she knew there was an 
investigation and that 1 had spoken to other people and, 
therefore, I should know what had happened at 
Mr. Epstein's house. 
Q. And did she make any other further explanation 
for her declining your request for an interview? 
A. No. 
Q. Did she tell you that she, like M., had 
positive regard for Mr. Epstein? 
A. I don't recall any positive regard. 
ti.3icylou take notes of your conversation with 
Ms.
Page 341 
1 
allegedly why 1 was there, but yet she... 
2 
Q. Well, you told her why you were there, and she 
3 
then said, I'm in love with Jeffrey Epstein and have 
4 
nothing negative to say about him? 
A. Correct. 
6 
Q. And so am I correct that she didn't say that 
7 
she knew why you were there, that you're assuming that, 
8 
because of the timing of that interview, that she had 
9 
discussed the investigation with others? 
10 
A. It's possible. 
11 
Q. You don't recall anybody telling you —
12 . 
A. No. 
13 
Q. — at this time, that they had talked to M. 
14 
about your investigation? 
15 
A. No. 
16 
Q. Was there more than one such person, meaning
17 
did anybody else that you attempted to interview about 
. 
18. 
Jeffrey Epstein decline to be interviewed, to your 
19 
current recollection? 
20 
A. No. I believe she's the only one. 
21 
Q. Can I ask you to look at page 81, paragraph 1 
22 
of your incident report, and ask whether or not that • . 
23 
refreshes your recollection about the events of 
• . 
24 
February 15, 2006. 
25 
A. Yes. 
Page 343 
1 
A. No. 
2 
O
fild you take notes of your conversation with 
3 
Ms. M.? 
4 
A. No. 
5 
Q. Did you write any supplemental report 
6 
regarding your interview attempts with Ms. 5? 
7 
A. I believe I did. 
• 
8 
Q. And likewise, you have before you a 
9 
supplemental 1.1 that reflects your attempts to 
10 
interview Ms.
11 
A. Yes. 
12. 
Q. Did you ever attempt to interview a woman 
13 
nulled a? 
14 
A. Yes, I did? 
15 
Q. What do you recall of that interview? 
16 
A. She was a masseuse. I remember going to her 
17 
home and interviewing her at her home. And If I recall 
18 
correctly, she stated that what happened betwom her and 
19 
Mr. Epstein were between consenting adults, that she was 
20 
over 18 at that time. 
21 
Q. And did you write a report on that inns-view 
22 
attempt? 
• 
23 
A. I believe so. 
24. 
Q. And in fact, you interviewed a writs of women 
25 
- 
who were over 18 years old,not only at the time of the 
7 (Pages 390 to 343) 
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interview, but also at the time of the events between 
2 
them and Mr. Epstein, correct? 
3 
A. Correct. 
Q. And you would incorporate those interviews 
within the overall 87-page incident report is that 
correct? 
A Correct 
8 
Q. So that the focus of this broad investigation 
9 
was not restricted to women under 18 and also included 
10 
women who were over IS; is that correct? 
11 
A. Correct 
12 
Q. Now, some of the girls that you interviewed, I 
13 
don't mean to be disrespectful, but some of the minors 
14' 
you interviewed were emotional at the time of your 
15 
interview, is that correct? 
16 
A. Correct 
17 
Q. And if they were under 18 at the time of their 
18 
interview, it WAS your practice to precede that 
19 
• interview with some notification to their parents; is 
20 
that correct? 
21 
A. Correct 
22 
Q. And what would that notification be? In other 
23 
words, what would you tell the mother or father of a 
24 
minor? 
25 
A. That their daughter was a possible victim 
2 
3 
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6 
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9 
10 
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12 
13 
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Page 346 
THE WITNESS: Right. Some girls wart under n 
different ruse. They thought they were going to 
either model or get a chance to be in Victoria 
Secrets or that kind of thing, but... 
BY MR. WEINBERG: 
Q. That was the exception to the rule. 
A. Nobody was bound and gagged to go to the 
house. 
Q. And those that told you that they thought they 
were going there for some other purpose were the 
exception to the rule that was disclosure by whoever 
invited them, correct? 
MS. ARBOUR: Object to the fonn. 
THE WITNESS: Some girls, again, told me that 
they were going there to give massages, and some 
girls went there for other reasons. 
BY MR. WEINBERG: 
Q. Well, let's take one of them who claimed to 
have gone there for another reason. Do
 recall 
interviewing n young woman named M.? 
A. Yes. 
Q. And when did you interview her? Would the 
date of January 9, 2006 be consistent with your memory 
as to when you interviewed 
A. It would have been, yeah, about that time. 1 
1 
3 
4 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
-17 
18 
19 
20 
21 
22 
23 
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25. 
Page 345 
and/or witness in a police investigation involving a 
gentleman that lives in the Town of Palm Beach. 
Q. And had you, at the time of say by October of 
2005, within 30 days of your commencing of your 
responsibilities in this investigation, concluded that, 
as to these minors, that they would not be prosecuted; 
that they were either victims or witnesses but not 
targets? 
A. Rephrase your question one more time, Tm 
sorry. 
Q. Sure. Let me give you a predicate. Many, if 
not all, of the people you interviewed were paid sums of 
money to give Mr. Epstein a massage at the bottom level, 
correct? 
A. Correct 
Q. And that they went to his house, correct? 
A. Yes. 
Q. And that they went to his house voluntarily; 
is that era met? 
MS. ARBOUR Object to the form. 
311E WITNESS: Yes. 
BY MR. WEINBERG: 
Q. In other words, they weren't kidnapped or . 
coerced into going to his house. 
MS. ARBOUR: Object to the form. 
Page 347 
1 
know 1 attempted it once before and she was emotional 
2 
and, plus, I needed to get her father's consent because 
3 
she was still underage. 
4 
Q. When you went to visit with her father, her 
S 
father talked to you, did he not? 
6 
A. Either 1 telephoned him or spoke to him 
7 
directly. I believe I might have tel 
oned him. 
8 
Q. And the father told you that M. had told him 
9 
that she had been hired to model lingerie; is that 
10 
correct? 
11 
A. 1 believe so. Pm not 100 percent certain on 
12 
that one. I know I recall the modeling part. I don't 
13 
know if it was exactly lingerie or... 
14 
Q. Okay. The father had communicated to you that 
15 
his daughter had told him that her connection to Jeffrey 
16 
Epstein was that she went to see him as a model? 
17 
A. Yes. 
18 
Q. In other words, what you took from talking to 
19 
the father is that M. had likely lied to him regarding 
20 
her experiences with Mr. Epstein, correct? 
21 
A. I wouldn't say "lied to him," because that's 
22 
what she claimed to me, that that was the purpose of her 
23 
going to the house. 
24 
Q. But the father said that that's what she said 
25 
was the relationship between him [sic] and Mr. Epstein, 
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that she went there as a model. 
2 
A I recall that that's what the father knew of 
3 
her going over there. 
4 
Q. Sure. And this isn't the first parent that 
5 
you interviewed that didn't know what his daughter would 
6 
later claim occurred to you; is that right? 
7 
A. What do you mem? 
8 
Q. In other words, many of the parents that you 
9 
sought permission to interview their daughters did not 
10 
know the details of what had transpired between their 
11 
daughters and Mr. Epstein, correct? 
12 
A. Correct. 
13 
Q. And in fact, no parent called you up 
14 
uninvited, uninitiated and said, I want to complain 
15 
about something that's happening in Palm Beach regarding 
16 
Mr. Epstein? 
17 
A. That's how the case first became originated, 
18 
but not me directly. 
19 
Q. Not you. 
20 
A. Not me directly. 
21 
Q. So of all of the witnesses that you 
22 
interviewed, there wasn't a single parent that came to 
23 
you as contrasted to you going to them? 
24 
A. No, not tome. I know that 
25 
Q. I understand and — 
1 
2 
3 
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8 
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10 
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14 
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Page 350 
came tome and said that something bad happened to her 
in relation to Jeffrey Epstein. 
A. No. 
Q. And no teacher ever came to you and said, my 
God, I have a student who is saying that something bad 
or improper happened in relation to her and Jeffrey 
Epstein, correct? 
A. Correct. 
Q. And no religious figure ever came to you and 
asked you to investigate Mr. Epstein as a result of some 
confessional or some complaint that he received from 
either a minor or from a parent of a minor? 
A. Correct. 
Q. And from that, you concluded that — strike 
that. 
No doctor ever came to you and said that they 
had a patient that had been harmed by Jeffrey Epstein 
during the time period of your 2005/'6 investigation, 
correct? 
A. Correct. 
Q. No psychiatrist or social worker or mental 
health professional ever came to you and said, I have a 
patient or client that claims to have been banned by 
Mr. Epstein? 
A. Correct 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
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Page 349 
A. -- Officer Pagan — 
Q. -- we'll get there. Because you never 
yourself interviewed .., is that correct? 
A. No, I did not 
Q. So any testimony that you have given about 
was derived from your reading reports that were 
authored by Officer Pagan and others, correct? 
A. Correct. 
Q. And amongst those reports was some indication 
that one of the parental figures in 
life had made 
a proactive phone call to the Palm Beach Police 
Department in March of 2005, correct? 
A. Coned. • 
• 
Q. And they had overheard some conversation about 
what .. 
claimed to have done at Jeffrey Epstein's 
house, correct? 
• 
A. Correct. 
Q. And that they were not saying, my daughter 
came to me and said, please call the police, something 
happened to me; they were claiming that they had 
overheard a conversation, correct? 
A. I believe so, yes. 
Q. So no parent said to you or — and there's no 
report that reflects a parent saying to Officer Pagan or 
anyone else in the Palm Beach Police Department, my kid 
Page 351 
1 
Q. And no minor ever came herself to the Palm 
2 
Beach Policy Department and claimed to have been alnico(' 
3 
or harmed by Jeffrey Epstein? 
4 
A. Well, after the arrest of Mr. Epstein, we did 
5 
have people telephone In, but... 
6 
Q. But not before the arrest and in fact, the --
7 
not before the grand jury returned its charge in the 
8 
summa of 2006, correct? 
9 
A. Correct. 
10 
Q. And then you had occasional calls from people 
11 
who you reported their allegations, correct? 
12 
A. Correct. Actually, it's Dawson —
13 
Q. One was from New York and California —
14 
A. — Sergeant Dawson, right. 
15 
Q. — and they had — they were kind of jumping 
16 
on the Internet train that resulted from the publicity 
17 
of Mr. Epstein's charge. 
18 
MS. ARBOUR: Object to form. 
19 
THE WITNESS: I don't know if you want to call 
20 
that as a publicity train, but some of these 
21 
victims were legitimate, you know. I mean, we did 
22 
have people call in as adults, but we had 
23 
legitimate victims calling in. 
24 . 
BY MR. WEINBERG: 
25 
Q. And you call them legitimate victims, but just 
PROSE COURT REPORTING AGENCY, 
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Page 352 
so the record is clear, you were not present at 
Page 354 
trying to initiate an investigation against Mr. Epstein 
7 
Mr. Epstein's home on any occasion when he had a 
with the sole exception of the n. broad family and the 
3 
one-to-one or contact with any of the so-called 
phone call that came into the police department six 
1 
complainants, correct? 
, 
months before you became case agent, correct? 
5 
A. No. 
5 
MS. ARBOUR: Object to form. 
6 
Q. So this is not something you — you were not 
6 
THE WITNESS: Coned. 
/ 
an eyewitness to any of the events, correct? 
7 
BY MR. WEINBERG: 
8 
A. Correct. 
8 
Q. So let's, if we can, go back to 
and try 
9 
Q. There was no video surveillance of what did or 
9 
to at least focus on one of the interviewees. 
10 
did not occur in the massage room on the second floor on 
10 
She told you that she had originally gone to 
11 
El Brillo; is that correct? 
11 
the house believing that she was going there for the 
12 
' A. 'Correct. 
12 
purpose of modeling; is that comet? 
13 
Q. There was no audio surveillance of any 
13 
A. Correct. 
14 
conversations that Mr. Epstein participated in with any 
14 
Q. And somebody must have told her that, correct? 
15 
of the witnesses or complainants; is that correct? 
15 
A. I believe the person that took her. 
16 
MS. ARBOUR: Object to form. 
16 
Q. And do you recall who took her? Would. 
17 
THE WITNESS: Correct. 
17 
ring a bell? 
18 
BY ta NVIIIIIBBRO: 
18 
A. I believe, yes, I believe it was M. that 
19 
Q. You're relying on, A, what you were told and, 
19 
took her. 
20 
B, what your investigation derived? 
20 
Q. Do you recall writing — and this comes from, 
21 
A. During the sworn taped statement. 
21 
what I believe, is Exhibit 1 of the Palm Beach Police 
22 
Q. So going back to the period before he was 
22 
Department affidavit that "On January 9.1_20306,1 
23 
arrested and before there was this kind of outflow of 
23 
located and interviewed another victim, s date of 
24 
media or attention, there was not any of the different 
24 
birth April 29, 1988. 
was identified as a potent .1 
25 
minors that, who reside in Palm Beach, ever came to 
25 
victim witness from infonnation obtained during tia.‘,1 
Page 353 
Page 355 
1 
their local police department or to the Palm Beach 
1 
pulls from Epstein's residence." 
2 
Police Department and made a complaint against 
2 
And I represent to you I'm reading this 
3 
Jeffrey Epstein; is that correct? 
3 
accurate. 
4 
MS. ARBOUR: Object to form. 
4 
Does that refresh your memory about the going 
5 
TIM WITNESS: Are you limiting your 
5 
ton.? 
6 
questioning to just the persons that lived within 
6 
A. Yes. 
7 
the Town of Palm Beach limits? 
7 
Q. And during what period of time would they have 
8 
BY MR. WEIN13ERO: 
• 
a 
these trash pulls? 
9 
Q. Let me start with the people within this 
9 
A. That would have been documented in the report. 
10 
region. Did any minor ever initiate a complaint with 
10 
Q. Any of them after the search of October 20th? 
11 
you against Mr. Epstein before you had gone to them? 
11 
A. It might have been. 
12 
A. Not that I can recall, no. 
12 
Q. And by trash pull, we're referencing the 
13 
Q. And likewise, you don't know that any minor in 
13 
attempts by the Palm Beach Police Department to derive 
14 
14 
investigatory material by searching the garbage that 
this region, before the publicity, ever went to their 
15 
local police department, be it in West Palm Beach or 
15 
came from Mr. Epstein's residence; is that correct? 
16 • 
Daytona Beach or wherever, and said, I want to report 
16 
A. That is correct. 
17 
that I have been injured, harmed, compromised by 
17 
Q. And the conversations engaged in between you 
18 
Jeffrey Epstein. 
18 
and others working for you and different representatives 
19 
MS. ARBOUR: Object to form. 
19 
of the Palm Beach Sanitation Department? 
20 
THE WITNESS: If there was, I wouldn't be . 
20 
A. The Sanitation Department didn't go through 
21 
aware of it. 
' 
21 
the trash; all they did was pull it for us. 
22 
BY Mit. WEINBERG: 
22 
Q. But there were conversations between the 
23 
Q. Your 87-page report does not reflect any 
23 - 
police and Sanitation asking Sanitation to have a clean 
24 
initiative taken by any minor or any parent of a minor 
24 
and empty truck; is that correct? 
25 ' 
or any professional who is associated with a minor in 
25 
A. Correct 
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Q. To drive the truck to a certain location, 
2 
correct? 
3 
A. Correct 
Q. To collect the trash on certain days from 
5 
Mr. Epstein's house, correct? 
6 
A. Correct. 
Q. You knew that Mr. Epstein's house was enclosed 
8 
by security gates from your surveillances there, did you 
9 
not? 
10 
A. Correct 
11 
Q. And that one would need to buzz in to come in? 
12 
A. Not necessarily. I mean, the gates leading to 
13 
the garage were always left unsecured, opened. 
14 
Q. Did you not know that the Sanitation people 
15 . 
would buzz in and ask — tell them that they were there 
16 
to get the trash? 
17 
A. In the many, many times that I've driven by, 
18 
I've always seen that gate open to the garage. 
19 
Q. But when the Sanitation people went to 
20 
Mr. Epstein's house, they were there pursuant to an 
21 
agreement with you, that they would bring the trash to a 
22 
predestined location where it would be made available to 
23 
Palm Beach --
24 
A. Well, they were watched. 
25 
Q. They were watched? 
Page 358 
1 
A. Correct 
2 
Q. And that they would go in and you would 
3 
surveille them going in? 
4 
A. Correct. 
5 
Q. They would come out with the trash, correct? 
6 
A. Correct 
7 
Q. They would put it in their truck, correct? 
8 
A. Correct. 
9 
Q. They wouldn't open it and mix it with the 
10. 
trash? 
11 
A. No. 
12 
Q. They would take special care of it —
13 
A. Absolutely. 
14 
Q. - so that it was preserved for search? 
15 
A. Absolutely. 
16 
Q. They would drive it to a place where the 
17 
target wouldn't observe the transfer? 
18 
• 
A. Correct. 
19. 
• 
Q. They would hand over the trash to the polio 
20 
officer, correct? 
21 
A. Correct. 
22 
Q. And the purpose of this trash seizure would be 
23 
to search the trash for investigative evidence, correct? 
24 
A. Correct. 
25 
Q. And to your understanding, that was done 
Page 357 
1 
A. They were watched. 
2 
Q. So you knew when they were going? 
3 
A. Correct. 
4 
Q. There was a predestined time tlx:? they worn• 
5 
going to go; is that correct? 
6 
A. Correct. Correct. 
7 
Q. And you saw them go onto Mr. Epstein's 
a 
property. 
9 
A. Correct. 
10 
Q. You saw them walk into, through the gates, 
11 • 
whether they were opened or whether they were opened for 
12 
the people; is that correct? 
13 
A. Correct. 
14 
Q. You'd see them walk through the driveway 
15 
area — 
16 
A. Correct 
17 
Q. — Into the garage or near the garage, or was 
18 
there a point in which they disappeared from your sight? 
19 
A. I wasn't the one that was watching them. 
20 
There was other representatives of the Police 
21 
Department. I'm just telling you how I have always done 
22 
my trash pulls. 
23 
Q. So standard practice would be to have an 
24 
agreement on a time that you would meet the trash people 
25 
outside the target's residence. 
• • 
Page 359 
1 
before you commenced your responsibilities m this 
2 
investigation? 
3 
A. Before and during. 
4 
Q. And there was always cooperation by the Palm 
5 
Beach Sanitation Department, correct? 
6 
A. Correct 
7 
Q. They were, in fact, directed not to disclose 
8 
to Mr. Epstein that they were seizing his trash, not 
9 
just to bring it to the dump, but to bring it to the 
10 
officers, correct? 
11 
A. Correct. 
12 
Q. And again, this was done not under your watch, 
13 
but under your supervision while you were case agent on 
14 
the 2005 fall Epstein investigation, correct? 
15 
A. Correct. 
16 
Q. And from the trash, different leads were 
17 
found; is that right? 
38 
A. Correct. 
19 
Q. Leads that might not have been found had you 
20 
not gone through the trash? 
21 
MS. ARBOUR: Object to form. 
22 
THE WITNESS: I would say some, but not all.
23 
BY MR. WEINBERG: 
24 
• 
Q. And you saw some message pads? 
25 
• 
A. Copies of the messages, yes. 
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Page 360 
Q. And you later teamed what they were as a 
result of your having gone to Mr. Epstein's home on 
October 20th, pursuant to a warrant, and seized large 
numbers of message pads, correct? 
A. Correct 
Q. And there were also notes that weren't on 
message pads, correct, that were seized from the 
garbage? 
A. Correct 
Q. Notes that were on Mr. Epstein's own pad with 
his own name on it, correct? 
A. Correct 
Q. And some of those notes related to his 
business, if you know? 
• 
A. I don't believe so. 
Q. But some of the messages led you to phone 
numbers and the names of different people, such as 
correct? 
A. Correct. 
Q. And since Ms. M. was first interviewed on 
January 9,2006, is it fair to say that the trash pull 
from which her identity was first revealed, occurred in 
the fall 2005 period while you were case agent? 
A. I don't know. Without seeing the actual 
• 
message, I can't commit to that kind of answer. 
Page 362 
1 
Q. Was it your understanding that Ms. M. had 
2 
been there months before January 9, '06 as contrasted 
3 
two years? 
4 
A. As far as, I'm sorry? 
5 
Q. When you interviewed her on January 9,'06 
6 
A. Right. 
7 
Q. — was she telling you of events that occurred 
8 
years before or months before, if you recall? 
9 
A. I can't recall. 
10 
Q. But you do meal! M. was her contact; she 
11 
was the person who invited her to go to Mr. Epstein's 
12 
home? 
13 
A. I believe so. 
14 
Q. And M. was currently in love with 
15 
Mr. Epstein in or around the same time period? 
16 
A. That's what she claimed to me. 
17 
Q. And did your investigation disclose whether 
18 
Ms. M. was currently seeing Mr. Epstein in the fall of 
19 
2005 into the early 2006? 
20 
A. I can't recall if she was still going to the 
21 
residence. 
22 
Q. Ms. ■ 
told you she was originally told she 
23 
would be able to model lingerie for a wealthy Palm 
24 
Beecher, is that correct? 
25 
A. That's what I documented. That's what she 
Page 361 
1 
Q. Did Ms... tell you when, in relation to 
2 
January 9, 2006, she had last been to Mr. Epstein's 
3 
home? 
4 
A. I can't recall. 
5 
Q. Did you ask these witnesses, whom you were 
6 
interviewing, what time period they recall being at his 
7 
house? 
8 
A. Yes. 
9 
Q. And if there is nothing in the report, would 
10 
that reflect — 
II 
A. Well, you're looking at the probable cause 
12 
affidavit The report will reflect more. 
13 
.Q. The incident report was — the probable cause 
14 
affidavit was a subset of the affidavit — strike that. 
15 
The affidavit is a subset of the incident 
16 
teport. 
17 
A. Correct 
18 
Q. If it's not in the incident report, then does 
19 
that reflect that you did not ask that question of .? 
20 
A. I would have asked regardless. 
21 
Q. Did it inflect that she didn't give you an 
• 
22 
answer? 
23 
A. Some witnesses were able to recall specifics; 
24 
others were not able to recall exactly when, pinpoint 
25 
what time. 
Page 363 
1 
told me. 
2 
Q. And that she was taken to Mr. Epstein's home 
3 
at El Brillo Way by Ms. M.; is that consistent with 
4 
your memory? 
5 
A. Yes. 
6 
Q. And Ms... introduced her to Mr. Epstein; is 
7 
that correct? 
8 
A. Yes. 
9 
lIl
And you have no independent memory that 
10. 
Ms. M. ever said that she had any conversation with 
11 
Mr. 
ein prior to her being introduced to him by 
12 
Ms. M.; is that correct? 
13 
. 
A. If she had prior conversations with —
14 
Q. Yes, with Mr. Epstein before sbe was brought 
15 
to the house and introduced — 
16 
A. I can't recall whether she said that or not. 
17 
I don't believe so. 
18 
Q. Let me broaden it. Most of the people, if not 
19 
all of people who you interviewed, were introduced to 
20 
Mr. Epstein by some other young woman; is that correct? 
21 
MS. ARBOUR: Object to form. 
22 
THE WITNESS: Correct. 
23 
BY MR. WE114BERO: 
24 
. Q. Whether Ms... was one,.., correct? 
25 
• 
A. Right. 
• 
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'1 
Q. M. was the second; is that correct, that 
1 
BY MR. WEINBERG: 
2 
brought people to his house? 
2 
Q. Or make phone calls to people that she was not 
3 
A. (Non-verbal response). 
3 
introduced to, correct? 
4 
Q. The routine and practice was for the pimple 
4 
MS. ARBOUR: Object to fonn. 
5 
that were introduced to him not to have had any prior 
5 
THE WITNESS: I knew she made several phone 
6 
conversations with him until they were introduced by an 
6 
calls, but it was to people that she knew that had 
7 
intermediary lace Ms. ■ 
or Ms. M.; is that correct? 
7 
been to the house previously. 
8 
MS. ARBOUR: Object to form. 
8 
BY MR. WEINBERG: 
9 
THE WITNESS: I believe so. 
9 
Q. Sure. So let me take it one step back then. 
10 
BY MR. WEINBERG: 
10 
The routine and practice was for one — let's focus on 
11 
Q. And in fact, there were no exceptions to that 
11 
— for a woman such as Ms. M., to introduce 
12 
rule as fares you currently remember? 
12 
Mr. Epstein to people that she had met or who were her 
13 
MS. ARBOUR: Object to form. 
13 
friends, correct? 
14 
THE WITNESS: As far as I can recall. 
14 
A. Uh-huh. 
15 
BY MR. WEINBERG: 
15 
MS. ARBOUR: Object to form. 
16 
Q. I mean, you have no — you don't recall any 
16 
BY MR. WEINBERG: 
17 
information that Mr. Epstein was out himself personally 
17 
Q. And likewise, the.. introduction of.. 
18 
trying to connect with young strange women. 
18 
fa that standard practice of one woman taking a second 
19 
A. No. 
19 
woman to Mr. Epstein and introducing them, correct? 
20 
Q. And likewise, you have no evidence that 
20 
MS. ARBOUR Object to form. 
21 
Mr. Epstein was e-mailing people that he didn't know 
21 
THE WITNESS: Correct. 
22 
attempting to ask than or invite than or recruit than to 
22 
BY MR. WEINBERG: 
23 
come to his home. 
23 
Q. And Ms. IIR, at least, told you during your 
24 
A. No. 
24 
interview with her in the first week of October 2005, 
25 
Q. And you have no evidence that Mr. Epstein, 
25 
that all of the young women that she introduced to 
Page 365 
Page 367 
1 
himself; personally was on a telephone trying to connect 
1 
Jeffrey Epstein knew exactly why they were going to 
2 
with people to whom he had not previously been 
2 
. Mr. Epstein's home. 
3 
introduced, correct? 
3 
MS. ARBOUR: Object to form. 
4 
A. People not known to him? 
4 
MS. FINNIGAN: Joined. 
5 
Q. Yes. 
5 
THE WITNESS: That is what I recall during the 
6 
A. No, not that I'm aware of. 
6 
interview. 
Q. And so that an one — let me ask the same 
7 
BY MR. WEINBERG: 
8 
questions for Ms. 
You're familiar with 
8 
Q. And that was corroborated by your reading the 
9 
her, are you not? 
9 
report that M. said that she knew what she was doing 
10 
A. Yes. 
10 
before she went to Mr. Epstein's home, correct? 
11 
Q. And you have no evidence that she was out 
11 
MS. ARBOUR: Object to form. 
12 
driving around the Palm Beach area looking to meet some 12 • 
TIME WITNESS: I believe so, yes. 
13 
young woman who she, herself, could go and introduce to 
13 
BY MR. WEINBERG: 
14 
Mr. Epstein, correct? 
14 
Q. It was corroborated by others who were 
15 
MS. ARBOUR: Object to form. 
15 
identified by M. and thereafter interviewed by you and 
16 
BY MR.. WEINBERG: 
16 
others working with you, correct? 
17 
Q. People that she had never previously met? 
17 • 
MS. ARBOUR: Fenn. 
18 
MS. ARBOUR: Same objection. 
.18 
THE WITNESS: I believe so. 
19 
THE WITNESS: Not that I'm aware of. 
19 
BY MR. WEINBERG: 
20 
BY MR. WEINBERG: 
20 
• 
Q. So that at least for the.. group, if I can 
21 
Q. And likewise, no evidence that she would 
21 • 
• confine than to by definition the people introduced to 
22 
e-mail people who she was not introduced to? 
22 
Mr. Epstein by Ms. M., none of them ever informed you 
23 
MS. ARBOUR: Object to form. 
23 
that they had gone there under a misapprehension as to 
24 
THE WITNESS: Not that Im aware of. 
24 
what was expected of them, correct? 
25 
25 
• MS. ARBOUR: Object to form. 
13 (Pages 364 to 367) 
PROSE COURT REPORTING AGENCY, INC. 
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• 
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Electronically signed by Jeana Ricciuti (601 
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EFTA00298225

Page 368 
1 
TIM WITNESS: Under the ■ 
group we're 
2 
taring about? 
3 
BY MR. WEINBERG: 
4 
Q. Yes. Let me break it down. Ms... 
5 
identified approximately six people that she had 
6 
introduced to Mr. Epstein. 
7 
A. Correct. 
8 
Q. And each of them was invited by Ms... to go 
9 
to Mr. Epstein's residence, correct? 
10 
A. Correct. 
11 
Q. And Mr. Epstein did not know any of these six 
12 
yotmnvomen prior to being introduced to them by 
13 
Ms. M., correct? 
14 
MS. ARBOUR: Fonn. 
15 
THE WITNESS: As far as I 'mow, yes. 
16 
BY MR. WEINBERG: 
17 
Q. And you have no knowledge that IMI=, 
18 
or anyone else that resided at Mr. Epstein's home on 
19 
El Brillo had any prior or independent relation with any 
20 
of the six girls that was being introduced to 
21 
Mr. Epstein by Ms. M.; is that correct? 
22 
MS. ARBOUR: Form. 
23 
THE WITNESS: As far as I know. 
24 
BY MR. WEINBERG: 
25 
Q. Ms. H.R. was asked by you and told you that 
Recto 370 
1 
BY MR. WEINBERG: 
2 
Q. And they came from her pool of friends or 
3 
associates or people that she made an independent 
4 
decision to sec whether or not they wanted to go and 
5 
meet Mr. Epstein, correct? 
6 
MS. ARBOUR: Form. 
7 
ME WITNESS: Correct 
8 
BY MR. WEINBERG: 
9 
Q. And the people that she invited to 
10 
Mr. Epstein's house had a choice; they could go to 
11 
Mr. Epstein's house, give him a massage and be paid or 
12 
decline to go to Mr. Epstein's house and not give him a 
13 
massage and not be paid, correct? 
14 
MS. ARBOUR: FORM 
15 
THE WITNESS: Correct 
16 
BY MR. WEINBERG: 
17 
Q. And did Ms... tell you there wine people 
18 
that she talked to who decided they didn't want to go to 
19 
Mr. Epstein's home? 
20 
A. I can't recall if she actually gave me names 
21 
of people that she offered to take there and declined. 
22 
Q. But if you take age out of the equation, 
23 
you'll agree there arc other residents in Palm Beach 
24 
that invite people to their homes to engage in paid 
25 
massages? 
Page 369 
1 
she had a practice of telling each and every one of the 
2 
people she invited to Mr. Epstein's home, that they were 
3 
to give Mr. Epstein a massage? 
4 
A. Correct. 
5 
Q. And that they could set their own limits while 
6 
giving Mr. Epstein a massage? 
7 
MS. ARBOUR: Form. 
THE WITNESS: I recall her saying the more you 
9 
do, the more you get paid. 
10 
BY MR. WEINBERG: 
11 
Q. But do you recall her also saying that you 
12 
don't have to do anything you don't want to do? 
13 
MS. ARBOUR: Form. 
14 
THE WITNESS: I believe so. 
15 
BY MR. WEINBERG: 
16 
Q. And she told each and every one of the people 
17 
she invited that they would be paid for the massage, 
18 
correct? 
19 
MS. ARBOUR: Form. 
20 
THE WITNESS: Correct 
21 
BY MR. WEINBERG: 
22 
Q. And she chose the people that she invited to 
23 
introduce to Mr. Epstein, coned? 
24 
MS. ARBOUR: Font 
25 
THE WITNESS: As far as I know, yes. 
Page 371 
1 
MS. ARBOUR: Object to form. 
2 
THE WITNESS: What do you mean? 
3 
BY MR. WEINBERG: 
4 
Q. I mean, in your history with the Palm Beach 
5 
Police Department, that have been residents of Palm 
6 
Beach that have called massage services or escort 
7 
services and utilized their services, correct? 
8 
MS. ARBOUR: Same objection. 
9 
THE WITNESS: I know there are legitimate 
10 
masseuses that come to the residences and provide 
11 
massages, if that's what you're trying to claim, 
12 
yes. 
13 
BY MR. WEINBERG: 
14 
Q. I'm not trying to claim anything. 
15 
A. No, no, no. But I mean, if that's what you're 
16 
trying to get at, absolutely, if that was your question. 
17 
Q. And there were also, to your knowledge as an 
18 
experienced professional officer, there are some not so 
19 
legitimate escort and massage services that have clients 
20 
in the Palm Beach area, correct? 
21 
A. Oh, I'm sure, yeah. 
22 
Q. And that this is not a prosecutorial target 
23 
for the Palm Beach Police to go and target at least 
24 
adult massages, even if they include a sexual element; 
25 
is that correct? 
14 (Pages 368 Lo 371) 
PROSE COURT. REPORTING AGENCY, INC. 
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Electronically signed by Jeana Ricciuti (601 
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Page 372 
Page 374 
1 
MS. ARBOUR: Form. 
2 
THE WITNESS: If there is a crime that's being 
3 
committed in the Town of Palm Beach, we'll follow 
4 
upon it. 
5 
BY MILWEINBERG: 
6 
Q. But you don't go and look for it 
7 
MS. ARBOUR: Form. 
8 
THE WITNESS: When I say that we would solicit 
9 
it? 
10 
BY MR. WEINBERG: 
11 
Q. Yes. 
12 
A. Probably not. Once we start to see a pattern, 
13 
especially in the hotels, yes, we would because we have 
14 
done stings in the past 
15 
Q. Can you recall in the last fwe years any 
16 
resident of Palm Beach, a person with a house there, 
17 
getting arrested for having the paid services of 
18 
masseuse in their home? 
19 
A. Are you talking a legitimate masseuse? 
20 
Q. Any masseuse, legitimate or illegitimate. 
21 
A. I mean, there's no crime against having a 
22 
massage at your house. 
23 
Q. I low about a paid massage that you had a basis 
24 
to believe was sexual as well as pwfiasional, is there 
25 
any resident of that island that's — 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
an escort or a masseuse into their own private 
residence, at least over the last five years, correct? 
A. I'm trying to think back I know we did make 
an arrest off an escort service whae a subject 
telephoned an escort service for sexual favors, and we 
ended up soliciting an arrest warrant for the individual 
for solicitation of prostitution. 
Q. And that resulted from your investigation of 
the escort service, correct? 
A. Based on the interview conducted with him and 
believe the escort herself. 
. 
Q. So one in five years? This is not an everyday 
investigatory priority of the Palm Beach Police, 
correct? 
A. No. We have other cases that we follow up on, 
but.. 
Q. And as you sit here now, you remember one 
'event, one such arrest in five years? 
A. That I can recall. I man... 
Q. Fair enough. Let's go back to II. 
THE WITNESS: Can we take a five-minute break? 
MS. O'CONNOlt: Sure. We need a five-minute 
break. 
(A brief recess was taken.) 
BY MR. WEINBERG: 
Page 373 
1 
A. We have followed up on eases. 
2 
Q. Is there anyone that you remember in the lest 
3 
five years that lives in Palm Beach, owns a house on 
4 
Palm Beach, had a escort or masseuse come to their home 
5 
and got prosecuted? 
6 
MS. ARBOUR: Fenn. 
7 
THE WIINESS: We have had instances where 
8 
officers have encountered escorts leaving the 
9 
residences of certain residents in the Town of Palm 
10 
Beach. They were documented on an intelligence 
11 
report and we would follow up on it the following 
12 
day or the day after. We go to their house and 
13 
identify what escort services, and we have done 
14 
stings, reverse stings where we contact the escort 
15 
services. 
16 
BY MR. WEINBERG: 
17 
Q. But in those cases, you would be investigating 
18 
the escorts, not the escortee or not the john? I'm not 
19 
trying to be difficult 
20 
A. No, no, no. Pm just —
21 
Q. The fact is that in the last five years —
22 
A. Pm eying to give you, you 'mow, examples. 
23 
Q. You've investigated for businesses that have 
24 
engaged in prostitution, but you have not, to your 
25 
memory, arrested any citizen of Palm Beach for inviting 
Page 375 
1 
Q. Go back to several areas that we didn't 
2 
complete. Back to this witness list that you saw in 
3 
Chief Reiter's office and that Chief Reiter represented 
4 
to you he was under a directive to destroy, do you know 
5 
whether or not a copy of that list was made so that it 
6 
would be available in the event there was a public 
7 
records request? 
8 
A. I don't believe so. 
9 
Q. Do you know whether or not the directive to 
10 
destroy was given in anticipation of the public records 
11: 
request? 
12 
A. That, I don't 'mow. 
13 
Q. Would that document have been within the 
14 
response to a public records request? 
15 
MS. ARBOUR: Object to form. 
16 
BY MR. WEINBERG: 
17 
Q. If you know. 
18 
A. I have no idea. 
19 
Q. And if that document became part of the case 
20 
file of the investigation or prosecution of Epstein, it 
21 
would be suhjcct to a public records request, at least 
22 
according to what you know about public records, 
23 
correct? 
24 
MS. ARBOUR: Form. 
25 
THE WITNESS: If it was submitted into 
AC•••••.• 
15 (Pages 372 to 375) 
PROSE COURT REPORTING AGENCY,' INC. 
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Electronically signed by Jeana Ricciutl (601 
c60626374130-46264130-bc814•314d7a 
EFTA00298227

Page 376 
, 
Page 378 
I 
evidence or the attachment file. 
1 
Q. Yes, for sexual conduct occurring between two 
2 
BY MR. WEINBERG: 
• 
2 
consenting human beings at a restaurant — at a 
3 
Q In terms of your memory dating back five 
3. 
residence. 
• 
4 
years, I asked you about whether you recalled any 
 
4 
MS. ARBOUR: Fenn. 
5 
resident of Palm Beach being arrested for the we or the 
5 
THE WITNESS: That I can recall. 
6 
misuse of an escort or massage service, correct? 
6 
BY MR. WEINBERG: 
7 
A. Correct. 
7 
. Back to Ms... She was invited there by 
8 
Q. And your best manory was that you recall there 
8 
M., correct? 
9 
was one such incident, correct? 
9 
A. I believe so, yes. 
10 
A. Correct. 
10 
Q. If you believe Ms..., Ms... deceived her 
11 
Q. And you do recall investigations of 
11 
as to the purpose of her going there, correct? 
12 
prostitution businesses, do you not? 
12 
A. She was going to go there to model is what I 
13 
A. Yes. 
13 
recall. 
14 
Q. And investigations and escort or massage 
14 
Q. And.., to your knowledge, had previously 
15 
businesses that you expected or had reason to believe 
15 
gone to Mr. Epstein's residence with other people? 
16 
were prostitution businesses, correct? 
16 
A. I believe so. 
17 
A. Correct. 
17 
Q. And those other people ended up giving a 
18 
Q. AM those investigations would be oriented 
18 
massage to Mr. Epstein? 
19 
towards targeting the people that made money from the 
19 
A. I believe so. 
20 
sale of sex, correct? 
20 
Q. And none of those people that M. brought to 
21 
A. Correct 
21 
Mr. Epstein's residence later represented to you that 
22 
Q. On the flip side, when I asked you about 
22 
M. said that the only object of the visit was to 
23 
residents of Palm Beach, twos asking you about people 
23 
model; is that correct? 
24 
that would be known as johns, correct? In other 
24 
A. Repeat that one more time. 
25 
words — 
25 
Q. The other people that you interviewed who said 
Page 377 
Page 379 
1 
MS. ARBOUR: Form. 
1 
that Ms... brought them to Mr. Epstein's residence, 
2 
BY MR. WEINBERG: 
2 
did not also tell you that they had gone there under a 
3 
Q. — the customers of a prostitution business. 
3 
false impression, correct? 
4 
MS. ARBOUR: Same. 
4 
A. Ica& recall. 
5 
771E WITNESS: Correct. 
5 
Q. If it's in your incident report —
6 
BY MR. WEINBERG: 
6 
A. It would be in there. 
7 
Q. And the same question, you recall only one 
7 
Q. — they told you, and if its not in there, 
8 
person who resides in Palm Beach who was prosecuted for 
8 
then these different individuals were representing to 
9 
being a customer of a prostitution business using them 
9 
you that they knew that they were going there to give 
10 
to come to his borne, correct? 
10 
Mr. Epstein a massage? 
11 
A. I believe so. 
11 
A. Right, it would have been in the re 
12 
Q. Do you recall the name of that person? 
12 
Q. Now, none of the women that Ms. M. invited 
13 
A. Not off the top of my head. 
13 
to meet Mr. Epstein ever told you that they went there 
14 
Q. Take it back ten years, do you recall any 
14 
for any purpose other than to give him a massage, 
15 
second such prosecution of a residence of Palm Beach for 
15 
correct? 
16 
ming the services of a prostitution or massage or 
16 
MS. ARBOUR: Object to form. 
17 
escort business? 
17 
THE WITNESS: I believe so. 
18 
A. Again, we do hold stings in certain hotels, 
18 
BY MR. WEINBERG: 
19 
the Breakers, the Four Seasons, the Marriott, where 
19 
Q. And Ms. 
El. to Mr. Epstein 
20 
women and men both go to the bars and solicit. 
20. 
%introduced 
according to what 
told you on January 9, 2006, 
21 
Q. But in terms of private residences, in your 
21 
correct? 
22 
entire professional life on the Palm Beach Police 
22 • 
A. Correct 
23 
Department, you only recall one such arrest and 
23 
lil?And Ms. • 
told
 that Mr. Epstein, 
24 
prosecution, correct? 
24 
Ms. M. and Mr. [sic] M. had a conversation at 
25 
A. At a residence? 
25. ' 
Mr. Epstein's house, correct?. 
16 (Pages 376 to 379) 
PROSE COURT REPORTING AGENCY, 'INC. 
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Page 380 
Page 382 
1 
A. I believe so. 
1 
A. Yes. 
2 
Q. And then Ms... told you that both Ms. 
2 
Q. And Ms... removed her pants and blouse, 
3 
and Mr. Epstein brought her upstairs into a master 
3 
correct? 
4 
bedroom area, correct? 
4 
A. Correct. 
5 
A. Yes, if it's in the report, that's... 
5 
Q. And she didn't say that she tried to run out 
6 
Q. And then Ms. M. observed a large massage 
6 
and couldn't get away or anything like that; is that 
7 
table with a sheet on it; is that your memory that 
7 
right? 
8 
Ms. M. told you that she, after meeting Mr. Epstein, 
A. Correct. 
9 
she went upstairs to an area of Mr. Epstein's home where 
Q. Otherwise, those kind of statements would be 
10 
there was a massage table? 
10 
clearly incorporated into this probable cause affidavit, 
11 
A. I believe so. 
11 
right? 
12 
Q. And did she tell you that Mr. Epstein came 
12 
A. Correct. 
13 
into that area wearing a towel, and that Ms. 
13 
Q. Because the affidavit was designed to persuade 
14 
informed Ms. M. they were going to provide Mr. Epstein 
14 
a judge that there was sufficient evidence to charge 
15 
with a massage? 
15 
Mr. Epstein and others with criminal offenses against 
16 
A. I believe so. 
16 
the State of Florida. 
17 
Q. And that when 
asked M. why they were 
17 
A. I wouldn't say persuade, but I would state the 
18 
doing this, 
explained to 
that they were going 
18 
facts. 
19 
to rub Ins calves and feet? 
19 
Q. And the purpose of stating the facts was to 
20 
A. I believe so. 
20 
fill out what you concluded was probable cause to 
21 
Q. And that Ms. M. didn't leave the massage 
21 
warrant the State Attorney from prosecuting Mr. Epstein 
22. 
area at this time, according to her statement to you; is 
.22 
fora criminal offense? 
23 
that right? 
23 
A. Correct. 
24 
A. Right. 
24 
Q. And this was done by you on May I, 2006, 
25 
Q. Then Ms. M. told you that she began to 
25 
correct? 
Page 381 
Page 383 
1 
partiate in this massage with Mr. Epstein and 
1 
A. Correct. 
2 
Ms. MI, correct? 
2 
Q. When matters were relatively fresh as 
3 
A. I believe so. 
3 
contrasted to how they are in April of 2010? 
4 
Q. And that Mr. Epstein asked her to get 
4 
A. Yes. 
5 
comfortable, do you recall that? 
5 
Q. And when you prepared this problem cause 
6 
A. I believe so. 
6 
affidavit, you were largely relying on your supplemental 
7 
Q. And that Nis... elected to take off her 
7 -
reports in the omnibus Palm Beach incident report, 
clothes leaving on only her pants; is that correct or 
8 
correct? 
9 
panties? 
9 
A. Correct 
10 
Do you want to read this? 
10 
Q. And you were not relying to your current 
11 
A. If you don't mint 
11 
memory on any tape recording of this statement on 
12 
Q. This is page 20 of E:dtibit I, which is 
12 
January 9th with Ms. M., were you? 
13 
Detective Reearey's — 
13 
A. A tape recording? 
14 
MR. PIKE: If you would, could you please turn 14 
Q. Yes. 
15 
to that page because there's some writing on this 
15 
A. Like I said, I have reviewed tape recordings 
16 
one and I don't want to —
16 
that I've conducted on interviews. 
17 
MR. WEINBERG: This is not the incident 
17 
Q. Which ones did you listen to before you 
18 
report This is the probable cause affidavit 
18 
executed an affidavit on May I st? 
19 
MS. ARBOUR: I have an extra one, I think. 
19.
A. I couldn't tell you. 
20 
MR. WEINBERG: Thank you. 
20 
Q. Would you have a note, record, diary, 
21 
BY MR. WEINBERG: 
21 
reference — 
22 
Q. Were on page 20, about five or six lines 
22 
A. No. 
23 
down. In paragraph I, Epstein told Ms. M. to get 
23 
Q. — any way to construct which ones you 
24 
comfortable. Actually, its seven lines down on the 
24 
listened to? 
25 
left side, page 20. 
25 
A. No. 
17 (Pages 380 to 383) 
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Page 384 
1 
Q. Tape recordings would, of course, be the most 
2 
reliable predicate for what, in fact, a witness told 
3 
you, correct? 
4 
MS. ARBOUR: Object to form. 
5 
BY MR. WEINBERG: 
6 
Q. But they are also longest to wade through. 
correct? 
MS. ARBOUR: Form 
9 
BY MR. WEINBERG: 
10 
Q. In other words, they take more time to hear 
11 
than reading a summary would take to read? 
12 
MS. ARBOUR: Same objection. 
13 
THE WITNESS: As far as, like, if you heard 
14 
it? 
15 
BY MR. WEINBERG: 
16 
Q. Yes. It would take you however many hours —
17 
A. Right, depending on the length of the 
18 
interview. I mean, some could have been an hour, some 
19 
could have been two hours. 
20 
Q. How long was the lengthy one, if you remember?. 
21 
A. I believe it was — it would have been over an 
22 
hour. She was still in high school and she had to get 
23 
back. 
24 
Q. But you have no memory that you, in fact, 
25 
listened to Ms. 
tape at or before the time you 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 386 
A. I may have listened to Ms. Jane Doc 103's 
interview while I was doing the supplement. 
Q. But you have no memory as you sit here now 
that you listened to it in the last days of April or 
around May 1, 2006, before summarizing the recitation by 
Ms. Jane Doe 103 into this probable cause affidavit, 
correct? 
A. If I listened to it prior to writing the PC? 
is that what you're asking me —
Q. Yes. Yes. 
A. — if I listened to it prior to writing the 
Q. Yes, prior to. 
A. No, I can't recall if I did or didn't. 
Q. And I'll ask the same questions regarding your 
preparation of the search warrant affidavit. You had 
tape recordings available to you, did you not? 
A. Yes, I did. 
Q. This investigation generated approximately 22 
tapes? 
A. Approximately. 
Q. Most of which were generated before 
October 18, 2005 when you authored an affidavit setting 
to search Mr. Epstein's private residence, correct? 
A. Correct 
Page 385 
1 
summarized your memory of your conversations with her 
2 
into this affidavit on May 1st, correct? 
3 
A. I can't say if I did or didn't. 
4 
Q. And the same thing with 
do you recall 
5 
whether or not that was one of the tapes you listened to 
6 
before summarizing what she had said to you in October 
7 
of 2005 into this probable cause affidavit? 
8 
A. M.'s was different. M.'s was a videotape 
9 
conducted at the Palm Beach Police Department. 
10 
02Did you watch and listen to the videotape of 
11 
the M. interview? 
12 
A. I may have. 
13 . 
Q. But you don't recall which ones you didn't or • 
14 
did, correct? 
15. 
A. Correct. 
16 
Q. And same with Jane Doe 103, October II, 2005, 
17 
interview in Tallahassee, that was tape recorded, was it 
16 
not? 
19 
A. Yes, it was. 
20 
Q. The telephone call the day before was not tape 
21 
recorded; is that correct? 
' 
22 
A. I may have recorded that one. 
.23 . 
Q. .Do you recall whedier.you listened to either 
• 
24. • 
or both of those tape recordings prior to executing the 
25 
May 1, 2006 affidavit? 
Page 387 
1 
Q Did you listen to all of those tape recordings 
2 
prior to drafting an affidavit that was intended to 
3 
result in the judicial authorization of a search and 
4 
seizure of Mr. Epstein's residence? 
A. I may have, as I was doing my supplements. 
6 
Q. Pm directing myself towards the time period 
7 
when you were drafting the affidavit that was going to 
8 
be filed with the judge to ask for permission to search 
9 
Mr. Epstein's residence. 
10 
Did you listen to those tapes contemporaneous 
11 • 
with your authoring the search warrant affidavit? 
12 
A. I can't recall if f did or didn't. 
13 
Q. If you did, would there be any note, report, 
14 
log entry that you did? 
15 
A. Not that I've kept am, no. 
16 
Q. You don't have a current memory of being at a 
17 
typewriter typing in your affidavit fora search 
18 
warrant --
19 
A. We don't utilize a typewriter, but — 
20 
Q. A computer? 
21 
A. A computer. 
22 
Q. It shows my age. 
23 
You typed into a computer the affidavit that 
24 
ultimately went to a judge to --
25 
A. Correct 
(561)—832-7.500 
18 (Pages 384 to 387) 
PROSE COURT REPORTING AGENCY,'INC. 
• S 
Electronically signed by Jeana Rice-lug (601 
Electronically signed by Jeana Riccluti (601 
c5062637-abet -452c-a836-bc614e314d7a 
EFTA00298230

Page 388 
1 
Q. 
seek authority to search Mr. Epstein's 
2 
home? 
3 
A. Correct. 
4 
Q. And you did that in your office? 
5 
A. Yes. 
6 
Q. And in your office, is there a tape recorder? 
7 
A. Yes, we do have tape recorders. We have —
8 
Q. And you had access to the tape recordings of 
9 
the witness interviews, did you not, at the time? 
10 
A. Yes. 
11 
Q. And you don't recall today whether or not you 
12 
listened to any or. all of them at or around the time 
13 
that you drafted the search warrant affidavit? 
14 
A. I can't recall if I did or didn't 
15 
. 
Q. Your best memory is that you relied on the 
16 
supplemental reports authored by you as the predicate 
17 
for what you represented to 'judge warranted his 
• 
18 
authorizing a search and seizure of Mr. Epstein's 
19 
property, correct? 
20 
A. Correct 
21 
Q. Back to Ms... This is the first time she 
22 
was at Mr. Epstein's home that she was telling you about 
23 
on January 9th, correct? 
24 
A. Yes. 
25 
Q. And she ultimately told you about two 
Page 390 
1 
Q. And Ms. M. said she started to nib 
2 
Mr. Epstein's 'chest; is that correct? 
3 
A. Yes. 
4 
Q. AM that's in addition to what she had been . 
5 
told, which is that she and Ms. M. were going to rub 
6. 
his calls and feet; is that right? 
7 
A. Correct. 
8 
Q. And she didn't say at this time that she in 
9 
any way was being forced or coerced into giving 
10 
Mr. Epstein a massage, correct? 
11 
A. Correct. 
12 
Q. Mr. Epstein, according to her recollection, 
13 
began to masturbate; is that right? 
14 
A. Yes, as he stroked her vagina. 
15 
Q. But she told you that Mr. Epstein was touching 
16 
her breast and touching her vagina; is that correct? 
17 
A. Correct. 
18 
Q. And she didn't tell yon she protested or 
19 
objected to such touching, did she? 
20 
A. No. 
21 
Q. Because it would be in your report? 
22 
A. It would be in the report if it did. 
23 
Q. And she then told you that she was paid $200 
24 
for the massage, correct? 
25 
A. Correct. 
Page 389 
1 
occasions that she went there; is that correct? 
2 
A. I believe so. 
3 
Q. And she, in fact, went back a third time, did 
4 
she not? Did she not? 
5 
A. I can't recall whether she — how many times 
6 
she went without looking at it. 
7 
Q. Let's first look at what's in front of you, 
8 
which is the probable cause aflidaviL She removed her 
9 
pants and blouse, correct? 
10 
A. Correct. 
11 
Q. And that was a voluntarily act on her part in 
12 
response to Mr. Epstein telling her to getting 
13 
comfortable, correct? 
14 
A. Correct. 
15 
Q. And that she stayed only in panties because 
16 
she didn't have a bra on that evening, correct? 
7 
A. Correct. 
18 
Q. So she took off her shirt and, therefore, was 
19 
naked froni the waist up; is that right? 
• 
20 
A. Correct 
21 
Q. AM Ms... was still there; is that right? 
22 
A. (Non-verbal response). 
23 
Q. And the two of them were massaging 
24 
Mr. Epstein? 
25 
A. Yes. 
Page 391 
1 
Q. And she was tearful, at least during parts of 
2 
this interview; is that correct? 
3 
A. Correct. 
4 
Q. But she didn't tell you that she refused the 
5 
$200, correct? 
6 
A. Right. 
7 
Q. And she didn't tell you that she was so 
8 
tranwiatizni injured or damaged by this incident that 
9 
she didn't voltmtarily return several days later, 
10 
coned? 
11 
A. I'm sorry, one more time. 
12 
Q. She didn't tell you that she was traumatized 
13 
by this event at the time it occurred, did she? 
14 
A. I don't recall her saying that she was 
15 
traumatized. 
16 
Q. Or in any way injured because she, infect, 
17 
was Invited to return and did return several days later 
18 
alone; is that right? 
19 
A. I believe so. 
20. . 
In other words, she told you, if you recall, 
21 
that she received several days later a telephone call 
22 
from la 
is that correct? 
23. 
. A. Correct. . 
24 
Q. And who essentially invited for to conic back, 
25 
correct? 
PROSE COURT REPORTING AGENCY, 
Electronically signed by Jeana Ricclutl (MI 
Electronically signed by Jeana Ricdutl (401 
19 (Pages 388 to 391 
INC. 
c5062637.abol-462c-a836-bc614e31ed7a 
EFTA00298231

Page 392 
Page 394 
1 
A. Right, to work. 
2 
Q. And this time, she wasn't with 
M
.
 
?
 
3 
A. Yes. 
4 
Q. AM she elected to return to Mr. Epstein's 
5 
house, this time knowing that it was not to model 
6 
lingerie? 
7 
A. Correct. 
8 
Q. And in fad,
 went back on her own as a 
9 
response to Ms. 
inviting her to give Mr. Epstein 
10 
a second massage? 
11 
A. Correct. 
12 
Q. And again, Mr. Epstein — she went upstair to 
13 
Mr. Epstein's bedroom area and gave Mr. Epstein a 
14 
massage, correct? 
15 
A. Correct. 
16 
Q. And again, she was paid for that massage, 
17 
correct? 
18 
A. Correct. 
19 
Q. And she didn't, between the dates of these tvio 
20 
massages and the date you went to her house on 
21 
January 9, 2006, or went to her school, she didn't call 
22 
you or didn't ask her parents to call you to complain 
23 
about the conduct that occurred at El Brillo, correct? 
24 
A. Correct. 
25 
Q. Now, if we switch for a second from your 
1 
If we start on 73 since it's redacted, I 
2 
want to assure you I'm talking about what I believe to 
3 
be the same interview on January 9, 2006. Paragraph 3 
4 
is. 
telling you she was told she could model 
5 
lingerie, and then much of the same right up to the last 
6 
sentence where she stated she went to Mr. Epstein's 
7 
house three or four times total. 
8 
- 
A. Right. 
9 
Q. And then on the next paragraph, she was 
10 
telling you that she once brought a friend? 
11 
A. Correct. 
12 
Q. Some of the young women told you they were 
13 
terribly upset while talking to you; is that correct? 
14 
A. Correct. 
15 
Q. And they had a variety of reasons to be upset, 
16 
didn't they? 
17 
MS. ARBOUR: Form. 
18 
BY MR. WEINBERG: 
19 
Q. To your knowledge. 
20 
A. To my knowledge, yeah, absolutely. 
21 
Q. One thing is that some of the women yawere 
22 
interviewing, for instance Ms... and Ms. M., twit: 
23 
actively bringing third parties to visit Mr. Epstein; k 
24 
that correct? 
25 
MS. ARBOUR: Form. 
1 
2 
3 
4 
5 
6 
7 
8. 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 393 
affidavit to your incident report, do you recall that 
she went back a third time and brought a friend a third 
time? 
A. I believe — I believe she may have brought 
someone. 
Q. AM do you recall who she brought? 
A. Not off the top of my head, no. 
Q. AM do you recall writing on page 74 of your 
incident report that she once brought a friend, and she 
said that she didn't know the last name, to give 
Mr. Epstein a massage and that she was paid $200 for 
. 
bringing a friend? 
A. !can't readL 
Q. Perhaps you can read page 74 and see if that 
refreshes your recollection. 
A. Page 74? 
Q. Yes. 
Just to orient you, it's her interviews with 
you start on page 73. The first of January 9, 2006. 
There's some redactions, but if you refer to 
paragraph 3, you'll sec that she was the person who told 
you she could model lingerie and then it continues.
A. I think your 74 is different than this 74. 
Q. We have different reports? May I sec yours 
for a second? 
1 
THE WITNESS: Correct. 
2 
BY MR. WEINBERG: 
3 
Q. And being paid for it? 
4 
MS. ARBOUR: Fa 
5 
TIIE WITNESS: Yes. 
6 
BY MR. WEINBERG: 
7 
Q. And that constitutes a violation of the 
8 
Florida statutes, does it not? 
9 
MS. ARBOUR: Form. 
10 
THE WITNESS: For unlicensed massages or... 
11 
BY MR. WEINBERG: 
12 
Q. For any and — I mean, did you believe that 
13 
you threatened Ms... with a criminal prosecution, did 
14 
you not, when she was videotaped on October 5, 2005 
15 
being interviewed? 
16 
MS. ARBOUR Form. 
17 • 
THE WITNESS: I didn't threaten Ms..., but 
18 
I did explain to her that what she did was illegal. 
19 
BY MR. WEINBERG: 
20 
Q. Was illegal? 
21 
A. Right 
.22 
Q. And similarly, what Ms... did was illegal? 
23 
• 
MS. ARBOUR: Fain.. 
24 
• BY MR. WEINBERG: 
25 
Q. In your mind. 
20 (Pages 392 to 395) 
PROSE. COURT REPORTING AGENCY, INC." 
Electronically signed by Jeans Medlin (601 
Electronically signed by Jeans Riccluti (601 
e6082637-abel-48204836-be614•314dra 
EFTA00298232

Page 396 
MS. ARDOUR: Same objection. 
2 
THE WITNESS: Pretty much. I mean, you 
3 
4 
BY MR. WEINBERG: 
5 
Q. Did you ever conduct a criminal investigation 
6 
of Ms. M.? 
7 
A. No. 
8 
Q. Did you ever conduct any followup 
9 
investigation of Ms... when she declined to speak to 
10 
you? 
11 
A. No. 
12 
Q. To your knowledge, did you or anyone else in 
13 
the Palm Beach Police Department have any contact with 
14 
Ms. 
M
.
 
during the time period of this investigation 
15 
which began in March of '05 and ended in December of 
16 
'06? 
17 
A. I spoke to her that one time and didn't speak 
18 
to her again. 
19 
Q. Eva seen a report from anyone else in Palm 
20 
Beach that ever spoke to her? 
21 
A. I don't believe anyone else spoke with her.' 
22 
Q. And you did no background on her to your best 
23 
recollection in terms of her character, her reputation, 
24 
her credibility, correct? 
25 
A. No. 
Page 398 
1 
to her and her father that she had lied to her father 
2 
about her visit with Mr. Epstein, correct? 
3 
A. Again, I don't know if she lied to her father. 
4 
I know she went there originally with the intentions to 
5 
model. 
6 
Q. But she never told her father she had been 
7 
paid for topless massages, comet? 
8 
A. Not to my knowledge. 
9 
Q. And her father told you what he knew of what 
10 
she had done or not done with Mr. Epstein, collect? 
11 
A. As far as he knew, yes. 
12 
Q. And clearly, there was at least a lie by 
13 
omission from Ms. M. to the father or the father to 
14 
you, correct, because Ms.. was telling you she did 
15 
far more than her father told you she did? 
16 
A. Yes. 
17 
Q. And she was not the only minor that you 
18 
interviewed, correct? 
19 
A. Correct. 
20 
Q. And therefore, Mr. I was not the only parent 
21 • 
that you had occasion to say that you were doing an 
22 
investigation in which their daughter was either a 
23 
witness or a victim, coned? 
24 
A. Correct. 
25 • 
Q. And you know, from having conducted followup 
8 
9 
10 
1/ 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
.24 
25 
Page 397 
Q. Likewise, Ms. 
did you do any background 
to determine whether she was a credible, trustworthy, 
reliable source of information about Mr. Epstein? 
A. Based on the sworn taped statement that I took 
of Ms. M., I mean, she had specific knowledge as to 
persons within the home, descriptions of the home, 
within the home, within the bath — you know, the 
bedroom, the bathroom area. 
Q. But she was telling you, was she not, that she 
was emotionally — had emotional consequences to what 
she did; is that right? She was crying at different 
times she was talking to you; is that right? 
A. Absolutely. 
Q. And several of the girls did; is that right? 
A. Absolutely. 
Q. And one of the realities were that their 
parents were fording out what happened, correct? 
A. Yes, in some of the victims, yes, the parents 
did find out. 
Q. And that was traumatizing to them, was it not? 
MS. ARBOUR: Fonn. 
THE WITNESS: I'm sure it was embarrassing for 
than, yes. 
BY MR. WEINBERG: 
Q. In fact, with 
it was becoming clear 
Page 399 
1 
and interviews, that parents learned a lot more as a 
2 
result of your visits than they had learned beforehand 
3 
regarding what had occurred between their daughters and 
4 
Mr. Epstein, correct? 
5 
MS. ARBOUR: Pam. 
6 
THE WITNESS: Right. 
7 
BY MR. WEINBERG: 
8 
Q. And that you also knew that sane of the tears 
9 
that were being shed were being shed by the girls 
10 
because suddenly their parents were involved, correct? 
11 
MS. ARBOUR Form 
12 
THE WITNESS: I don't know if the tears were 
13 
because the parents were involved. I know that 
14 
there was a lot of shame, a lot of embarrassment 
15 
BY MR. WEINBERG: 
16 
Q. A lot of fear, fear of school? 
17 
MS. ARBOUR: Form. 
18 
THE WITNESS: I know, in Ms. 
case, 
19 
she was in fear of Mr. Epstein. 
20 
BY MR. WEINBERG: 
21 
Q. And do you know in Ms. 
case she was 
22 
also in fear of her school friend in that which she had 
23 
done? 
24 
Let's step back a step. What she had done is 
25 
she had gotten money for a sexual massage, correct? 
21 (Pages 396 to 399) 
PROSE COURT' REPORTING AGENCY, INC. 
Electronic/By signed by Jeans Rleekel PM= 
Electrote signed by Jeans Rlcdutl (401 
c6062637,41301-462e4a136-bc614•31467a 
EFTA00298233