EFTA00298259

Page 74 
1 
a Heidi Fleiss. At that point it was the madam 
2 
over in, I guess, in California 
3 
MR. KUVIN: Okay. 
4 
THE WITNESS: 
that provided girls to 
5 
potential clients. 
6 
BY MR. KUVIN: 
7 
Q. And the potential client in this case 
8 
would have been? 
9 
A. Mr. Epstein. 
10 
Q. Okay. 
11 
MR. PIKE: Form and move to strike. 
12 
BY MR. KUVIN: 
13 
Q. All right. When was the first time that 
14 
you spoke with any other potential victims? 
15 
MR. PIKE: Form. 
16 
BY MR. KUVIN: 
17 
Q. So, now just so I can understand the 
18 
timeline, up to this 
int we have been discussing 
19 
you knew 
a potential victim. You 
20 
talked to 
What is the next potential 
21 
victim you learn about? 
22 
MR. PIKE: Form. 
23 
WITNESS: During the interview with 
24 
li
Eshe explained, she gave us additional 
25 
names of people that she brought to the house. 
1 
2 
3 
4 
5 
6 
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Page 76 
THE WITNESS: Correct 
BY MR KUVIN: 
Q. So, as best as you can recall, were there 
four people that she identified? 
MR. PIKE: Form. 
THE WITNESS: Yes. 
BY MR. KUVIN: 
Q. And why would you reference the date of 
birth? What is the importance of that? 
A. Indicate their age. 
Q. Okay. And why would it be blacked out if 
you know? 
MR. PIKE: Form. 
THE WITNESS: At that point they were 
minors. 
BY MR. KUVIN: 
Q. Okay. If we turn to Page 31 of the 
incident report for a moment. This is the first 
reference I could see to a rental car company. So 
let me ask you this: At some point did you learn 
any information regarding the use of rental cars and 
transporting girls or women to Mr. Epstein's home? 
MR. PIKE: Form. 
THE WITNESS: Yes. 
Page 75 
MR. KUVIN: Okay. 
2 
THE WITNESS: We identified some with her 
3 
assistance of where they reside. 
MR. KUVIN: Okay. 
THE 
S: That night after we dropped 
6 
off Ms. air 
her home, we began to attempt 
to contact some of these girls that have been 
to his house. 
9 
BY MR. KUVIN: 
10 
Q. All right. And just so we're clear, if 
11 
you turn back to Page 29 of your incident report in 
12 
the center of the page, once we get an unredacted 
13 
copy we will know, but for reference sake, do you 
14 
see in the second paragra
wn where it says: 
15 
"With the assistance of 
we were able to 
16 
identify.* Do you see that, and there is a whole 
17 
bunch of black? 
18 
A. Yes. 
19 
Q. Okay. It appears, and correct me if I am 
20 
wrong, that there is one name with a date of birth, 
21 
both blacked out; a second name with a date of birth 
22 
blacked out; a third name with a date of birth 
23 
blacked out; and a fourth name with the date of 
24 
birth blacked out? 
25 
MR. PIKE: Form, 
Page 77 
1 
BY MR. KUVIN: 
2 
Q. Tell us about that. 
3 
A. Dining the investigation it was determined 
4 
that one of the girls had a rental car. 
5 
Q. Do you remember which one? 
6 
A. From Dollar, Dollar Rent-A-Car. 
7 
Q. Okay. Do you remember which girl? 
8 
A. I believe it was lane Doe No. 4. 
9 
Q. Okay. And did you determine how she 
10 
obtained the rental vehicle? 
13. 
MR. PIKE: Form. 
12 
THE WITNESS: Records were subpoenaed to 
13 
Dollar to determine from the rental coritract, 
14 
and the rental car was being paid for by 
15 
Mr. Epstein. 
16 
BY MR. KUVIN: 
17 
Q. Okay. And at the time was lane Doe No. 4 
18 
a minor? 
19 
NIB. PIKE: Form. 
20 
THE WITNESS: I believe at this time she 
21 
had started in the university, so I am not 
22 
100 percent certain as to her age at that 
23 
particular moment. 
24 
BY MR. KUVIN: 
2 5 
Q. All right. Let's 
down to the bottom of 
Kg. 
20 (Pages 74 to 77) 
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Page 78 
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Page 31. At some point there is an additional trash 
2 
pull done, and a U.S. Airways boarding pass is 
3 
obtained. Do you see that? 
4 
A. Yes. 
5 
Q. There is a name there Janusz Barrasiak? 
6 
A. Janusz, yes. 
7 
Q. Did you determine who that individual was 
8 
at any point during the investigation? 
9 
A. He was Mr. Epstein's houseman at the time. 
10 
Q. Okay. And there is another person that's 
11 
listed there. Who else was listed on a note paper? 
12 
A. Oh, Ohislaine Maxwell. 
13 
Q. Did you determine who she was? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: She's Mr. Epstein's friend. 
16 
MR. PIKE: Form, move to strike. 
17 
BY MR. KUVIN: 
18 
Q. How did you determine that? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: Through the media, online, 
21 
online resources. 
22 
BY MR. KUVIN: 
23 
Q. All right. Let's go down now to Page 32, 
24 
just so I can clarify this as well and find out what 
25 
this was. It says: "While sifting through Epstein's 
• 1 
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8 
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10 
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13 
14 
15 
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18 
19 
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24 
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Page 80 
A. It's when it gets inputted. 
Q. I hear you. If we go to 
next 
page, there is a preference to a ii.
eWho is 
that? 
MR. PIKE: Form. 
THE WITNESS: Not 100 percent certain. 
BY MR. KUVIN: 
Q. There is a reference to an MSN Hotmail 
le 
record,
@hormail.com. Do you 
see that? 
A. Yes. 
Q. Did you determine whose e-mail address 
that was during the investi 
'on? 
A. That was 
Q. And who was she? 
MR. PIKE: Form 
BY MR. KUVIN: 
Q. if you know. 
MR. PIKE: Same objection. 
THE WITNESS: I believe she was an 
employee. 
MR. PIKE: Move to strike. 
BY MR. KUVIN: 
Q. Was she a minor at the time, do you Imow? 
Page 79 
1 
trash, I also collected a three-inch purple finger 
2 
size object which had a broken end. The object 
3 
appeared to be a broken piece from a sexual toy 
4 
similar to a Cyclone vibrator possibly used for 
5 
rectum gratification." The evidence was placed in 
6 
bio-hazard bag with possible body fluids. 
7 
MR. PIKE:. Form. 
' 8 
BY MR. KUVIN: 
9, 
Q. At any time did you determine what that 
10 
particular piece of evidence was, whether, in fact, 
11 • 
it was a sexual toy? 
12 
A. I believe that that was the initial discovery 
13 
of the purple handle. That was the initial discovery of 
14 
it as this was, this is not chronological. 
15 
Q. This is going back, it looks if we go back 
16 
up to the paragraph on April I of 2005? 
17 
THE WITNESS: Correct. 
18 
. 
MR. KUVIN: Gotcha 
19 
MR. PIKE: Form. 
20 
' BY MR. KUVIN: 
21 
Q. This is what we were referring to before 
22 
in the beginning? 
23 
A. Yes. 
24 
' Q. Gotcha. it would help if you guys did 
25 
this in chronological order. 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 81 
MR. PIKE: Form. 
THE WITNESS: I don't believe so. 
BY MR. KUVIN: 
Q. Do you know how old she was? 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. Did you ever determine how old she was? 
MR. PIKE: Same objection. 
THE WITNESS: She was identified but I 
can't recall her age. 
BY MR. KUVIN: 
Q. All right. if we go to the next page, 
Page 34 references a phone contact you had on 
October 4 of 2005. Do you see that? 
A. Yes. 
Q. Do you recall who that was that called you 
back? 
A. I could see her face. I am just trying to 
think of her 
e. 
Q. %sit 
A. No. It was not.. It was. III 
• MR. PIKE: Pm sorry. What page and 
reference are we reading from? 
MR. KU VIN: Page 34, first paragraph. 
21 (Pages 78 to 81) 
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Page 82 
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BY MR. KUVIN: 
2 
. Q. Arawas under the age of 18 at the 
3 
time? 
4 
MR. PIKE: Fonn. 
5 
THE WITNESS: Correct. 
6 
BY MR. KUVIN: 
7 
Q. Do you know how old she was back on 
8 
October 4 of 2005? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: Ilatow she was still in high 
11 
school. I can't recall exactly her age. 
12 
BY MR. KUVIN: 
13 
Q. Okay. Did she describe to you whether or 
14 
not she was taken to Mr. Epstein's home? 
15 
MR. PIKE: Form. 
16 
THE WITNESS: Yes. 
17 
BY MR. KUVIN: 
18 
Q. What did she describe occurred when she 
19 
went to his home? • 
20 
MR. PIKE: Form. 
21 
BY MR. KUVIN: 
22 
Q. And just so we're clear, let me back up. 
23 
Was she describing this to you? 
24 
A. Correct. 
25 
Q Okay. 
Page 84 
1 
believe the following morning I received a 
2 
telephone call from her stating that she was 
3 
not being 100 percent truthful with me when I 
4 
first spoke with her. 
5 
MR KUVIN: Okay. 
6 
THE WITNESS: And at which point she 
7 
described that she had been to Mr. Epstein's 
8 
home. 
9 
BY MR. KUVIN: 
10 
Q. All right. When she described this to 
11 
you, mild you describe for us whether or not she 
12 
explained to you her mental state or her emotions 
13 
about this entire process? 
14 
MR. PUCE: Form. 
15 
THE WITNESS: From what lrecall I believe 
16 
she was, she was crying. She was upset. 
17 
MR. PIKE: Form, move to strike, 
18 
nonresponsive. 
19 
BY MR. KUVIN: 
20 
Q. Did she appear emotional during that 
21 
conversation you had with her? 
22 
A. Yes. 
23 
Q. Did she appear upset about the incident 
24 
that she was describing? 
25 
MR. PIKE: Form. 
Page 83 
1 
MR. PIKE: Form. Still hearsay. 
2 
BY MR. KUVIN: 
3 
Q. And this conversation occurred between you 
4 
and her, yes? 
5 
A. Yes. 
6 
MR. PIKE: Form. 
1 
BY MR. KUVIN: 
Q. During the investigation itself, correct? 
9 
Mft. PIKE: Font 
10 
THE WITNESS: Correct. 
11 
BY MR. KUVIN: 
12 
Q. Okay. At this poim this was a police 
13 
investigation to determine whether or not there 
14 
should be charges brought against Mr. Epstein? 
15 
A. Correct. 
16 
MR. PIKE: Form. 
17 
BY MR. KUVIN: 
18. 
Q. Okay. All right. What did she describe? 
19 
MR. PUCE: Form. 
20 
THE WITNESS: Well, the initial 
21. 
conversation I had with her, she had advised 
22 
that nothing had happened. I believe this is 
23 
when Captain Frick and I went to her home. 
24 
MR. KUVIN: Okay. 
25 
THE WITNESS: It wasn't until, I think, I 
Page 8F) 
1 
THE WITNESS: Yes. 
2 
BY MR. KUVIN: 
3 
Q. Describe for us the details of what she 
4 
told you as best you can recall. And then if you 
5 
cannot recall the details, then let us know and 
. 6 
you're welcome to refresh your recollection with the 
7 
incident report. 
8 
MR. PIKE: Font 
9 
THE WITNESS: 1 recall she was taken to 
11 
remember exzWwitilliat
ullbelieve 
10 
the home by 
trying W 
12 
she was, she was the girl who was upset. She 
13 
was the one that got upset when either 
14 
Mr. Epstein tried to touch her buttocks or her 
15 
breasts. I can't recall. 
16 
MR. PIKE: Form, move to strike, 
17 
nonresponsive. 
18 
MR. KUVIN: Okay. Why don't we do this: 
19 
Would it help toicficli your recollection by 
20 
looking at the incident report? 
21 
THE WITNESS: Yeah, it's been sane time. 
22 
MR. KUVIN: That's fine. Go ahead and 
23 
take a look and refresh your recollection, if 
24 
you would, of the interview that you did with 
25 
her. 
22 (Pages 82 to 85) 
PROSE COURT REPORTING AGENCY, INC. 
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Page 86 
1 
THE WITNESS: Yes. 
2 
BY MR. KUVIN: 
3 
Q. Okay. Does the incident report help 
4 
refresh your recollection regarding your 
5 
conversation with her? 
6 
A. Yes. 
7 
Q. All right. Go ahead and if you would 
8 
explain what she told you in this emotional phone 
call that she had. 
MR. PIKE: Form. 
THE WITNESS: That she was taken to the 
home of Jeffrey Epstein by 
She 
went up — she was taken upstairs. 
BY MR. KUVIN: 
Q. Who was she taken upstairs by? 
A. M. 
While she was upstairs they showed her 
which lotions to use. 
Q. La's be clear. Hang on a second. I want 
to make sure that you take a look at Paragraph 2 
there. 
A. By 
Q. Okay. So 
takes her up? 
MR. PIKE: Form 
THE WITNESS: Correct. 
1 
2 
3 
4 
5 
6 
7 
8 
10 
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Page 88 
massage I guess he tried to remove her shirt. 
At this point she became upset and they had a 
verbal disaseement. She came back downstairs 
and told = 
that she wanted to leave. 
MR. PIKE: Form, move to strike. 
BY MR. KUVIN: 
Q. Did she tell you whether she ever returned 
to the home? 
MR. PIKE: Same objections. 
THE WITNESS: She did state that she came 
back to the home a second time. She was 
wearing very tight jeans with a, with a tight 
belt. She was brought upstairs and I believe 
Mr. Epstein tried to touch her buttocks. She 
again told him that she did not want to be 
touched and the massage was discontinued. 
BY MR. KUVIN: 
Q. Now, was she emotional and crying during 
the entire conversation she had with you? 
MR. PIKE: Form, and asked and answered. 
THE WITNESS: Yes, she was. 
BY MR. KUVIN: 
Q. Did you investigate to determine whether 
at the time of this incident that she reported to 
you how old she was? 
Page 87 
1 
BY MR. KUVIN: 
2 
Q. Just so we're clear before I have you go 
3 
further, this narrative that you wrote out here, was 
4 
it, when was it written out? 
5 
A. October 7th. 
6 
Q. Okay. Was it written out at or around the 
time that she came and told you this information by 
3 
phone? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: Correct. 
11 
BY MR. KUVIN: 
12 
Q. You recorded this down within days of this 
13 
phone call? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: Probably during the phone 
16 
call, transcribed it onto a Word Document, 
17 
forwarded it to NicIde Altomaro to input it 
18 
into the system and the notes were destroyed. 
19 
BY MR. KUVIN: 
20 
Q. Ail right. Let's go on. So she tells you 
21 
that = 
takes her up to the room. What happened? 
22 
What does she tell you happened next? 
23 
MR- PIKE: Form, move to strike. 
24 
THE WITNESS: She was shown which oil to 
25 
be used. Mr. Epstein came in.  Dt
S
......„..,
he 
Page 89 
1 
MR. PIKE: Form. 
2 
THE WTINESS: 16 I believe. 
3 
BY MR. KUVIN: 
4 
Q. How did you verify that? 
5 
A. She was still in high school. She was still 
6 
attending Royal Palm Beach High School. 
7 
MR. PIKE: Form. 
8 
MR. KUVIN: Okay. Did you —
9 
THE WITNESS: I located her date of birth. 
10 
BY MR. KUVIN: 
11 
Q. How did you find the date of birth? How 
12 
do you verify dates of birth if somebody tells you? 
13 
A. Ask the victim the date of birth and we go 
14 
back and confirm it through their driver's license. 
15 
Q. In other words you don't just take their 
16 
word for it. Just because they are in high school, 
17 
you don't assume they are underage, do you? 
18 
A. No. 
19 
Q. All right. Did her recollection of the 
20 
incident at Mr. Epstein's home bear any similarities 
21 
to the stories that you had heard told to you by 
22 
-QM` 
23 
MR. PIKE: Form. 
24 
THE WITNESS: Yes, they had similarities. 
25 
23 (Pages 86 to 89) 
3 
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Page 90 
Page 92
BY MR. KUVIN: 
Q. All right. On the following Page 35 there 
3 
is an additional girl you speak to. It looks like 
you go out to a home and speak to someone in the 
kitchen area, do you see that, and a sworn taped 
o 
statement was taken? 
7 
A. Yes. 
8 
Q. Do you recall which girl this was? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: I can see her face but I'm 
11. 
trying to recall her name. I want to say• 
12 
BY MR. KUVIN: 
13 
Q. Uncertain though without seeing the 
14 
redacted, =redacted, I should say, copy? 
15 
A. I believe it waal She was the one that I, 
16 
I went to visit her at her house. She had guests, so we 
17 
went into the kitchen area to talk. 
18 
Q. Okay. This statement that you took from 
19 
her was recorded? 
20 
A. Yes. They are all taped statements. 
21 
Q. And she agreed to that statement to be 
22 
taken? 
23 
A. Correct. 
24 
Q. Okay. Do you recall how many taped 
25 
statements you took of girls? 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 
turned over to the FBI? 
2 
A. Yes. 
3 
Q. That was pursuant to — well, why don't 
4 
you tell us. Why, why was all of that turned over 
5 
to the FBI? Why was your entire investigative file 
6 
given to them, if you know? 
7 
MR. PIKE Form. 
8 
THE WITNESS: They came with a grand jury 
subpoena requesting all evidence, all working 
files, all any notes, any, anything 
pertaining to the investigation 
BY MR. KUVIN: 
Q. And that would have included all the audio 
taped statements that you took? 
A. Correct. 
Q. All right. And I am sorry, I forgot the 
name again of this girl that you talked to in the 
kitchen. 
A. J.L. 
Q. IL, what did she tell you occurred? 
MR. PIKE: Form. 
THE WITNESS: That he was taken to the 
home of Mr. Epstein by 
She was 
brought upstairs by an employee of the house. 
I can't recall if she identified who that 
Page 91 
1 
MR. PIKE: Form. 
2 
THE WITNESS: Several. It was, it was 
3 
quite a bit 
4 
BY MR. KUVIN: 
5 
Q. More than five? 
6 
A. Yes. 
7 
Q. More than ten? 
8 
MR. PIKE: Form —
9 
THE WITNESS: Yes. 
10 
MR. PIKE: 
to five and ten. 
11 
BY MR. KUVIN: 
12 
Q. Did you take more than 20? 
13 
MR. PIKE: Form. 
14 
MR. KUVIN: Just trying to get an idea of 
15 
how many taped statements might exist. 
16 
MR. PIKE: Form. 
17 
THE WITNESS: 1 believe more than 20. 
18 
BY MR. KUVIN: 
19 
Q. Now, is that more than 20 different girls? 
20 
MR. PIKE: Form. 
21 
THE WITNESS: Not only girls. Like 
22 
previous employees, people that have worked at 
23 
Mr. Epstein's home. 
24 
BY MR KUVIN: 
25 
Q. kll±fn jt a ......_,
dstatementsultimatel were 
Page 93 
1 
person was, but she was shown which oil to use. 
2 
BY MIL KUVIN: 
3 
Q. Much hie the other girls? 
MR. PIKE: Form, move to strike. 
MR. KUVIN: Okay. Go ahead. 
MR. PUCE: What question are we on now? 
MR. KUVIN: Describing what she told him. 
8 
MR. PIKE: Okay. Form. 
THE WITNESS: She went upstairs, provided 
the massage. 
BY MR. KUVIN: 
Q. Was she asked to remove her clothes? 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. Did she tell you whether she was asked to 
remove her clothes? 
MR. PIKE: Form. 
THE WITNESS: I can't recall. 
BY MR. KUVIN: 
Q. If we look at Page 35 about halfway down, 
the beginning of the line is a blacked out word, and 
it says "feather stated." Do you see that? 
A. Yes. 
Q. All right. Does that help refresh your 
recollection with respect to --
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
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24 (Pages 9O to 93) 
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Page 94 
Page 96 
1 
A. Yes. 
2 
Q. -- what she described? 
3 
MR. PIKE Form. 
4 
TILE WITNESS: Mr. Epstein came into the 
5 
room and asked her to remove her clothing. 
6 
BY MR ICUVIN: 
7 
Q. And she was how old at this time? 
B 
MR. PIKE: Form. 
9 
THE WITNESS: Sixteen, I believe. 
10 
Sixteen, 17. 
11 
BY MR. KUVIN: 
12 
Q. All right. And did she give him, did she 
13 
describe whether or not she gave him a massage? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: Yes, she did. I remember 
16 
she provided the massage. 
17 
BY MR. KUVIN: 
18 
Q. Was she partially naked, top of her 
19 
clothing was off at the time exposing her breasts? 
20 
MR. PIKE: Form. 
21 
THE WITNESS: I believe so. 
22 
BY MR. KUVIN: 
23 
Q. All right. During the incident with her, 
24 
did she discuss whether or not a large white 
25 
vibrator was used at all? 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
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13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
BY MR KUVIN: 
Q. What was her demeanor during this 
conversation? 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. I mean, was she calm, cool, collected, was 
she upset? I mean describe for us if you would her 
demeanor. 
MR PUCE: Form. 
THE WITNESS: rm trying to recall. I 
think she was upset. 
MR. KUVIN: Okay. 
MR. PIKE: Thank you. 
BY MR. KUVIN: 
Q. Did Mr. Epstein give her money at the 
conclusion of this event? 
MR. PIKE: Form. 
THE WITNESS: Yes. 
BY MR. KUVIN: 
Q. Does she describe to you whether or not 
Mr. Epstein ejaculated during the massage? 
MR. PIKE: Fonn. 
THE WITNESS: Yes, he did. I believe he 
did. 
Page 95 
1 
MR. PIKE: Form. 
2 
THE WITNESS: Yes, I do recall it was a 
3 
large, large massage, massager, slash, vibrator 
4 
used 
5 
MR. PIKE: Move to strike, leading. 
6 
BY MR.1CU'VIN: 
7 
Q. Did she describe whether or not it was 
8 
used on her? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: Yes, she did. She did 
11 
recall. She did state it. 
12 
BY MR. KUVIN: 
13 
Q. How did she describe it being used on her? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: Rubbed on her vaginal area. 
16 
BY MR. KINN: 
17 
Q. And who was holding it at the time? Did 
18 
she explain that? 
19 
A. Mr. Epstein. 
20 
MR. PIKE: Form. 
21 
BY MR KUVIN: 
22 
Q. Now, this conversation you had with her 
23 
occurred in the kitchen area of her home? 
24 
THE WITNESS: Yes. 
25 
MR. PIKE: Form. 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
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18' 
19 
20 
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Page 97 
BY MR. KUVIN: 
Q. Now, at the end of the page I notice you 
have a note there regarding her description of her 
emotional state. What did she describe to you, if 
anything, regarding how she felt about this incident 
occurring? 
A. If I can refresh —
MR. PIKE: Form 
MR.1CUVIN: Please do. 
THE WITNESS: Thanks. 
MR. PIKE: And for the record, the witness 
is refreshing his recollection with Exhibit 2. 
THE WITNESS: Okay. That she was ashamed 
and embarrassed about the situation. 
MR. KUVIN: Okay. 
MR. PIKE: Is this a good time to take 
break? 
MR. KUVIN: Sure. All right. It's 11:30 
well take a five-minute break 
(A brief recess was held and Ms. 
Finnigan entered the deposition room and 
Mr. Garcia left the deposition room. 
BY MR. KUVIN: 
Q. Okay. All right. Let's go to Page 37 in 
Narrative 10 for a moment. It looks like, correct 
25 (Pages 94 to 97) 
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Page 98 
Page 100 
1 
me if I'm wrong, that on this particular date, 
2 
October 6th, 2005 well, you tell me. What did 
3 
you do on that date? 
4 
A. That was the date back then when Detective 
5 
Dawson and I went to down to speak to Jane Doe No. 4. 
6 
Q. Jane — 
7 
A. Doe No.4. 
8 
Q. Okay. And where did you have to go? 
9 
A. To the university she was attending. 
10 
Q. Okay. When you went there did you get a 
11 
chance to meet with her? 
12 
A. Yes, I believe so. 
13 
MR. PIKE: Form. 
14 
BY MR. KUVIN: 
15 
Q. MI right. And what was her demeanor when 
16 
you met with her on this particular occasion? 
17 
MR. PIKE: Form. 
18 
THE WITNESS: I can't recall her exact 
19 
demeanor. 
20 
BY MR. KUVIN: 
21 
Q. Do you recall whether this conversation 
22 
was taped? Was this a taped statement? 
23 
A. I am trying to remember. I believe it was. 
24 
Q. Okay. And during this particular 
25 
interview, did she describe to you what she thought 
1 
BY MR. KUVIN: 
2 
Q. All right. Let's move to Page 39 if we 
3 
could. On October 10, 2005, you made telephone 
4 
contact with someone. Do you recall who that was? 
5 
A. Yes, I do. 
6 
Q. Okay. And which person was this? 
7 
A. I believe this was Jane Doe No. 103 
8 
Q. Okay. And if we go through this 
9 
particular phone call, I believe you actually 
10 
document in this phone call her emotional state. If 
11 
we look at Paragraph 2, five lines up from the 
12 
bottom. 
13 
(Mr. Goldberger entered the 
14 
deposition room.) 
15 
BY MR. KUVIN: 
16 
Q. What did you document as Ms. Jane Doe No. 
17 
103's emotional state was during this conversation 
18 
you had with her? 
19 
MR. PIKE: Form. . 
20 
THE WITNESS: She was crying hysterically 
21 
and very upset as she was discussing the 
22 
incidents. 
23 
BY MR- KUVIN: 
24 
Q. Okay. And as she's crying discussing 
25 
these incidents, does she describe to you how many 
Page 99 
1 
of Mr. Epstein? 
2 
MR. PIKE: Form. 
3 
MR. KUVIN: And if you can't recall, 
4 
you're welcome to refresh your recollection. 
5 
Just let us know that you need to refresh your 
6 
recollection and utilize the report. 
7 
THE WITNESS: I'm going have to look at 
8 
the report because it was some time ago. 
9 
MR. KUVIN: Okay. Take a look at the 
10 
report, the bottom of the page, last line. 
11 
MR. PIKE: Are we still on Page 35? 
12 
MR. KUVIN: Thirty-seven. 
13 
BY MR. KUVIN: 
14 
Q. How did she describe Mr. Epstein? 
15 
MR. PIKE: Form. 
16 
THE WITNESS: She was uncomfortable. She 
17 
considered Jeff a pervert who kept pushing to 
18 
go further and further. 
19 
BY MR. KUVIN: 
20 
Q. And if we look at Page 38, bottom of the 
21 
first paragraph, last line, during the incidents 
22 
that she described to you with Mr. Epstein, how old 
23 
was she? 
24 
A. Sixteen. 
25 
MR. PIKE: Form move to strike. 
Page 101 
1 
times these had occurred? 
2 
MR. PIKE: Font 
3 
MR. KUVIN: And if you need the report to 
4 
help refresh your recollection, you're welcome 
5 
come to use that. Just let us know that you're 
6 
using it for that purpose. 
7 
THE WITNESS: I know it was numerous times 
8 
over a two-year period. 
9 
MR. PIKE: Mow to strike. 
10 
BY MR. KUVIN: 
11 
Q. If you look at the ixmort afler the 
12 
section that says "Ms. Jane Doe No. 103 began crying 
13 
on the telephone," do you see that line? 
14 
MR. PIKE: Form. 
15 
THE WITNESS: Yes. 
16 
BY MR. KUVIN: 
17 
Q. How nntny times do you document that she 
18 
tells you she had been there over a two-year period? 
19 
MR. PIKE: Form. 
20 
THE WITNESS: Hundreds of times. 
21 
BY MR. KUVIN: 
22 
Q. Do you make this report, do you write out 
23 
this report at or around the time the phone call 
24 
occurred? 
25 
A. Correct. 
26 (Pages 98 to 101) 
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Page 102 
1 
Q. Contemporaneous, essentially, as you're 
2 
taking notes? 
3 
A. Correct. 
4 
Q. You type it up soon thereafter? 
5 
A. Correct. 
6 
Q. Is she, at the time these incidents 
7 
occurred, does she express to you whether she was 
8 
under the age of 18? 
9 
MR. PIKE: Form. 
10 
THE WITNESS: Yes. 
11 
BY MR. KUVIN: 
12 
Q. How old do you determine that she was 
13 
during the incidents that she describes? 
14 
MR. PIKE: Fonn. 
15 
THE WITNESS: Sixteen years old. 
16 
BY MR. KUVIN: 
17 
Q. And at the time that she's 16 year old, 
18 
was she able to recount to you what Mr. Epstein's 
19 
penis looked like? 
20 
MR. PIKE: Form. 
21 
THE WITNESS: Yes, she did. 
22 
BY MR KUVIN: 
23 
Q. How did she describe it? 
24 
MR. PIKE: Form. 
25 
THE WITNESS: I believe she recalled it as 
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 104 
first, and I want to go through in here. If we look 
at the last paragraph on Page 39, it says, and I am 
assuming this is referring to Ms. Jane Doe No. 103 
"became more upset, crying hysterically." 
Do you see that last paragraph? 
A. Yes. 
Q. Okay. So, during this phone call you're 
having with her, she's actually crying hysterically 
on the phone to you? 
MR. PACE: Form. 
THE WITNESS: Yes. 
BY MR. KUVIN: 
Q. And you documented that at the time that 
you had the phone call with her? 
A. Yes, I did. Asa matter of fact it was 
recorded. 
Q. Okay. 
MR. PIKE: Form. 
THE WITNESS: It was a recorded telephone 
cat 
MR. PIKE: Form to the last question. 
BY MR. KUVIN: 
Q. When this phone call occurred with 
Ms. Jane Doe No. 103, what was her, just so we're 
clear, what was her emotional state? 
Page 103 
1 
an egg-shaped penis. 
2 
BY MR. KUVIN: 
3 
Q. All right. I want to make sure that we're 
4 
talking about the correct girl here. If we look at 
5 
the report on October 10, 2005, does she describe 
6 
whether or not it is circumcised? 
MR. PIKE: Form. 
THE WITNESS: Yes, she does. 
9 
BY MR. KUVIN: 
10 
Q. Okay. And did she understand what that 
11 
meant to be circumcised or not circumcised? 
12 
MR. PIKE: Form. 
13 
THE WITNESS: Correct. 
14 
BY MR. KUVIN: 
15 
Q. Does Ms. lane Doe No. 103 also describe 
16 
any additional sexual acts other than naked massages 
17 
for Mr. Epstein that she engaged in? 
18 
MR. PUCE: Form. 
19 
THE WITNESS: Yes, she did. During my 
20 
interview with her, that was actually — there 
21 
was one on the telephone, and I agreed to meet 
22 
with her to speak with her personally to get a 
23 
more in-depth interview with her. 
24 
BY MR. KUVIN: 
25 
Q. Let's talk about just this phone call 
Page 105 
1 
MR. PIKE: Form, speculation. 
2 
THE WITNESS: She was crying hysterically. 
3 
And I recall having to give her time to regain 
4 
her composure to continue the conversation. 
5 
BY MR. KUVIN: 
6 
. 
Q. And does she describe additional sexual 
7 
acts that she engaged in with Mr. Epstein other than 
8 
naked massages? 
9 
MR. PIKE: Form. 
11 
relationship with 
-.
I believe 
THE 
: es. She described having a 
10 
12 
she described at one time, I believe, she had 
13 
sex with Mr. Epstein onetime. 
14 
BY MR. KUVIN: 
15 
Q. All right. Let's do this: I want you to 
16 
take a look at this lasfparagraph on Page 39 for a 
17 
second and see if that helps refresh your 
18 
recollection. And then I would like to ask you a 
19 
couple of questions about the phone call in 
20 
particular. 
21 
A. Okay. 
22 
Q. All right. During this part of the phone 
23 
call, is she still, is she still emotional with you? 
24 
MR. PIKE: Form. 
25. 
THE WITNESS: Yes, very. 
27 (Pages 102 to 105) 
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Page 106 
Page 108 
1 
BY MR. KUVIN: 
2 
' Q. Okay. And what does she describe occurs 
3 
between her, Ms. 
Mr. Epstein, if 
4 
anything? 
5 
MR. PIKE: Form. 
6 
THE WITNESS: It was oral sex performed on 
7 
her. There was strap-on penises utilized. 
8 
Them was other scaml toys being used, a 
9 
vibrator. 
10 
BY MR. KUVIN: 
11 
Q. Does she describe whether or not 
12 
Mr. Epstein actually puts his fingers inside of her 
13 
vagina or not? 
14 
A. Yes, 
15 
MR. PIKE: Form. 
16 
BY MR. WAN: 
17 
Q. What does she stale about that? 
18 
MR PIKE: Font. 
19 
THE WITNESS: That Mr. Epstein inserted 
20 
his fingers in her vagina in an attempt to make 
21 
her climax as she was masturbating him. 
22 
BY MR. KUVIN: 
23 
Q. All of this while she was how old? 
24 
A. Sixteen. 
25 
Q. All right. At some point you have to stop 
1 
Jacksonville tape recorded? 
2 
A. Yes. 
3 
Q. Okay. So one of the tapes that is 
4 
currently in the possession of the FBI would include 
5 
that interview? 
6 
A. Correct. 
7 
Q. Okay. Was she still emotional during the 
8 
interview in Jacksonville --
9 
MR. PIKE: Objection. 
10 
BY MR. KUVIN: 
11 
Q. — about the incidents that occurred? 
12 
A. At times she would get emotional and start to 
13 
cry. 
14 
Q. Okay. If we go down to Page 40 in your 
15 
report — first let me back up. When you meet with 
16 
her, do you take notes? 
17 
A. Yes. 
18 
Q. And do you record those notes into the 
19 
report itself in a timely manner? 
20 
A. Yes. 
21 
Q. If we look at the bottom of Page 40, does 
22 
to you anything with respect to 
23 
and how Epstein and her may have met? 
24 
MR PIKE: Form. 
25 
THE WITNESS: She claimed that Epstein had 
Page 107 
1 
the phone call; is that correct? 
2 
A. Correct. 
3 
Q. NAY? 
4 
A. She was unable to maintain her composure to 
5 
talk to me. 
6 
Q. Did you make arrangements to meet with 
7 
her? 
3 
A. Correct. 
9 
Q. You then meet up with her? 
10 
A. Correct. 
11 
Q. Where do you meet her? 
12 
A. At a park in Jacksonville. 
13 
Q. Is she with someone at the time? 
14 
A. Yes. 
15 
Q. Who was she with? 
16 
A. She was with a female friend. 
17 
Q. Does she describe for you her history with 
18 
Mr. Epstein? 
19 
• 
MR. PIKE: Form. 
20 
THE WITNESS: Yes. 
21 
BY MR. KUVIN: 
22 si itashe 
talk to you at all about 
23 
when you met with her in person? 
24 
A. Yes, she did. 
25 
Q. Okay. And was thytpart !friar meefintin 
1 
2 
3 
BY MR. KUVIN: 
4 
Q. Okay. /knight. Lees tum to Page 41. 
5 
Now, she recounts to you, or does she recount to you 
6 
whether she has actually seen Mr. Epstein's penis? 
7 
MR. PIKE: Form. 
8 
THE WITNESS: Yes, she did. 
9 
BY MR. KUVIN: 
10 
Q. So, she tells you that she saw it? 
11 
A. Correct. 
12 
MR. PIKE: Form. 
13 
BY MR. KUVIN: 
14 
Q. Did she see it once or numerous times? 
15 
THE WITNESS: Numerous times. 
16 
MR. PIKE: Form. 
17 
BY MR. KUVIN: 
18 
Q. All right. And when she's discussing this 
19 
with you, is she also, is she in an emotional state, 
20 
upset, distraught about it at all? 
21 
MR. PIKE: Form. 
22 
THE WITNESS: Like I said, during the 
23 
interview as we were getting more and more 
24 
information, she would get upset. We would 
25 
gr. Allowed her to regain her con:i===,mc
emld ,„
Page 109 
from her family in 
urchas
isp 
28 (Pages 106 to 109) 
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Page 110 
Page 112 
1 
we would continue. 
2 
BY MR. KUVIN: 
3 
Q. All right. If we look at Page 41, you 
4 
have there in the second paragraph an explanation of 
5 
her description of Mr. Epstein's penis; is that 
6 
correct? 
7 
THE WITNESS: Correct. 
8 
BY MR. KUVIN: 
9 
Q. And at the time that this was occurring, 
10 
how old was she? 
11 
MR. PUCE: Form. 
12 
THE WITNESS: Sixteen. 
13 
BY MB. KUVIN: 
14 
Q. And could you tell us how she described 
15 
Mr. Epstein's penis at the time? 
16 
MR. PIKE: Form. 
17 
THE WITNESS: She claimed that it was 
18 
deformed. She called it egg-shaped. 
19 
BY MR. KUVIN: 
20 
Q. What description did she actually use? 
21 
MR. PIKE: Form, asked and answered. 
22 
THE WITNESS: It was oval in shape. 
23 
BY MR. KUVIN: 
24 
Q. All right. If we look here, you have 
25 
recorded exactly — well, let me ask you this: Did 
1 
BY hat. KUVIN: 
2 
Q. — any lawful reason why you could think 
3 
of why a 16-year-old girl could desaibe 
4 
Mr. Epstein's penis? 
5 
MR. PIKE: Form. 
6 
THE WITNESS: No. 
7 
BY MR. KUVIN: 
8 
Q. Did Ms. ane Ike No. 103 describe whether 
9 
or not she had an on in sexual relationship with 
10 
Mr. Epstein and Nie. 
at 
11 
A. Yes, she did. She Mated that —
12 
MR. PIKE: Form. 
13 
THE WITNESS: She stated that when she 
14 
would come over, there was, she would have 
15 
either mla6ms with 
or — and at one 
16 
point she even stated there were some 
17 
photographs taken of her in the tub with 
18 
MR. PIKE: Form. 
19 
BY MR. KUVIN: 
20 
Q. Did you ever recover those photographs? 
21 
A. No. 
22 
MR. PIKE: Form, mmm to strike the 
23 
previous response. 
24 
MS. MIL: Mr. Kuvin, nnise me. I was 
25 
trying to object to the form of the previous 
Page 111 
1 
you record exactly what she had told you dicing the 
2 
interview? 
3 
A. Yes, I did. 
4 
Q. All right. If we look at Page 41, she 
5 
claimed when Mr. Epstein's penis was erect, it was 
6 
thick towards the bottom but was thin and small 
7 
toward the head portion. Do you see that? 
8 
MR. PIKE: Form, leading. 
9 
THE WITNESS: Yes. 
10 
BY MR. KUVIN: 
11 
Q. All right. Is that what she described to 
12 
you? 
13 
A. Yes. 
14 
MR. PIKE: Form. 
15 
BY MR. KUVIN: 
16 
Q. Were you the one that used the term 
17 
egg-shaped. 
18 
MR. PIKE: Form. 
19 
THE WITNESS: No, she used egg-shaped. 
20 
BY MR. KUVIN: 
21 
Q. Okay. Any reason that you could think of 
22 
at the time of this interview why a 16-year-old girl 
23 
would know how to describe Mr. Epstein's penis —
24 
MR. PIKE: Form, confusing. 
25 
THE WITNESS: No. 
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 113 
question about how a I6-year-old girl would 
know how to describe the penis. And I think my 
phone was muted at the time. 
MR. KUVIN: It was, but thank you. 
MS. B7MTI : That If I could just have 
that recorded. 
MR. KUVIN: Sure. 
BY MR. KUVIN: 
Q. All right. If we look at your report on 
Page 41. It appears that Ms. Jane Doe No. 103 
describes an incident that occurred in the massage 
room. 
Do you see that, second paragraph 
from the bottom? 
MR. PIKE: Form, leadirkg. 
THE WITNESS: Yes. 
BY MR. KUVIN: 
Q. All right. Why don't you for a second, 
read the second paragraph from the bottom, and then 
I have a couple of questions to ask you about it. 
Go ahead. Just read the whole paragraph. I just 
want to make sure and then I'm going to ask you 
about it. 
A. Can I use her name? 
Q. No, no. I want ou to 'ust read the 
29 (Pages 110 to 113) 
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1 
Page 114 
second paragraph from the bottom. 
1 
Page 116 
BY MR. KUVIN: 
2 
A. I know, but do you want to me to use her name 
2 
Q. And she said no? 
3 
or use the redacted portions of it? 
3 
MR. PIKE: Hold on a second. The witness 
4 
Q. Yes. We're discussing Ms. Jane Doe No. 
4 
is answering the question. So if you would, 
5 
103 at this point. 
5 
rather than lead the witness through his answer 
6 
A. "Jane Doe No. 103 advised one day, Jane Doe 
6 
so he can answer the way that you would like, 
7 
No. 103 was unable to state the exact date this incident 
7 
would you please ensure that the witness is 
8 
occurred.' 
e 
finished with his answer before you follow 
9 
Q. I'm sorry. Read it to yourself and I will 
9 
through with the next question. 
10 
just ask you questions. 
10 
BY MR. KUVIN: 
11 
A. Okay. 
11 
Q. Did she explain whether or not she said 
12 
Q. Sorry about that. Okay. Did Ms. Jane Doe 
12 
no? 
13 
No. 103 describe to you an incident that occurred in 
13 
MR. PIKE: Form. 
14 
the massage room at Mr. Epstein's home? 
14 
THE WITNESS: Yes, she did. 
15 
A. Yes. 
15 
BY MR. KUVIN: 
16 
MR. PIKE: Form. 
16 
Q. And she said no? 
17 
BY MR. KUVIN: 
17 
A. Yes. 
18 
Q. And what did she describe to you with 
18 
MR. PIKE: Form. 
19 
respect to Epstein and her and any contact that he 
19 
BY MR. KUVIN: 
20 
may have had with her? 
20 
Q. Okay. And what did he do when she said 
21 
MR. PIKE: Form. 
21 
that? 
22 
THE WITNESS: She stated that she had gone 
22 
MR. PIKE: Form. 
23 
up to the bedroom and that both 
and 
23 
THE WITNESS: He apologized to her and she 
24 
Epstein were in the bedroom. They were already 
24 
stated that she had received 51,000 for that 
25 
naked. She had removed her clothing. That 
25 
visit. 
Page 115 
Page 117 
1 
was an appointed time when her and 
began 
1 
BY MR. KUVIN: 
2 
kissing, touching on the massage table. She 
2 
Q. Did she say whether or not as a result of 
3 
stated that she had achieved climax. 
3 
the incident she was injured in any war! 
4 
All the while this was occurring 
4 
MR. PIKE: Form. 
5 
Mr. Epstein was masturbatingg. At one 
5 
THE WITNESS: I can't recall if - I know 
6 
point Mr. Epstein put her onto the massage 
6 
that during our conversations, during her 
7 
table and inserted his penis into her 
7 
visits going to the house and during the 
8 
vagina. 
different acts that occurred while she was at 
9 
BY MR. KUVIN: 
9 
the house, she claimed that she had left very 
10 
Q. Did she say whether or not this was 
10 
sore, but I don't recall her saying anything as 
11 
consensual or not? 
11 
to that particular incident 
12 
MR. PIKE: Form. 
12 
BY MR. KUVIN: 
13 
THE WITNESS: This was not consensual. 
13 
Q. All tight If we tum to the next page, 
14 
BY MR. KUVIN: 
14 
Page 42, Narrative 12, this narrative is reported by 
15 
Q. And what did she say occurred happened at 
15 
you? 
16 
that point? 
16 
A. Yes. 
17 
MR. PIKE: Form. 
17 
Q. All right. As a result of the interviews 
18 
THE WITNESS: She said this occurred for 
18 
that you bad done in the investigation up until this 
19 
very quick He removed himself from her 
19 
point, did you request a search warrant for the 
20 
nem 
20 
home? 
21 
BY MR. KUVIN: 
21 
A. Yes, I did. 
22 
Q. Did she say whether or not she told him 
22 
Q. And was a search warrant actually signed 
23 
no? 
23 
by the judge? 
24 
A. Yes. 
24 
A. Yes. 
25 
MR. PIKE: Form, move to strike. 
25 
Q. When was that warrant executed on the 
30 (Pages 114 to 117) 
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Page 118 
1 
home? 
2 
A. Sometime in October. 
3 
Q. All right If we look at Page 42, it 
4 
says: "on October 18, 2005,1 met with Judge Laura 
5 
Johnson who signed the warrant" And then on 
6 
October 20, 2005, at approximatly 9:36 a.m., members 
7 
of the police department investigation unit nee' lied 
B 
the warrant? 
9 
A. Correct. 
10 
Q. Is that in and about the time the warrant 
11 
was executed? 
12 
A. That's correct. 
13 
Q And this warrant, the execution of this 
14 
warrant was videotaped? 
15 
A. The — it's our policy when the search warrant 
16 
is executed, we do entry/exit videos. 
17 
Q. Okay. That's what you did in this case? 
18 
A. Yes. 
19 
Q And you kept those videos at the 
20 
departMent? 
21 
A. Yes. 
22 
Q. They we a part of the investigation? 
23 
A. Yes, sir. 
24 
Q. And the videos were taken, were they taken 
25 
by personnel working for the department? 
Page 120 
1 
THE WITNESS: The CPU's were removed. The 
2 
CPU's being the computers. The towers were 
3 
removed. The wires were just left. The 
4 
cabinet in which they claimed all the oils were 
5 
being kept were, was empty except for one 
6 
bottle that was way in the back The drawer in 
7 
the bedroom where they claimed all the toys 
8 
were was empty. That's what I meant by --
9 
MR. KUVIN: Sanitized? 
10 
THE WITNESS: (Witness nods head.) 
11 
BY MR. KUVIN: 
12 
Q. Okay. During the inspection that you did 
13 
or the warrant, execution of the warrant, did you 
14 
determine whether or not there were any internal 
15 
security cameras in the borne? 
16 
A. Yes, there were. 
17 
MR. PIKE: Fonn. 
18 
BY MR. KUVIN: 
19 
Q. And do you recall whether there were any 
20 
located based on your inspection in the upstairs 
21 
area of the home? 
22 
MR. PIKE: Fenn. 
23 
THE WITNESS: Not in the upstairs area. 
24 
There was a covert clock in the downstairs 
25 
office area and there was another covert clock 
Page 119 
A. Yes. 
2 
Q. All right. And you were present? 
A. Yes. 
Q. Tell us, if you would, how you found the 
5 
state of the home when you arrived on that date for 
6 
the inspection? 
MR. PIKE: Form. 
• 
MR. KUVIN: Or for the execution of the 
9 
warrant, excuse me. 
10 
THE WITNESS: It was determined, obviously 
11 
when we were in the house, that the house was 
12 
somewhat sanitized. 
13 
MR. PIKE: Form. 
14 , 
MR. KUVIN: Describe what you mean. 
15 
• I think we just got disconnected. 
16 
• Ms. Ezell. 
17 
(A brief recess was held.) 
18 
MR. KUVIN: We lost you, Kathy. 
19 
MS. EMI  • Sony. Lost you fora minute. 
20 
BY MR KUVIN: 
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Q All right. You mentioned before we took a 
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quick break there that you felt that the house was, 
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or you determined that the house was somewhat 
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sanitized. Can you describe what you mean by that? 
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MR. PIKE: Form. 
Page 121 
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on the wall in the garage. 
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BY MR. KUVIN: 
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Q Okay. The one in the garage, what was it 
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pointing at? In other words what was it attempting 
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to see from that direction? 
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MR. PIKE: Form. 
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THE WITNESS: I believe it was, it was the 
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overview of the vehicles kept in the garage, 
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bicycles, motorcycle, cars, garage doors, so... 
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BY MR. KUVIN: 
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Q Okay. And the one in the office was 
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pointed at what? 
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MR. PIKE: Palm. 
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THE WITNESS: The desk living room area. 
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BY MR. KUVIN: 
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Q. Okay. Any other cameras that you can 
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recall finding during the execution of the warrant, 
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either covert or overt? 
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MR. ME: Form. 
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THE WITNESS: Not that I can recall. 
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BY MR. ICUVIN: 
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Q. Okay. And did you come to learn or 
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discover any information about whether Mr. Epstein 
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may have been tipped off as to the execution of this 
25 
warrant? 
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Page 122 
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WIPIKE:Fonn. 
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THE WITNESS: i 'mow that some of the 
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girls had maintained contact with IMIM. 
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There was a couple of girls that stated that 
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was calling to find out the status 
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or questions asked by us, the police 
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department. 
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BY MR. KUVIN: 
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Q. This all occurred prior to the warrant? 
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MR. PIKE: Form. 
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THE WITNESS: Yes. 
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. MR. PIKE: Move to strike. 
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BY MR. KUVIN: 
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Q. And by the titre you left the property was 
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an attorney, did an attorney arrive? 
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A. Yes. As we were leaving securing the 
17 
residence, a Guy Fronstin walked up onto the property. 
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Q. Okay. How long did the execution of this 
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warrant take, roughly? 
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MR. PIKE: Form. 
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MR. KUVIN: What is wrong with that 
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question? 
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MR. PIKE: It is depending on the 
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investigation. You're tip-toeing into a lot of 
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hearsay testimony with these questions. I 
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Page 124 
MR. PIKE: How much longer do you have? 
MR. KUVIN: I have no idea. i have no 
idea 
But the question that's pending that 
I wanted an explanation or which you 
haven't explained is how long did it take 
you to execute this search warrant. 
MR. PIKE: Form. 
MR. KUVIN: And the form would be? 
MR PIKE: How long did it take to 
execute: What search warrant? When? When? 
What time? Him? His officers? What 
detective? I don'ticnow. Shall I go on? 
MR. KUVIN: Actually, yeah, because it's 
kind of comical, but I will clarify because you 
don't understand. 
BY MR. KUVIN: 
Q. Detective Recarey, how long were you on 
Mr. Epstein's property that day? 
MR. PIKE: Form, predicate. You have 
actually even — here, let me help you out a 
bit. You have actually failed to lay the 
appropriate predicate and foundation that he 
was the one that executed the search warrant or 
whether it was his team that executed the 
Page 123 
1 
don't know where it's corning from. You have 
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asked several questions here about-
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MR. KUVIN: The outstanding question is 
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MR. PIKE: Wait, wait, wait one second. 
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MR. KUVIN: — how long did the execution 
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of the warrant take. 
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MR. PIKE: I am going to answer your 
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question. You have asked several questions 
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here today that involve hearsay opinion 
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testimony from others that Detective Recarey 
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allegedly spoke to others that spoke to, for 
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instance, third parties that spoke to Detective 
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Recarey. 
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And as a result you have very serious 
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opinion and hearsay privileges that are 
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asserted here. And I really don't 
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understand the point of this deposition 
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today because none of it is admissible. 
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So, hopefully that helps you with 
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your question, and you can rephrase them 
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or, you know, just continue, 
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And while we're on that topic, let me 
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ask you this, it's 12:15 and —
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MR. KUVIN: i was going to break at 12:30 
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for lunch. 
Page 125 
1 
search warrant, so... 
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BY MR. KUVIN: 
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Q. Detective Recarey, did you go to 
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Mr. Epstein's house that day? 
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A. Yes, I did. 
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Q AM how long were you at his house that 
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the 
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A. I believe we started around 9:30 and we 
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concluded I want to say around 1:00. 
10 ' 
Q. Okay. I have a whole bunch of property 
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receipts that were turned over by the Town of Palm 
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Beach. This was the property receipt turned over to 
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us the other day bye-mail. 
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MR. PIKE: This is not what we discussed 
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yesterday. 
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MR. KUV1N: This is an e-mail from 
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Ms. O'Connor's office that was sent to 
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everybody. 
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MR. EDWARDS: These were all in the 
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original production as well. 
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MR. PIKE: I have a copy. 'Blank you. 
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MR. KUVIN: I would blue to show you those 
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property receipts. And just for the record, 
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let's mark all property receipts as Exhibit 4. 
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Do it as a composite exhibit. 
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(Plaintiffs Exhibit No. 4 was marked for 
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identification.) 
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BY MR. KUVIN: 
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Q. Can you tell by looking at the pmperty 
5 
receipts what property was seized on the date of the 
6 
execution of the warrant versus other property that 
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may have been obtained during the investigation? 
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A. Yes. 
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Q. All tight. Could you pull out the 
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property receipts regarding the property seized on 
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the date of the execution of the warrant. Just 
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separate those out for us. 
13 
A. PC affidavit would have actually written on it 
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search warrant return on the very top, so it's easy to 
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identify plus it would be notarized at the bottom. 
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Q. Great. Take a look then. 
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A. I have five here, but it looks like I am 
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missing one because it says one of six; two, three, 
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four, five. 
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Q. Just if you would look through the 
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remaining documents to make sure we're not missing a 
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page. Yeah, keep those separate. 
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Mk PIKE: Move to strike. 
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THE WITNESS: Here we go. Page 6 of 6. 
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MR.1CUVIN: Okay. Just put the rest of it 
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Page 128 
Q. It's got your ID number there. And what 
was your ID number at the time? 
A. 7915. 
Q. And the unit was what? 
A. At that time I was Delta Unit. It was 
Delta EL 
Q. Okay. And the date that this property was 
recovered was when? 
A. October 20th, 2005. 
Q. All right. Let's go through some of these 
thing. It appears that you retrieved phone message 
books from the kitchen area of the house; is that 
correct? 
A. Correct 
MR. PIKE: Form. 
BY MR. KUVIN: 
Q. There seemed to be little bar codes next 
to some of the descriptions. I would ask you to 
describe what those are. 
A. The bar codes is actually utilized by crime 
scene to find the location of it. It's a — the 
property itself and the property receipt has the same 
bar code, and it's to help them identify where it is in 
the evidence room. 
Q. Okay. Did you recover numerous different 
Page 127 
1 
back and I just want to make sure that I got 
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the entire — let's do this if you would: 
3 
Stick 4, I am going to put 4-A on this document 
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just so that we can separate it out from the 
5 
rest of 4. 
6 
THE WETNESS: That was towards the back 
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MR. PIKE: Yes, I know. I have got it. 
8 
(Plaintiffs Exhibit No. 4-A was marked 
9 
for identification.) 
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MR. PIKE: And it's six pages, correct, 1 
11 
through 6? 
12 
THE WITNESS: Yes, sir. 
13 
MR. KUVIN: Mars correct. 
14 
BY MR. KUVIN: 
15 
Q. Let's go through this fora moment. All 
16 
right. Is this a document that you fill out? In 
17 
other words is that your handwriting? 
18 
A. It might have been crime scene's. 
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Q. Okay. Do you sign the document at all? 
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A. Yes, I do. 
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Q. All right. Where does your signature 
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appear? 
23 
A. It would be in the performance of my duties. 
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Q. Gotcha. In the bottom right corner? 
25 
A_ Yes. 
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PAT-, 
". 
phone message pads? 
MR. PIKE: Form 
THE WITNESS: Yes, I did. 
BY MR. KUVIN: 
Q. Les go to Page 2 along with phone 
message pads. Did you also recover CD's and —
MR. EDWARDS: We might have lost her 
offain 
MR. PIKE: Kathy, are you them? 
MR. EDWARDS: Were about to break anyway 
MR. KUVIN: Why don't we go ahead and 
break. How long do you want for lunch? 
MR. PIKE: Half hour. 
MR. KUVIN: Is that okay with you? Its 
12:30. Let's do 30. 
MR. EPSTEIN: Back at 1:00? 
MR. KUVIN: Yes, back at 1:00. 
(A luncheonrecess was held.) 
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