giuffre-maxwell-batch-4.pdf

Case 1:15-cv-07433-LAP Document 1328 Filed 01/05/24 Page 1 of 1 January 5, 2024 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Pursuant to the Court’s December 18, 2023, unsealing order, and following conferral with Defendant, Plaintiff files this set of documents ordered unsealed. The filing of these documents ordered unsealed will be done on a rolling basis until completed. This filing also excludes documents pertaining to Does 105 (see December 28, 2023, Email Correspondence with Chambers), 107, and 110 (see ECF No. 1319), while the Court’s review of those documents is ongoing. Respectfully, /s/ Sigrid S. McCawley Sigrid S. McCawley cc: Counsel of Record (via ECF)  Case 1:15-cv-07433-LAP Document 1328-1 Filed 01/05/24 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X .......................................... VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration Of Jeffrey S. Pagliuca In Support Of Defendant’s Response in Opposition to Plaintiff’s Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions Filed Under Seal I, Jeffrey S. Pagliuca, declare as follows: 1. I am an attorney at law duly licensed in the State of Colorado and admitted to practice in the United States District Court for the Southern District of New York pro hac vice. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of Response In Opposition to Plaintiff’s Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions Filed Under Seal. 2. Attached as Exhibit A (filed under seal) are true and correct copies of excerpts from the deposition of Virginia Giuffre, designated as Confidential under the Protective Order. 3. Attached as Exhibit B are true and correct copies of Bates stamped documents GM_00523-00528.  Case 1:15-cv-07433-LAP Document 1328-1 Filed 01/05/24 Page 2 of 3 4. Attached as Exhibit C (filed under seal) are true and correct copies of excerpts from the April 22, 2016 deposition of Ghislaine Maxwell, designated as Confidential under the Protective Order. 5. - Attached as Exhibit D (filed under seal) is a true and correct copy of the July 22, 2016 deposition of Ghislaine Maxwell, designated as Confidential under the Protective Order. 6. Attached as Exhibit E (filed under seal) are true and correct copies of excerpts from the deposition of Johanna Sjoberg, designated as Confidential under the Protective Order. 7. Attached as Exhibit F (filed under seal) are true and correct copies of excerpts from the deposition of Detective Joseph Recarey designated as Confidential under the Protective - Order. 8. Attached as Exhibit G (filed under seal) are true and correct copies of excerpts from the deposition of Juan Alessi, designated as Confidential under the Protective Order. 9. Attached as Exhibit H (filed under seal) are true and correct copies of excerpts from the deposition of Tony Figueroa, designated as Confidential under the Protective Order. 10. Attached as Exhibit I (filed under seal) are true and correct copies of excerpts from the deposition of Rinaldo Rizzo, designated as Confidential under the Protective Order. Dated: August 8, 2016 By: /s/ Jeffrey S. Pagliuca Jeffrey S. Pagliuca 2  Case 1:15-cv-07433-LAP Document 1328-1 Filed 01/05/24 Page 3 of 3 CERTIFICATE OF SERVICE I certify that on August 8, 2016, I electronically served this Declaration Of Jeffrey S. Pagliuca In Support Of Defendant’s Response in Opposition to Plaintiff’s Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions Filed Under Seal via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 cassellp@law.utah.edu Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.com J. Stanley Pottinger Bradley J. Edwards 49 Twin Lakes Rd. FARMER, JAFFE, WEISSING, EDWARDS, South Salem, NY 10590 FISTOS & LEHRMAN, P.L. StanPottinger@aol.com 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com /s/ Nicole Simmons Nicole Simmons 3 Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 1 of 26 EXHIBIT F  Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 2 of 26 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 21, 2016 9:17 a.m. C O N F I D E N T I A L Deposition of JOSEPH RECAREY, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 3 of 26 Page 178 1 JOSEPH RECAREY - CONFIDENTIAL 2 BY MR. PAGLIUCA: 3 Q. Then there's a category, victim 4 information, and then we have listed, I believe, a 5 total of 17 individuals that the Palm Beach Police 6 Department incident report lists as alleged victims 7 in this case, correct? 8 A. Correct. 9 Q. And are you aware as to whether or not 10 that list was supplemented after July 25th, 2006, in 11 the investigative incident report? 12 A. I'm not sure if it was updated or not. 13 MR. PAGLIUCA: I don't know if we want to 14 mark this or not. I can hand you what I 15 believe to be a more recent, or I think you 16 actually brought one with you -- 17 THE WITNESS: I did. 18 MS. SCHULTZ: If you're talking about the 19 document that he brought with him, I had it 20 Bates labeled. 21 MR. PAGLIUCA: We can show him that. I 22 think I have the same document here. And we 23 can -- I guess we'll mark that as 11. 24 25 Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 4 of 26 Page 179 1 JOSEPH RECAREY - CONFIDENTIAL 2 (The referred-to document was marked by 3 the court reporter for Identification as 4 Deposition Exhibit 11.) 5 BY MR. PAGLIUCA: 6 Q. If you look at the -- is that what you're 7 looking at? 8 MS. SCHULTZ: That's mine. I just wanted 9 to make sure it's the same. 10 BY MR. PAGLIUCA: 11 Q. If you go into the third -- I think it's 12 the third page of that document, we then end with VI 13 17 Juno. 14 Do you see that? 15 A. Yes. 16 Q. So that would tell me that there were no 17 individuals listed as additional victims as of the 18 conclusion of your investigation in this case; is 19 that correct? 20 MS. SCHULTZ: Object to form and 21 foundation. 22 THE WITNESS: That's correct. 23 BY MR. PAGLIUCA: 24 Q. Okay. So let's stick with Exhibit 1, and 25 let's go to Narrative No. 1, which is on page 11 of Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 5 of 26 Page 180 1 JOSEPH RECAREY - CONFIDENTIAL 2 Exhibit 1. Are you with me? 3 A. Uh-huh. 4 Q. Okay. Again, this was information that 5 was obtained by Detective Pagan, correct? 6 A. Correct. 7 Q. And it's true, is it not, that this 8 alleged victim never claimed to have been recruited 9 by Ghislaine Maxwell; true? 10 MS. SCHULTZ: Object to form and 11 foundation. 12 THE WITNESS: Correct. 13 BY MR. PAGLIUCA: 14 Q. And this individual, alleged victim No. 1, 15 never identified Ghislaine Maxwell as being at 16 Mr. Epstein's house when she was there, correct? 17 MS. SCHULTZ: Object to form and 18 foundation. 19 THE WITNESS: I don't believe so. 20 BY MR. PAGLIUCA: 21 Q. You don't believe so -- 22 A. I don't believe so. 23 Q. That she ever identified Ghislaine Maxwell 24 as being in the house? 25 A. Right. Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 6 of 26 Page 181 1 JOSEPH RECAREY - CONFIDENTIAL 2 Q. Okay. She never -- this individual, 3 victim No. 1, never claimed that Ghislaine Maxwell 4 paid her any money, correct? 5 A. Correct. 6 Q. And this individual No. 1 never claimed 7 that Ms. Maxwell instructed her what to wear, 8 correct? 9 A. Right. 10 Q. This individual never claimed that 11 Ghislaine Maxwell told her how to act, correct? 12 A. Correct. 13 Q. This individual never claimed to have met 14 Ghislaine Maxwell ever, correct? 15 A. I don't believe so, no. 16 Q. This individual never claimed to even have 17 spoken to Ghislaine Maxwell ever, correct? 18 A. I don't believe so, no. 19 Q. And when you say "I don't believe so, no," 20 that means my statement to you is correct; is that 21 right? 22 MS. SCHULTZ: Object to form, foundation. 23 THE WITNESS: Well, you're saying "ever." 24 I don't know if she's ever, ever spoken to -- 25 Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 7 of 26 Page 182 1 JOSEPH RECAREY - CONFIDENTIAL 2 BY MR. PAGLIUCA: 3 Q. To Detective Pagan. 4 A. Right. To my knowledge, I don't know, 5 because Detective Pagan is the one who actually 6 interviewed her. So I don't know to the answer of 7 "ever." So not to my knowledge. 8 Q. Certainly, nothing in Exhibit 1, Narrative 9 1 reflects that this individual ever met or talked 10 to or spoke to Ghislaine Maxwell, right? 11 A. Right. Not to my knowledge. 12 Q. And, indeed, you would agree with me that 13 if this individual claimed that Ms. Maxwell had 14 something to do with the events listed in Narrative 15 1, you would have folded up on it, as the 16 investigating detective, right? 17 MS. SCHULTZ: Object to the form. 18 THE WITNESS: Either myself or Detective 19 Pagan would have. 20 BY MR. PAGLIUCA: 21 Q. Sure. And when you got the case six 22 months later, if there hadn't been follow-up, you 23 would have followed up on it, right? 24 MS. SCHULTZ: Object to form. 25 THE WITNESS: Correct. Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 8 of 26 Page 191 1 JOSEPH RECAREY - CONFIDENTIAL 2 A. Yes. 3 Q. And then you asked various individuals who 4 was there when you went to Mr. Epstein's house, 5 right? 6 A. Correct. 7 Q. And you then, to the best of your ability, 8 recorded those answers, I take it, as to who was 9 there, right? 10 A. Yes. 11 Q. And with regard to AH, she never said 12 anything about Ghislaine Maxwell being at 13 Mr. Epstein's house, did she? 14 MS. SCHULTZ: Object to form and 15 foundation. 16 BY MR. PAGLIUCA: 17 Q. To you? 18 A. I don't believe she did. 19 Q. Okay. And if she did, it's likely that 20 you would have recorded it, correct? 21 A. Correct, and it would be on the -- it 22 would be on the tape. 23 Q. Right. 24 She never claimed, , that Ms. Maxwell Jane Doe 25 paid her, right? Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 9 of 26 Page 192 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to form and 3 foundation. 4 THE WITNESS: Correct. 5 BY MR. PAGLIUCA: 6 Q. She never claimed that -- never claimed Jane Doe 7 that Ms. Maxwell instructed her about what to wear, 8 correct? 9 MS. SCHULTZ: Object to the form. 10 THE WITNESS: Correct. 11 BY MR. PAGLIUCA: 12 Q. never claimed that Ms. Maxwell told her Jane Doe 13 how to act at Mr. Epstein's house, correct? 14 MS. SCHULTZ: Object to form. 15 THE WITNESS: Correct. 16 BY MR. PAGLIUCA: 17 Q. never claimed to have met Ghislaine Jane Doe 18 Maxwell anywhere, correct? 19 MS. SCHULTZ: Object to form. 20 THE WITNESS: I don't believe so, no. 21 BY MR. PAGLIUCA: 22 Q. Okay. If we go on to individual alleged 23 victim No. 3, AY, the same question: AY never 24 identified Ms. Maxwell as someone she knew or 25 interacted with in any fashion, correct? Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 10 of 26 Page 193 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to form. 3 THE WITNESS: No. 4 BY MR. PAGLIUCA: 5 Q. No, she did not? 6 A. No, she did not. 7 Q. Okay. The same with individual No. 4, 8 alleged victim FP: Again, FP never claimed to have 9 met with Ms. Maxwell, correct? 10 MS. SCHULTZ: Object to form and 11 foundation. 12 THE WITNESS: I don't believe so, no. 13 BY MR. PAGLIUCA: 14 Q. Okay. And FP never identified Ms. Maxwell 15 as someone being at Mr. Epstein's house, correct? 16 MS. SCHULTZ: Object to form and 17 foundation. 18 BY MR. PAGLIUCA: 19 Q. And if you need to look at your report -- 20 A. No, I don't -- I don't believe so. The 21 only people that recalled Ghislaine at the house 22 was -- 23 Q. Sjoberg? 24 A. Johanna Sjoberg. 25 Q. Who was over the age of 18, correct? Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 11 of 26 Page 194 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to form and 3 foundation. 4 THE WITNESS: And Venero, Christina 5 Venero. 6 BY MR. PAGLIUCA: 7 Q. Who is an adult as well? 8 MS. O'CONNOR: Object to form. 9 THE WITNESS: Yes. 10 BY MR. PAGLIUCA: 11 Q. So out of your entire report, the only two 12 people who ever said anything about Ms. Maxwell were 13 Ms. Sjoberg, who I believe was 23 when you 14 interviewed her? 15 A. Right, but she was -- 16 MS. SCHULTZ: Object to form and 17 foundation. 18 THE WITNESS: She was -- she had worked 19 there for quite some time, so you would have to 20 back up, I think, a year or two. 21 BY MR. PAGLIUCA: 22 Q. She was an adult when she worked there? 23 A. Right. She was over the age of 18, right, 24 let's put it that way. 25 Q. And she was not listed by you as a victim Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 12 of 26 Page 195 1 JOSEPH RECAREY - CONFIDENTIAL 2 as part of this case, right? 3 A. Correct, because it was between two 4 consenting adults. 5 Q. Exactly. 6 And so that's Ms. Sjoberg, and then the 7 other individual, I think you said Bolero; is that 8 right? 9 A. Venero, Christina Venero. She's a -- 10 Q. Adult masseuse, correct? 11 A. Yes. I remember she had lots of tattoos. 12 Q. Tatts, right. 13 But the 17 individuals that you listed in 14 Exhibit 1, none of those individuals ever said the 15 word -- the words "Ghislaine Maxwell" during the 16 course of this investigation to you, correct? 17 MS. SCHULTZ: Object to form and 18 foundation. 19 THE WITNESS: I don't believe so. It 20 would be on the tapes if they did. 21 BY MR. PAGLIUCA: 22 Q. Well, or it would be in your report, 23 right? 24 MS. SCHULTZ: Object to form and 25 foundation. Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 13 of 26 Page 211 1 JOSEPH RECAREY - CONFIDENTIAL 2 A. Correct. 3 Q. And then Mr. Epstein is arrested and ends 4 up pleading guilty and all of that, right? 5 MS. SCHULTZ: Object to form. 6 THE WITNESS: I think there was a 7 non-prosecution agreement prepared between the 8 Feds and some kind of agreement was made. But, 9 yes, he did end up pleading guilty. 10 BY MR. PAGLIUCA: 11 Q. All right. 12 Now, based on the questions that were 13 asked of you in the grand jury, it's fair to say 14 that Ms. Maxwell was not a target of the grand 15 jury's investigation, correct? 16 MS. SCHULTZ: Object to form and 17 foundation. 18 THE WITNESS: Not based on the questions 19 that the state was asking me, no, the state 20 wasn't... 21 BY MR. PAGLIUCA: 22 Q. In fact, it's fair to say that you never 23 said Ms. Maxwell's name in the grand jury, right? 24 MS. SCHULTZ: Object to form and 25 foundation. Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 14 of 26 Page 212 1 JOSEPH RECAREY - CONFIDENTIAL 2 THE WITNESS: No. Based on the questions 3 that the state was asking, no. 4 BY MR. PAGLIUCA: 5 Q. Were you aware of who was being issued 6 subpoenas by the grand jury? 7 A. No. But it wasn't the actual subpoena 8 from the grand jury; it came from the State 9 Attorney's Office. 10 Q. At the direction of the grand jury, 11 though, right? 12 MS. SCHULTZ: Object to form and 13 foundation. 14 THE WITNESS: I don't know. Again, I 15 don't know. 16 BY MR. PAGLIUCA: 17 Q. I would like to talk a little bit about 18 the surveillance that you initiated at Mr. Epstein's 19 house, okay? 20 Can you tell me when the surveillance 21 began? 22 A. It would have started under Detective 23 Pagan and gone through -- 24 Q. The entire investigation? 25 A. Pretty much trash pulls. We stopped the Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 15 of 26 Page 214 1 JOSEPH RECAREY - CONFIDENTIAL 2 Q. And so these were video cameras? 3 A. Correct. 4 Q. And so whoever was coming and going, 5 whenever -- an officer saw somebody coming or going, 6 they would videotape that person; is that correct? 7 A. Or they would just leave the video 8 rolling, time lapse. 9 Q. And did you have the opportunity to 10 observe any of that video? 11 A. I did observe a couple, but the person who 12 actually set it up would review it and then submit a 13 supplement to the report. 14 Q. Okay. It's true that none of the video of 15 the surveillance led to the identification of 16 Ghislaine Maxwell as coming or leaving the house 17 during the time of surveillance, correct? 18 MS. SCHULTZ: Object to form and 19 foundation. 20 THE WITNESS: I don't know. I didn't see 21 all of the video, so I can't -- I can't attest 22 to that. 23 BY MR. PAGLIUCA: 24 Q. Okay. Did anybody report to you that 25 Ms. Maxwell was seen coming or going? Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 16 of 26 Page 215 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to form, foundation. 3 THE WITNESS: I don't recall. 4 BY MR. PAGLIUCA: 5 Q. If someone had reported to you that 6 Ms. Maxwell was seen coming or going, you would have 7 recorded it in your Palm Beach Police Department 8 incident report, Exhibit No. 1, correct? 9 MS. SCHULTZ: Object to form and 10 foundation. 11 THE WITNESS: I would have told the 12 officer who was conducting the surveillance or 13 reviewing the video to document it in the 14 supplements. 15 BY MR. PAGLIUCA: 16 Q. And there is no documentation in the 17 supplement of Ms. Maxwell either coming or going 18 from Mr. Epstein's house during this time frame, 19 correct? 20 MS. SCHULTZ: Object to the form. 21 THE WITNESS: I don't believe so. I 22 don't -- I don't -- I don't believe so. 23 BY MR. PAGLIUCA: 24 Q. And, again, so we're on the same page, 25 when you say "I don't believe so," I interpret that Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 17 of 26 Page 216 1 JOSEPH RECAREY - CONFIDENTIAL 2 as her name is not in here as someone who was 3 incoming or going; am I correct in my 4 interpretation? 5 MS. SCHULTZ: Object to form and 6 foundation. 7 THE WITNESS: Again, I don't know. I 8 don't believe so. 9 BY MR. PAGLIUCA: 10 Q. I'm just trying to understand what "I 11 don't believe so" means, okay? 12 A. I don't -- I don't believe it's in the 13 report, no. 14 Q. Okay. "I don't believe it's in the 15 report" that she was ever seen coming or going, 16 right? 17 A. Right, that's what I'm saying. 18 Q. All right. We're on the same page. 19 The trash pulls, do you recall how many 20 trash pulls were done? 21 A. There were numerous trash pulls done. 22 There was trash pulls down under Detective Pagan and 23 under my request. 24 Q. As I understand the trash pull protocol, 25 you or someone at your direction or Detective Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 18 of 26 Page 257 1 JOSEPH RECAREY - CONFIDENTIAL 2 A. I don't believe clothing was seized. 3 Q. To your knowledge, did you seize any 4 property belonging to Ghislaine Maxwell from the 5 home? 6 MS. SCHULTZ: Object to form and 7 foundation. 8 THE WITNESS: I'm not sure. Not to my 9 knowledge. 10 BY MS. SCHULTZ: 11 Q. Okay. No one ever came to you and said, 12 Could you please return these items to Ms. Maxwell, 13 correct? 14 MS. SCHULTZ: Object to form. 15 THE WITNESS: No. 16 BY MS. SCHULTZ: 17 Q. All right. 18 You did that with Janush? 19 A. Yes, he had photos and -- 20 Q. But nothing like that ever happened with 21 Ms. Maxwell, correct? 22 MS. SCHULTZ: Object to form. 23 THE WITNESS: No. 24 BY MS. SCHULTZ: 25 Q. Ms. Maxwell was not present when you Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 19 of 26 Page 288 1 JOSEPH RECAREY - CONFIDENTIAL 2 Did you observe any child pornography when 3 you were in Mr. Epstein's home? 4 MS. SCHULTZ: Object to form. 5 THE WITNESS: Not in that area where I was 6 at, no. 7 BY MR. PAGLIUCA: 8 Q. Well, you had to walk into the house, 9 right? Through an entranceway? 10 A. Yes. 11 Q. You didn't observe any child pornography 12 in the entranceway, correct? 13 A. No. 14 Q. And then you had to walk from the 15 entranceway to where the office was, correct? 16 A. Which was straight back, it was right 17 there. 18 Q. You are going through a hallway and a kind 19 of an open area, correct? 20 A. Correct. 21 Q. You didn't observe any pictures of 22 neighborhood children when you were walking through 23 that area, did you? 24 A. I don't recall. 25 Q. That's something that would have stuck out Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 20 of 26 Page 289 1 JOSEPH RECAREY - CONFIDENTIAL 2 in your mind, right? Correct? 3 MS. SCHULTZ: Object to the form. 4 THE WITNESS: Yes. 5 BY MR. PAGLIUCA: 6 Q. And you're a peace officer, obligated to 7 arrest when a felony is committed in your presence, 8 correct? 9 A. Correct. 10 Q. And the possession of child pornography is 11 a felony, correct? 12 A. Correct. 13 Q. And had you seen any child pornography in 14 Mr. Epstein's house when you were there installing 15 these cameras, you would have done something about 16 it, correct? 17 MS. SCHULTZ: Object for form. 18 THE WITNESS: Right. 19 BY MR. PAGLIUCA: 20 Q. You wouldn't have just walked out and 21 said, Nice pics, have a nice day, correct? 22 A. Correct. 23 Q. So is it fair to say the entire time you 24 were in Epstein's house, whether it's 2002, 2003, 25 you did not observe any child pornography, right? Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 21 of 26 Page 290 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to the form. 3 THE WITNESS: Not in the areas I was in. 4 BY MR. PAGLIUCA: 5 Q. You don't recall seeing any pictures of 6 naked women, do you? 7 MS. SCHULTZ: Object to form. 8 THE WITNESS: Again, I was only confined 9 to where that desk was. That's where I set up 10 the camera, and then after it was set up, I 11 left. 12 BY MR. PAGLIUCA: 13 Q. Okay. But, again, all I'm asking you is 14 wherever you were, you didn't see any pictures of 15 naked women? 16 A. Right. No, I didn't see any. 17 Q. And at the time you recall that he had 18 these surveillance cameras already installed; is 19 that true? Other cameras, the clock cameras? 20 MS. SCHULTZ: Object to form. 21 THE WITNESS: I'm not sure if he had the 22 cameras installed or not. I can't recall. 23 BY MR. PAGLIUCA: 24 Q. Why would he need your cameras if he 25 already had cameras? Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 22 of 26 Page 300 1 JOSEPH RECAREY - CONFIDENTIAL 2 None of these alleged victims claimed to 3 have ever traveled with Mr. Epstein, correct? 4 MS. SCHULTZ: Object to form. 5 THE WITNESS: No. 6 BY MR. PAGLIUCA: 7 Q. No, they did not? They did not travel 8 with Mr. Epstein, right? 9 MS. SCHULTZ: Object to form. 10 THE WITNESS: I don't believe so, no. 11 BY MR. PAGLIUCA: 12 Q. None of them reported that to you? 13 A. Not reported, correct. 14 Q. None of them reported to you that they 15 ever spent the night with Mr. Epstein, did they? 16 MS. SCHULTZ: Object to form. 17 THE WITNESS: I don't believe so. 18 BY MR. PAGLIUCA: 19 Q. None of them ever reported being 20 trafficked by Mr. Epstein to other men, correct? 21 MS. SCHULTZ: Object to form, foundation. 22 THE WITNESS: I don't believe so. 23 BY MR. PAGLIUCA: 24 Q. The only other men that any of these 25 alleged victims -- the only man that any of these Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 23 of 26 Page 301 1 JOSEPH RECAREY - CONFIDENTIAL 2 alleged victims ever claimed to have any contact 3 with that was sexual in nature was Mr. Epstein, 4 correct? 5 MS. SCHULTZ: Object to form and 6 foundation. 7 THE WITNESS: Yes. 8 BY MR. PAGLIUCA: 9 Q. Okay. None of these alleged victims ever 10 claimed to have been sent to another location to 11 have sex with another man, correct? 12 MS. SCHULTZ: Object to form and 13 foundation. 14 THE WITNESS: I don't believe so. 15 BY MR. PAGLIUCA: 16 Q. Meaning my statement is correct; is that 17 right? 18 MS. SCHULTZ: Object to form. 19 BY MR. PAGLIUCA: 20 Q. I'm just trying to -- 21 A. Meaning I don't believe they've ever said 22 that. I don't recall any of them ever saying... 23 Q. Had they claimed that they were sent 24 somewhere else to have sex with another man, you 25 would have followed up on that, correct? Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 24 of 26 Page 302 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to form. 3 THE WITNESS: Correct. 4 BY MR. PAGLIUCA: 5 Q. And none of them ever claimed to have been 6 sent to another location to give another man a 7 massage, correct? 8 MS. SCHULTZ: Object to form. 9 THE WITNESS: No, not the victims. 10 BY MR. PAGLIUCA: 11 Q. Right. That's who I'm talking about. 12 A. I believe Sjoberg did. 13 Q. Who is an adult, right? 14 MS. SCHULTZ: Object to form. 15 THE WITNESS: Right. 16 BY MR. PAGLIUCA: 17 Q. We covered this, I believe: None of them 18 ever was on Mr. Epstein's airplane, correct? 19 MS. SCHULTZ: Object to form. 20 THE WITNESS: I believe one of the victims 21 were, but not to a private island. I think 22 they went -- they didn't go to a private 23 island; they went to some other trip. 24 BY MR. PAGLIUCA: 25 Q. I think maybe you're referring to AH, who Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 25 of 26 Page 303 1 JOSEPH RECAREY - CONFIDENTIAL 2 went to New York but on a commercial flight. Does 3 that jog your memory? 4 MS. SCHULTZ: Object to form. 5 THE WITNESS: No. 6 BY MR. PAGLIUCA: 7 Q. Okay. Do you recall who it is? 8 A. It would have been FP. 9 Q. Okay. Was on Mr. Epstein's airplane? 10 MS. SCHULTZ: Object to form. 11 THE WITNESS: I believe so. 12 BY MR. PAGLIUCA: 13 Q. Would that be reflected in Exhibit 1? 14 MS. SCHULTZ: Object to form. 15 THE WITNESS: But she flew alone. It 16 wasn't like Epstein was there. She went 17 someplace else, not to his private island, 18 nothing to do with Epstein. It was something 19 she wanted to do. And I think she flew on his 20 plane, but it was, like, her by herself. 21 BY MR. PAGLIUCA: 22 Q. Alone. 23 A. Right. 24 Q. With a pilot? 25 A. Right. Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 26 of 26 Page 334 1 JOSEPH RECAREY - CONFIDENTIAL 2 BY MS. SCHULTZ: 3 Q. Was it your impression at the time that 4 those statements could incriminate her? 5 MR. PAGLIUCA: Object to form and 6 foundation. 7 THE WITNESS: Yes. 8 BY MS. SCHULTZ: 9 Q. You testified earlier that you interviewed 10 approximately 30 or 33 girls, correct? 11 THE WITNESS: Yes. 12 MR. PAGLIUCA: Object to form and 13 foundation. 14 BY MS. SCHULTZ: 15 Q. Did the course of your investigation -- 16 through the course of your investigation, did you 17 find that all 30 or 33 of the girls knew one 18 another? 19 MR. PAGLIUCA: Object to form and 20 foundation. 21 THE WITNESS: Some did, some did not. 22 BY MS. SCHULTZ: 23 Q. Okay. Among the girls who did not know 24 one another, were their accounts of what happened at 25 Jeffrey Epstein's house similar? Case 1:15-cv-07433-LAP Document 1328-3 Filed 01/05/24 Page 1 of 14 EXHIBIT H  Case 1:15-cv-07433-LAP Document 1328-3 Filed 01/05/24 Page 2 of 14 Video Deposition of Tony Figueroa (Volume 1) 1 1 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 3 CASE: 15-cv-07433-RWS 4 VIRGINIA GIUFFRE, 5 Plaintiff, 6 v. 7 GHISLAINE MAXWELL, 8 Defendant. 9 _ _ _ _ _ _ _! 10 VIDEOTAPED DEPOSITION OF TONY FIGUEROA 11 Volume 1 of 2 12 Pages 1 - 157 13 14 15 Taken at the Instance of the Defendant 16 17 DATE: Friday, June 24, 2016 18 TIME: Commenced: 8:59 a.m. 19 Concluded: 1:22 p.m. 20 PLACE: Southern Reporting Company B. Paul Katz Professional Center 21 (SunTrust Building) One Florida Park Drive South 22 Suite 214 Palm Coast, Florida 32137 23 REPORTED BY: LEANNE W. FITZGERALD, FPR 24 Florida Professional Reporter Court Reporter and Notary Public 25 Southern Reporting Company (386)257-3663  Case 1:15-cv-07433-LAP Document 1328-3 Filed 01/05/24 Page 3 of 14 :MHIS (ITSWMXMSR SJ 8SR] *MKYIVSE :SPYQI    5 =SY HMHR X ORS[ LIV XS [SVO EX ER] VIXEMP  TPEGIW#  % 2SX XLEX - Q E[EVI SJ  5 (S ]SY VIGEPP LIV [SVOMRK EW E [EMXVIWW#  % - FIPMIZI WS ]IW  5 ;LIR [EW XLEX#  % - HSR X ORS[ XLI I\EGX HEXI  5 ;EW MX [LMPI ]SYEPP [IVI HEXMRK#  % - Q TVIXX]  MX QMKLX LEZI FIIR ]IW  5 (MH ]SY IZIV KS XS LIV VIWXEYVERX#  % 2S - HMH RSX LEZI E GEV  5 (MH 1W 6SFIVXW LEZI E GEV#  % 7LI HMH ]IEL  5 ;LEX OMRH SJ GEV HMH WLI LEZI#  % -X [EW E  - Q TVIXX] WYVI MX [EW E  [LMXI  E [LMXI 4SRXMEG - XLMRO MX [EW EX JMVWX  5 0MOI E #  % =IEL - XLMRO WS %RH XLIR WLI IRHIH YT  FY]MRK E XVYGO  5 ;LIR HMH WLI FY] XLI XVYGO#  % -X [EW E PMXXPI FMX FIJSVI WLI PIJX FYX  RSX XSS PSRK  5 ;LEX OMRH SJ XVYGO#  % -X [EW E (SHKI (EOSXE I\XIRHIH GEF  5 (S ]SY ORS[ [LEX LETTIRIH XS XLEX [LIR WLI 7SYXLIVR 6ITSVXMRK 'SQTER]    Case 1:15-cv-07433-LAP Document 1328-3 Filed 01/05/24 Page 4 of 14 :MHIS (ITSWMXMSR SJ 8SR] *MKYIVSE :SPYQI    HMH RSX GSQI FEGO JVSQ 8LEMPERH#  % =IEL - 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