291-28.pdf

EXHIBIT 29 Case 9:08-cv-80736-KAM Document 291-28 Entered on FLSD Docket 01/21/2015 Page 1 of 5 Case 9:08-cv-80736-KAM Document 291-28 Entered on FLSD Docket 01/21/2015 Page 2 of 5 Page 2 Page 4 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 1 APPEARANCES: CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 On behalf of the Plaintiffs, B.B., C.L.: 2 CASE No.502008CA037319XXXXMB AB 3 SPENCER T. KUVIN, ESQUIRE LEOPOLD KUVIN 3 4 2925 PGA Boulevard B.B. Suite 200 4 5 Palm Beach Gardens, Florida 33410 Plaintiff, Phone: 561.515.1400 5 6 6 -vs- VOLUME I OF II 7 On behalf of the Plaintiffs, L.M., E.W. and 7 JEFFREY EPSTEIN Jane Doe: 8 AND SARAH KELLEN, 9 BRADLEY J. EDWARDS, ESQUIRE 8 FARMER, JAFFE, WEISSING, EDWARDS Defendants. 10 FISTOS & LEHRMAN, P.L. 9 I 425 North Andrews Avenue 10 11 Suite 2 11 Fort Lauderdale, Florida 33301 12 DEPOSffiON OF 12 Phone: 954.524.2820 13 On behalf of Jane Does 1 through 8: DETECTIVE JOSEPH RECAREY 14 JESSICA ARBOUR, ESQUIRE 13 MERMELSTEIN & HOROWITZ, P.A. 14 Friday, March 19, 2010 15 18205 Biscayne Boulevard 15 9:37 - 5: 12 p.m. Suite 2218 16 250 Australian A venue South 16 Miami, Florida 33160 Suite 1500 Phone: 305.931.2200 17 West Palm Beach, Florida 33401 17 E-mail: Ahorowitz@sexabuseattomey.com 18 On behalf of the Plaintiffs: Jane Does 101, 102 and 18 103: 19 19 20 20 KATHERINE W. EZELL, ESQUIRE 21 PODHURST ORSECK 22 Reported By: 21 25 West Flagler Street Cynthia Hopkins, RPR, FPR Suite 800 22 Miami, Florida 33130 23 Notary Public, State of Florida Phone: 305.358.2382 Prose Court Reporting 23 (Via telephone) 24 Job No.: 1509 24 25 25 ,,,,-.... Page 3 Page 5 1 1 Appearances continued ... 2 UNITED STATES DISTRICT COURT 2 On behalf of the Plaintiffs: SOUTHERN DISTRICT OF FLORIDA 3 ISIDRO MANUEL GARCIA, ESQUIRE GARCIA, ELKINS & BOEHRINGER 3 4 224 Datura A venue, Suite 900 CASE NO. 10-80309 West Palm Beach, Florida 33401 4 5 Phone: 561.832.8033 5 JANE DOE NO. 103, 6 and 7 TARA A FINNIGAN, ESQUIRE 6 Plaintiff, TARA A FINNIGAN, P.A. 7 -vs- VOLUME I OF II 8 224 Datura Street 8 JEFFREY EPSTEIN, Suite 900 9 Defendant. 9 West Palm Beach, Florida 33401 I Phone: 561.835.8115 10 10 11 On behalf of the Defendant, Jeffrey Epstein: 11 12 MICHAEL PIKE, ESQUIRE 12 DEPOSITION OF BURMAN, CRITTON, LUTTIER & COLEMAN, LLP DETECTIVE JOSEPH RECAREY 13 303 Banyan Boulevard 13 Suite 400 14 West Palm Beach, Florida 33401 14 Friday, March 19, 2010 Phone: 561.842.2820 15 9:37 - 5: 12 p.m. 15 16 250 Australian A venue South 16 and Suite 1500 17 JACK ALAN GOLDBERGER, ESQUIRE ATTERBURY, GOLDBERGER & WEISS, P.A. 17 West Palm Beach, Florida 33401 18 250 Australian Avenue South 18 Suite 1400 19 19 West Palm Beach, Florida 33401-5012 20 Phone: 561.659.8300 20 21 21 and 22 Reported By: 22 MIL TONG. WEINBERG, ESQUIRE Cynthia Hopkins, RPR, FPR LAW OFFICE OF MIL TON G. WEINBERG 23 Notary Public, State of Florida 23 20 Park Plaza Prose Court Reporting Suite 1000, 24 Boston, Massachusetts 02116 24 Job No.: 1509 Phone: 617.227.3700 , 25 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. 2 (Pages 2 to 5) (561) 832-7506 Case 9:08-cv-80736-KAM Document 291-28 Entered on FLSD Docket 01/21/2015 Page 3 of 5 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 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 279 Q. I mean, I'm sorry for such a bad question, 1 but in looking at these property receipts, I just 2 don't see where it tells me how much time each 3 interview had taken. So, I mean, is there an 4 average? 5 A. That's not going to indicate on any property 6 receipt. There is no... 7 Q. Right. Okay. Have you ever seen the 8 nonprosecution agreement? 9 A. No. 10 Q. Have you ever seen the attached list of 11 victims that was attached as an addendum to the 12 nonprosecution agreement? 13 MR. PIKE: Form. 14 THE WI1NESS: I believe the Chiefhad a 15 copy ofit. He may have, you know, done one of 16 these, but, no, not in my physical hands. 1 7 MR. PIKE: And just for the record when 18 the witness said -- 1 9 THE WI1NESS: I held it up. 2 o MR. PIKE: -- one of these, he held up 21 Exhibit 29. 2 2 MR. EDWARDS: Which said memorandum. 2 3 MR. PIKE: Memorandum. 2 4 THE WI1NESS: I just held it up. 2 5 Page 280 BY MR.EDWARDS: 1 Q. If a memorandum exists and it is the 2 attached addendum to the nonprosecution agreement 3 containing the names of the underage victims, would 4 that be something in the possession currently of the 5 Palm Beach Police Department? 6 MR. PIKE: Form. 7 THE WITNESS: I don't believe so. 8 BY MR.EDWARDS: 9 Q. Is that something that's been destroyed or 1 0 also -- 11 MR. PIKE: Form. 12 THE WITNESS: I never received a copy of 13 it so... 14 BY MR. EDWARDS: 15 Q. Have you ever seen it? 16 A. Like I said, I may have seen it. I may have 1 7 been shown it, you know, and just by holding it up and I 18 am only using this exhibit as an example. It may have 19 been just shown to me like this but not in my hands 2 0 where I actually read the entire document. 21 MR. PIKE: Move to strike. 2 2 BY MR.EDWARDS: 2 3 Q. In your investigation, did you prepare a 2 4 flight log summary? 2 5 Page 281 A. I remember getting documents from Alan Dershowitz which were flight logs pertaining to Mr. Epstein's plane. And I subpoenaed the information from Jet Aviation, but I don't, I don't recall preparing a flight log. Q. Okay. Do you remember receiving information from Jet Aviation directly? MR. PIKE: Form. THE WITNESS: Jet Aviation does not keep records according to them as to who flies on what plane. I guess you can just drive up to a plane, board it. They have no idea who's on the, who is flying on the plane. They have records of when the plane comes in, if the plane is serviced, and when the plane leaves. BYMR. EDWARDS: Q. Did you ever attempt to check with customs or FAA on any of the passengers that have ever been on international flights with Jeffrey Epstein or on his planes? MR. PIKE: Form. THE WITNESS: I'm trying to recall. BYMR.EDWARDS: Q. At the current time do you have any knowledge of that being done by either the U.S. Page 282 Attorney's office or the FBI? A. I have no idea what the FBI does. They are primarily one way. You give them the information and nothing comes back, so ... Q. I am starting to get that idea. I am understanding that. Okay. A. But you know, and I work with them almost on a daily basis, so I am in direct contact with them. And still I have yet to see information come back the other way. Q. Just so the record is clear, when you say you're working with them on a daily basis, when you're in the Organized Crime Unit on other cases, correct? A. Yeah, and I am also assigned to the JTTF, the Joint Terrorism Task force here in West Palm Beach. Q. My understanding from reading your reports is that you also subpoenaed phone records of numer