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ict Attorney, Sex Crimes Unit / Trial Bureau 40 New York District Attorneys Office One Hogan Place New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYS1D # OS1909, Supreme Court Case # 30129-2010 Dear ADA Gaffney and ADA Egan: As you know, we represent Jeffrey E. Epstein, who is scheduled to
ieve expose the stark contrast between the inflammatory, speculative case summary presented by the Board of Examiners in its recommendation for Mr. Epstein, and the actual evidence that exists concerning the alleged conduct for which New York seeks to require Mr. Epstein to register under SORA. We beli
New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYS1D # OS1909, Supreme Court Case # 3
New York, NY 10013 Re: SORA Determination for Jeffrey E. Epstein, NYS1D # OS1909, Supreme Court Case # 30
the Board of Examiners in its recommendation for Mr. Epstein, and the actual evidence that exists concerning
l have a date in the report as to how long before October 10 and 11, 2005 that single event occurred, then she didn't remember, is that right? MS. ARDOUR: Pone. THE WITNESS: Can you ask that question one more time? BY MR. WEINBERG: Q. Sure. If there's no date for that — A. Then she did not recall
10 - - - EXHIBITS 11 12 NUMBER DESCRIPTION PAGE 13 DEPOSITION EX. 29 MESSAGE BOOKS 592 DEPOSITION EX. 30 HANDWRITTEN NOTE ON 617 14 JEFFREY E. EPSTEIN MEMO PAD 15 DEPOSITION EX. 31 HANDWRITTEN MESSAGE 622 16 17 18 19 20 21 22 23 24 25 1 counsel? 2 MS. ARBOUR: Form. 3 THE WITNESS
re talking about right before the recess, do you ever recall dicr-ncsions with the State Attorney's office about an offer that was extended to Mr. Epstein to plead guilty and receive a five-year period of probation for an aggravated assault charge? A. Yes. Q. And that was a subject of discussion bet
DEPOSITION EX. 30 HANDWRITTEN NOTE ON 617 14 JEFFREY E. EPSTEIN MEMO PAD 15 DEPOSITION EX. 31 HANDWR
DEPOSITION EX. 30 HANDWRITTEN NOTE ON 617 14 JEFFREY E. EPSTEIN MEMO PAD 15 DEPOSITION EX. 31 HANDWRI
ney's office about an offer that was extended to Mr. Epstein to plead guilty and receive a five-year period o
0298342 Page 504 Page 506 1 INDEX 2 3 I wrrNESS: COMM CROSS CROSS REDIRECT RECROSS 5 DETECTIVE JOE RECAREY 6 BY MR. WEINBERG 505 BY MS. ARDOUR 636 7 BY MR. GARCIA 636 9 10 - - - EXHIBITS 11 12 NUMBER DESCRIPTION PAGE 13 DEPOSITION EX. 29 MESSAGE BOOKS 592 DEPOSITION EX. 30
ch Police Department in March of 2005, correct? A. Coned. • • Q. And they had overheard some conversation about what .. claimed to have done at Jeffrey Epstein's house, correct? • A. Correct. Q. And that they were not saying, my daughter came to me and said, please call the police, something happened to
that would be your personal summary of the interview 5 that you were conducting with one of the many people 6 that gave you information about Mr. Epstein? A. Correct. 8 Q. And it was always your practice in this case 9 to then destroy the notes that you used as a basis for 10 that typed summary;
13 know if it was exactly lingerie or... 14 Q. Okay. The father had communicated to you that 15 his daughter had told him that her connection to Jeffrey 16 Epstein was that she went to see him as a model? 17 A. Yes. 18 Q. In other words, what you took from talking to 19 the father is that M. h
e many people 6 that gave you information about Mr. Epstein? A. Correct. 8 Q. And it was always your pract
onically signed by Jeans Medlin (601 Electronically signed by Jeans Riccluti (601 e6082637-abel-48204836-be614•314dra EFTA00298232 Page 396 MS. ARDOUR: Same objection. 2 THE WITNESS: Pretty much. I mean, you 3 4 BY MR. WEINBERG: 5 Q. Did you ever conduct a criminal investigation 6 of Ms. M.
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