EXHIBIT Case Document Filed Page of Page UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO VIRGINIA GIUFFRE Plaintiff GHISLAINE MAXWELL Defendant June a.m I I A Deposition of JOSEPH RECAREY pursuant to notice taken by Plaintiff at the offices of Boies Schiller Flexner 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 Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL BY MR PAGLIUCA Then theres a category victim information and then we have listed I believe a total of individuals that the Palm Beach Police Department incident report lists as alleged victims in this case correct A Correct And are you aware as to whether or not that list was supplemented after July 25th in the investigative incident report A Im not sure if it was updated or not MR PAGLIUCA I dont know if we want to mark this or not I can hand you what I believe to be a more recent or I think you actually brought one with you THE WITNESS I did MS SCHULTZ If youre talking about the document that he brought with him I had it Bates labeled MR PAGLIUCA We can show him that I think I have the same document here And we can I guess well mark that as Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL The referred-to document was marked by the court reporter for Identification as Deposition Exhibit BY MR PAGLIUCA If you look at the is that what youre looking at MS SCHULTZ Thats mine I just wanted to make sure its the same BY MR PAGLIUCA If you go into the third I think its the third page of that document we then end with VI Juno Do you see that A Yes So that would tell me that there were no individuals listed as additional victims as of the conclusion of your investigation in this case is that correct MS SCHULTZ Object to form and foundation THE WITNESS Thats correct BY MR PAGLIUCA Okay So lets stick with Exhibit and lets go to Narrative No which is on page of Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL Exhibit Are you with me A Uh-huh Okay Again this was information that was obtained by Detective Pagan correct A Correct And its true is it not that this alleged victim never claimed to have been recruited by Ghislaine Maxwell true MS SCHULTZ Object to form and foundation THE WITNESS Correct BY MR PAGLIUCA And this individual alleged victim No never identified Ghislaine Maxwell as being at Mr Epsteins house when she was there correct MS SCHULTZ Object to form and foundation THE WITNESS I dont believe so BY MR PAGLIUCA You dont believe so A I dont believe so That she ever identified Ghislaine Maxwell as being in the house A Right Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL Okay She never this individual victim No never claimed that Ghislaine Maxwell paid her any money correct A Correct And this individual No never claimed that Ms Maxwell instructed her what to wear correct A Right This individual never claimed that Ghislaine Maxwell told her how to act correct A Correct This individual never claimed to have met Ghislaine Maxwell ever correct A I dont believe so no This individual never claimed to even have spoken to Ghislaine Maxwell ever correct A I dont believe so no And when you say I dont believe so no that means my statement to you is correct is that right MS SCHULTZ Object to form foundation THE WITNESS Well youre saying ever I dont know if shes ever ever spoken to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL BY MR PAGLIUCA To Detective Pagan A Right To my knowledge I dont know because Detective Pagan is the one who actually interviewed her So I dont know to the answer of ever So not to my knowledge Certainly nothing in Exhibit Narrative reflects that this individual ever met or talked to or spoke to Ghislaine Maxwell right A Right Not to my knowledge And indeed you would agree with me that if this individual claimed that Ms Maxwell had something to do with the events listed in Narrative you would have folded up on it as the investigating detective right MS SCHULTZ Object to the form THE WITNESS Either myself or Detective Pagan would have BY MR PAGLIUCA Sure And when you got the case six months later if there hadnt been follow-up you would have followed up on it right MS SCHULTZ Object to form THE WITNESS Correct Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL A Yes And then you asked various individuals who was there when you went to Mr Epsteins house right A Correct And you then to the best of your ability recorded those answers I take it as to who was there right A Yes And with regard to she never said anything about Ghislaine Maxwell being at Mr Epsteins house did she MS SCHULTZ Object to form and foundation BY MR PAGLIUCA To you A I dont believe she did Okay And if she did its likely that you would have recorded it correct A Correct and it would be on the it would be on the tape Right She never claimed that Ms Maxwell paid her right Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL MS SCHULTZ Object to form and foundation THE WITNESS Correct BY MR PAGLIUCA She never claimed that never claimed that Ms Maxwell instructed her about what to wear correct MS SCHULTZ Object to the form THE WITNESS Correct BY MR PAGLIUCA never claimed that Ms Maxwell told her how to act at Mr Epsteins house correct MS SCHULTZ Object to form THE WITNESS Correct BY MR PAGLIUCA never claimed to have met Ghislaine Maxwell anywhere correct MS SCHULTZ Object to form THE WITNESS I dont believe so no BY MR PAGLIUCA Okay If we go on to individual alleged victim No AY the same question AY never identified Ms Maxwell as someone she knew or interacted with in any fashion correct Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL MS SCHULTZ Object to form THE WITNESS No BY MR PAGLIUCA No she did not A No she did not Okay The same with individual No alleged victim FP Again FP never claimed to have met with Ms Maxwell correct MS SCHULTZ Object to form and foundation THE WITNESS I dont believe so no BY MR PAGLIUCA Okay And FP never identified Ms Maxwell as someone being at Mr Epsteins house correct MS SCHULTZ Object to form and foundation BY MR PAGLIUCA And if you need to look at your report A No I dont I dont believe so The only people that recalled Ghislaine at the house was Sjoberg A Johanna Sjoberg Who was over the age of correct Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL MS SCHULTZ Object to form and foundation THE WITNESS And Venero Christina Venero BY MR PAGLIUCA Who is an adult as well MS OCONNOR Object to form THE WITNESS Yes BY MR PAGLIUCA So out of your entire report the only two people who ever said anything about Ms Maxwell were Ms Sjoberg who I believe was when you interviewed her A Right but she was MS SCHULTZ Object to form and foundation THE WITNESS She was she had worked there for quite some time so you would have to back up I think a year or two BY MR PAGLIUCA She was an adult when she worked there A Right She was over the age of right lets put it that way And she was not listed by you as a victim Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL as part of this case right A Correct because it was between two consenting adults Exactly And so thats Ms Sjoberg and then the other individual I think you said Bolero is that right A Venero Christina Venero Shes a Adult masseuse correct A Yes I remember she had lots of tattoos Tatts right But the individuals that you listed in Exhibit none of those individuals ever said the word the words Ghislaine Maxwell during the course of this investigation to you correct MS SCHULTZ Object to form and foundation THE WITNESS I dont believe so It would be on the tapes if they did BY MR PAGLIUCA Well or it would be in your report right MS SCHULTZ Object to form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL A Correct And then Mr Epstein is arrested and ends up pleading guilty and all of that right MS SCHULTZ Object to form THE WITNESS I think there was a non-prosecution agreement prepared between the Feds and some kind of agreement was made But yes he did end up pleading guilty BY MR PAGLIUCA All right Now based on the questions that were asked of you in the grand jury its fair to say that Ms Maxwell was not a target of the grand jurys investigation correct MS SCHULTZ Object to form and foundation THE WITNESS Not based on the questions that the state was asking me no the state wasnt BY MR PAGLIUCA In fact its fair to say that you never said Ms Maxwells name in the grand jury right MS SCHULTZ Object to form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL THE WITNESS No Based on the questions that the state was asking no BY MR PAGLIUCA Were you aware of who was being issued subpoenas by the grand jury A No But it wasnt the actual subpoena from the grand jury it came from the State Attorneys Office At the direction of the grand jury though right MS SCHULTZ Object to form and foundation THE WITNESS I dont know Again I dont know BY MR PAGLIUCA I would like to talk a little bit about the surveillance that you initiated at Mr Epsteins house okay Can you tell me when the surveillance began A It would have started under Detective Pagan and gone through The entire investigation A Pretty much trash pulls We stopped the Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL And so these were video cameras A Correct And so whoever was coming and going whenever an officer saw somebody coming or going they would videotape that person is that correct A Or they would just leave the video rolling time lapse And did you have the opportunity to observe any of that video A I did observe a couple but the person who actually set it up would review it and then submit a supplement to the report Okay Its true that none of the video of the surveillance led to the identification of Ghislaine Maxwell as coming or leaving the house during the time of surveillance correct MS SCHULTZ Object to form and foundation THE WITNESS I dont know I didnt see all of the video so I cant I cant attest to that BY MR PAGLIUCA Okay Did anybody report to you that Ms Maxwell was seen coming or going Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL MS SCHULTZ Object to form foundation THE WITNESS I dont recall BY MR PAGLIUCA If someone had reported to you that Ms Maxwell was seen coming or going you would have recorded it in your Palm Beach Police Department incident report Exhibit No correct MS SCHULTZ Object to form and foundation THE WITNESS I would have told the officer who was conducting the surveillance or reviewing the video to document it in the supplements BY MR PAGLIUCA And there is no documentation in the supplement of Ms Maxwell either coming or going from Mr Epsteins house during this time frame correct MS SCHULTZ Object to the form THE WITNESS I dont believe so I dont I dont I dont believe so BY MR PAGLIUCA And again so were on the same page when you say I dont believe so I interpret that Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL as her name is not in here as someone who was incoming or going am I correct in my interpretation MS SCHULTZ Object to form and foundation THE WITNESS Again I dont know I dont believe so BY MR PAGLIUCA Im just trying to understand what I dont believe so means okay A I dont I dont believe its in the report no Okay I dont believe its in the report that she was ever seen coming or going right A Right thats what Im saying All right Were on the same page The trash pulls do you recall how many trash pulls were done A There were numerous trash pulls done There was trash pulls down under Detective Pagan and under my request As I understand the trash pull protocol you or someone at your direction or Detective Case Document Filed Page of MAGNA9 LEGAL SERVICES Page JOSEPH RECAREY CONFIDENTIAL A I dont believe clothing was seized To your knowledge did you seize any property belonging to Ghislaine Maxwell from the home MS SCHULTZ Object to form and foundation THE WITNESS Im not sure Not to my knowledge BY MS SCHULTZ Okay No one ever came to you and said Could you please return these items to Ms Maxwell correct MS SCHULTZ Object to form THE WITNESS No BY MS SCHULTZ All right You did that with Janush A Yes he had photos and But nothing like that ever happened with Ms Maxwell correct MS SCHULTZ Object to form THE WITNESS No BY MS SCHULTZ Ms Maxwell was not present when you Case Document Filed Page of MAGNA9 LEGAL SERVICES
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