EXHIBIT 4 (File Under Seal)¶
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK¶
CASE NO. 15-CV-07433-RWS¶
x,¶
v . GHISLAINE MAXWELL, Plaintiff, Defendant.¶
June 21, 2016 9:17 a.m.¶
CONFIDENTIAL Deposition of 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.
¶
2 Ghislane Maxwell?¶
3 A. I wanted to speak with everyone related to 4 this home, including Ms. Maxwell. My contact was 5 through Gus, Attorney Gus Fronstin, at the time, who 6 initially had told me that he would make everyone 7 available for an interview. And subsequent 8 conversations later, no one was available for 9 interview and everybody had an attorney, and I waf 10 not going to be able to speak with them.¶
11 Q. Okay. During your investigation, what did 12 you learn in terms of Ghislane Maxwell's 13 involvement, if any?¶
14 MR. PAGLIUCA: Object to form and 15 foundation.¶
16 THE WITNESS: Ms. Maxwell, during her 17 research, was found to be Epstein's long-time 18 friend. During the interviews, Ms. Maxwell was 19 involved in seeking girls to perform massages 20 and work at Epstein's home.¶
21 MR. PAGLIUCA: Object to form and 22 foundation.¶
23 BY MR. -:¶
24 Q. Did you interview -- how many girls did 25 you interview that were sought to give or that¶
2 actually gave massages at Epstein's home?¶
3 MR. PAGLIUCA: Object to form and 4 foundation.¶
5 BY MR. -:¶
6 Q. Approximately.¶
7 MR. PAGLIUCA: Same objection.¶
8 THE WITNESS: I would say approximately 9 30; 30, 33.¶
10 BY MR. -:¶
11 Q. And of the 30, 33 or so girls, how many 12 had massage experience?¶
13 MR. PAGLIUCA: Object to form and 14 foundation.¶
15 THE WITNESS: I believe two of them may 16 have been -- two of them.¶
17 BY MR. -:¶
18 Q. Okay. And as we go through this report, 19 you may remember the names?¶
20 A. Correct. Let me correct myself. I 21 believe only one had.¶
22 Q. And was that -- was that one of similar 23 age to the other girls?¶
24 MR. PAGLIUCA: Object to form and 25 foundation.¶
2 THE WITNESS: No.¶
3 BY MR. -:¶
4 Q. Okay. The one with massage experience was 5 older?¶
6 MR. PAGLIUCA: Object to form and 7 foundation.¶
8 THE WITNESS: Correct.¶
9 BY MR. -:¶
10 Q. The remainder of the 30 girls that went to 11 this house for the purposes of massage or recruited 12 for massage, is it my understanding that they had no 13 massage experience?¶
14 MR. PAGLIUCA: Object to form and 15 foundation.¶
16 THE WITNESS: That's correct.¶
17 BY MR. -:¶
18 Q. And were the majority of those girls that 19 you interviewed over or under the age of 18?¶
20 MR. PAGLIUCA: Object to form and 21 foundation.¶
22 THE WITNESS: The majority were under.¶
23 BY MR. -:¶
24 Q. And how was it that Mr. Epstein gained 25 access to that number of underaged girls?¶
2 MR. PAGLIUCA: Object to form and 3 foundation.¶
4 THE WITNESS: Each of the victims that 5 went to the home were asked to bring their 6 friends to the home. Some complied and some 7 didn't.¶
8 BY MR. -:¶
9 Q. Okay. So the victim would come to the 10 home and could give a massage and get paid for it; 11 is that right?¶
12 MR. PAGLIUCA: Object to form and 13 foundation.¶
14 THE WITNESS: Correct.¶
15 BY MR. -:¶
16 Q. And at the end of that massage, if that 17 victim brought other friends, she would get paid for 18 the recruitment of those friends?¶
19 MR. PAGLIUCA: Object to form and 20 foundation.¶
21 THE WITNESS: Correct.¶
22 BY MR. -:¶
23 Q. Additionally, did your investigation 24 reveal that the assistants of Jeffrey Epstein would 25 call and set up for these girls to come over to the¶
2 house for the massages?¶
3 MR. PAGLIUCA: Object to form and¶
4 foundation.¶
5 THE WITNESS: Correct.¶
6 BY MR. -:¶
7 Q. And, as well, certain people that were¶
8 friends or girlfriends or assistants of Jeffrey¶
9 Epstein would recruit girls under the pretense of 10 giving a massage?¶
11 MR. PAGLIUCA: Object to form and¶
12 foundation.¶
13 THE WITNESS: Correct.¶
14 BY MR. -:¶
15 Q. Is that what your investigation revealed 16 in terms of the system of getting these girls over, 17 to the house?¶
18 MR. PAGLIUCA: Object to form and¶
19 foundation.¶
20 THE WITNESS: Yes.¶
21 BY MR. -:¶
22 Q. Okay. Talking about the massages, when 23 when these -- the various girls that you interviewed 24 described the massages, was there a pattern of what 25 occurred during these massages?¶
2 MR. PAGLIUCA: Object to form and 3 foundation.¶
4 THE WITNESS: Yes, there was.¶
5 BY MR. -:¶
6 Q. Okay. Describe for us what the pattern 7 was that was told to you by the 30 or so girls that 8 you interviewed?¶
9 MR. PAGLIUCA: Object to form and 10 foundation.¶
11 THE WITNESS: Initially, when the when 12 the victims would come into the home and were 13 brought upstairs to provide the massage, 14 Epstein would lay on his massage table, where 15 they would start to rub his back and the back 16 of his legs.¶
17 Epstein would either attempt to fondle the 18 girls or touch the girls inappropriately, and 19 at which point he would masturbate. And when 20 he was done, he would get up and go wash off 21 while the girls would get dressed and go back 22 downstairs and get paid.¶
23 BY MR. -:¶
24 Q. Okay. So did you determine that "massage" 25 was actually a code word for something else?¶
2 MR. PAGLIUCA: Object to form and 3 foundation.¶
4 THE WITNESS: When they went to perform a 5 massage, it was for sexual gratification.¶
6 BY MR. -:¶
7 Q. And when the assistants would call and ask 8 these girls to work, did you learn what the term 9 "work" meant with respect to these girls coming to 10 the house?¶
11 MR. PAGLIUCA: Object to form and 12 foundation.¶
13 THE WITNESS: "Work" meant to come and 14 provide Epstein a massage.¶
15 BY MR. -:¶
16 Q. And massage -- how often would these 17 massages, based upon your investigation, turn into 18 something sexual?¶
19 MR. PAGLIUCA: Object to form and 20 foundation.¶
21 THE WITNESS: During the investigation, it 22 was determined that he would have multiple 23 massages during the day. He would have some in 24 the morning and some in the afternoon, 25 sometimes into the evening. So he would¶
2 BY MR. -:¶
3 Q. All right.¶
4 And so when you went to speak with the 5 victims, what did these victims say about their 6 experience with Jeffrey Epstein?¶
7 MR. PAGLIUCA: Object to form and 8 foundation.¶
9 THE WITNESS: Once they were recruited, 10 they were brought to the home. They were to 11 provide a massage.¶
12 Some of the victims did not want to be 13 touched; some of the victims did not want to 14 partake in that. So it was -- I believe for 15 for a couple of them it was only a one-shot 16 deal, but others continued to come.¶
17 BY MR. -:¶
18 Q. Okay. And as you interviewed some of 19 those victims, did you learn that some of those 20 victims also brought additional girls?¶
21 MR. PAGLIUCA: Object to form and 22 foundation.¶
23 THE WITNESS: That's correct.¶
24 BY MR. -:¶
25 Q. So as you were investigating this case, as¶
1 RECAREY - CONFIDENTIAL 2 part of your investigation, you're learning 3 information from these victims and then going to 4 talk to the next person down the line, if you will?¶
5 MR. PAGLIUCA: Object to form and 6 foundation.¶
7 THE WITNESS: Correct.¶
8 BY MR. -:¶
9 Q. And what is the purpose of that?¶
10 A. To identify further victims and acquire 11 additional information.¶
12 Q. And in doing that, were you able to 13 corroborate the accuracy of what the first victim 14 told you?¶
15 MR. PAGLIUCA: Object to form and 16 foundation.¶
17 THE WITNESS: Correct.¶
18 BY MR. -:¶
19 Q. Okay. And did you learn of 20 involvement with respect to the various girls?¶
21 MR. PAGLIUCA: Object to form and 22 foundation.¶
23 THE WITNESS: Yes.¶
24 BY MR. -:¶
25 Q. What was her role?¶
2 MR. PAGLIUCA: Object to form and 3 foundation.¶
4 THE WITNESS: That is correct.¶
5 BY MR. -:¶
6 Q. And did you turn all of your files over to 7 either the State Attorney's Office or the FBI?¶
8 A. That is correct.¶
9 Q. And through the State Attorney's Office, 10 was the information contained within the probable 11 cause affidavit and the incident reports a publicly 12 available document?¶
13 MR. PAGLIUCA: Object to form and 14 foundation.¶
15 THE WITNESS: Yes.¶
16 BY MR. -:¶
17 Q. And around the time of your 18 investigation -- around the time you ended your 19 investigation and thereafter, were various newspaper 20 articles written about the substance of some of your 21 investigation?¶
22 A. Yes.¶
23 Q. Did it become well known to the public 24 that Jeffrey Epstein had recruited high school girls 25 to his house for the purpose of some sexually¶
2 involved massage?¶
3 MR. PAGLIUCA: Object to form and¶
4 foundation.¶
5 THE WITNESS: That is correct.¶
6 BY MR.¶
7 Q. And, in fact, haven't you read many of¶
8 these newspaper articles?¶
9 A. That is correct.¶
10 Q. That was not a hidden secret from the¶
11 public beginning in 2006, right?¶
12 A. No.¶
13 Q. And from your overall investigation, kind¶
14 of just a big picture, what was the criminal¶
15 activity, as specific as you can, that you learned¶
16 that Jeffrey Epstein and others were involved in?¶
17 MR. PAGLIUCA: Object to form and¶
18 foundation.¶
19 THE WITNESS: It was sexual battery and¶
20 lewd and lascivious conduct for under the agc¶
21 of 16.¶
22 BY MR.¶
23 Q. And what was the specific system of¶
24 engaging in this type of activity?¶
25 MR. PAGLIUCA: Object to form and¶
2 foundation.¶
3 THE WITNESS: As to --¶
4 BY MR. -:¶
5 Q. From the recruitment to the: How did you 6 get them, what did you do, how did you keep it 7 going?¶
8 A. Once the --¶
9 MR. PAGLIUCA: Object to form and 10 foundation. Sorry.¶
11 THE WITNESS: No, no.¶
12 As it became known to us that the victir: 13 was recruited, brought to the home, provided 14 the massage, was paid, whether there was 15 16 17 18 19 20 21 were identified, we continued the same the 22 same method of investigation. inappropriate touching, whether there was sexual activity, whether there was actually intercourse, all of that was documented and was asked whether they brought anyone to the home, whether they had any formal training in massage therapy, and once -- once additional victims¶
23 BY MR. -:¶
24 Q. Okay. And one of the earliest victims, in 25 terms of the chronology of this pyramid of girls,¶
2 for lack a better word -- you understand what I mean 3 by that, right?¶
4 MR. PAGLIUCA: Object to form and 5 foundation.¶
6 THE WITNESS: Yes.¶
7 BY MR. -:¶
8 Q. That there's -- there's -- one of the 9 earliest victims that you interviewed was ; is that right?¶
11 MR. PAGLIUCA: Object to form and 12 foundation.¶
13 THE WITNESS: It was actually SG, I think 14 was the first one that was interviewed, and 15 then HR was the one I interviewed.¶
16 BY MR. -:¶
17 Q. Okay. My question was bad.¶
18 I know that the first person interviewed 19 that kind of kicked off the investigation was SG, 20 but -- and just to create a picture of what we have 21 here, this is, and tell me if I characterized it 22 wrong, a scheme that Jeffrey Epstein engaged in by 23 using assistants to recruit girls, right?¶
24 A. Correct.¶
25 Q. Under the¶
2 MR. PAGLIUCA: Object to form and 3 foundation.¶
4 BY MR. -:¶
5 Q. Under the pretense of giving a massage?¶
6 MR. PAGLIUCA: Object to form and 7 foundation.¶
8 THE WITNESS: Correct. Either a message 9 and/or become a model for Victoria's Secrets 10 and/or connections.¶
11 BY MR. -:¶
12 Q. And when he was able to get these girls to 13 his home, he would then offer them money to also 14 become recruiters for him?¶
15 MR. PAGLIUCA: Object to form and 16 foundation.¶
17 THE WITNESS: Correct.¶
18 BY MR. -:¶
19 Q. And that created this -- if you've mapped 20 it out, kind of a spider web or a pyramid of girls 21 bringing girls to Jeffrey Epstein's house?¶
22 MR. PAGLIUCA: Object to form and 23 foundation.¶
24 BY MR. -:¶
25 Q. Right?¶
2 A. Correct.¶
3 Q. All right.¶
4 So when I say one of the first, I mean on 5 the top of the pyramid one of the earliest people 6 that you interviewed that brought girls to Jeffre., 7 Epstein's house was HR?¶
8 A. Correct.¶
9 MR. PAGLIUCA: Object to form and 10 foundation.¶
11 BY MR. -:¶
12 Q. And I think that you testified that Molly 13 and Tony drove HR to Jeffrey Epstein's house the 14 first time, right?¶
15 MR. PAGLIUCA: Object to form and 16 foundation.¶
17 THE WITNESS: Correct.¶
18 BY MR. -:¶
19 Q. Did you ever trace all the way up to the 20 highest level to determine who was it that started 21 this particular chain of Palm Beach girls coming 22 over to Jeffrey Epstein's home?¶
23 MR. PAGLIUCA: Object to form and 24 foundation.¶
25 THE WITNESS: I did not. Basically, when¶
2 AFFIDAVIT¶
3 STATE OF FLORIDA¶
COUNTY OF¶
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, being first 6 duly sworn, do hereby acknowledge that I did read a true and certified copy of my deposition which was taken in the case of V. MAXWELL, taken on the 24th day of September, 8 2016, and the corrections I desire to make are as indicated on the attached Errata Sheet.¶
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12 STATE OF FLORIDA COUNTY OF )¶
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15 Before me personally appeared to me well known / known to me to be the 16 person described in and who executed the foregoing instrument and acknowledged to and 17 before me that he executed the said instrument in the capacity and for the purpose therein 18 expressed.¶
CERTIFICATE¶
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20 Witness my hand and official seal, this day of¶
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25 My Commission Expires:¶
(Notary Public)¶