IN THE COURT OF THE FIFTEENTH

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA B.B., CASE NO. 502008CA0373193OOOCMB AB Plaintiff, v. and Defendants NOTICE OF TAKING DEPOSITION DUCES TECUM PLEASE TAKE NOTICE that the undersigned attorney will take the deposition duces tecum (See attached Exhibit "A") of: DEPONENT Det. Joseph Recarey do Joanne M. O'Conner, Esq. Jones, Foster, Johnson & Stubbs, P.A. 505 S. Flagler Drive, #1100 West Palm Beach, FL 33401 DATE & TIME LOCATION OF DEPOSITION February 25, 2010 at 9:30 AM Prose Court Reporting One Clearlake Centre 250 Australian Avenue South West Palm Beach, FL 33401 upon oral examination, before Prose Court Reporting, a Notary Public, or any other officer authorized by law to take depositions in the State of Florida. The oral examination is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the applicable Statutes of Rules of Court. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S following addressees on this 3rd day of February, 2010: Theodore J Leopold, Esq. Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. 2925 PGA Blvd., Suite 200 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 Mail to the EFTA00598945 B.B v. Epstein, et al Page 2 Palm Beach Gardens, FL 33410 Fax: 561 697 2383 Counsel for Plaintiff West Palm Beach, FL 33401-5012 Fax: 561-835-8691 Co-Counsel for Defendant Jeffrey Epstein BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 515 N. Flagler Drive, Suite 400 Wet a ch, FL 33401 (561)515-3148 Fax Robe . Critton, Jr. Florida Bar #224162 Mi mel I Pike Florida Bar #617296 (Colonel for Defendant Jeffrey Epstein) EFTA00598946 EXHIBIT "A" 1 Any and all written reports, notes, memoranda or other papers authored by you or any other member of the Palm Beach Police Department, whether in hard-copy or electronic form, that relate to any law enforcement investigation of Jeffrey Epstein including but not limited to the investigation that resulted in the filing of State criminal charges against Mr. Epstein This request includes any written communications between you and any members of the Palm Beach Police Department, any member of any Federal Law Enforcement Agency, any member of the Unites States Attorney's Office, any member of the Office of the State Attorney, any representatives of the media, any civil parties, any civilian witnesses and/or any lawyers or representatives of any parents of any civilian witnesses. 2. Any and all electronic communications (EMAIL) between yo any of the following relating to any law enforcement investigation of Jeffrey Epstein including but not limited to the investigation that resulted in the filing of State criminal charges against him: (A) any member of the Palm Beach Police Department, (13) any member of any Federal Law Enforcement Agency, (C) any member of the Untied States Attorney's Office, (D) any member of the Office of the State Attorney (E) any member of any print, television, or radio media outlet, (F) any attorney representing any civilian witness or civil party who has filed or may potentially file a civil complaint against Mr Epstein. 3 Any and all notes, memoranda or reports reflecting any communications between you and counsel on behalf of Mr. Epstein, including but not limited to any request for exculpatory evidence. 4. Any and all notes, memoranda or reports reflecting any attempts by you to initiate or encourage a federal review of any facet/aspect of the Epstein investigation or State prosecution of Epstein 5 Any and all notes, memoranda or reports reflecting any complaints made to the Palm Beach Police Department from any person, parent, or lawyer for any person or parent claiming to have been a victim of any conduct of Mr Epstein or from any other private citizen of Palm Beach County relating to any conduct of Epstein from January 1, 2000 — October 22, 2009. 6. Any and all notes, memoranda, or reports reflecting any communication between you or and any other member of the Palm Beach Police Department with "A H." in relation to her being subpoenaed to testify before or her requested attendance before a State Grand Jury, including but not limited to any discussions regarding what she would testify to and/or any preparation that any law enforcement officer provided her with prior to any testimony. 7. Any and all notes, memoranda, or reports reflecting any communication between you or any other member of the Palm Beach Police Department with "A H."* or referencing "A.H "* in relation to her being subpoenaed to testify before or her requested attendance before a State Grand Jury where you or any Palm Beach police officer or official sought to discourage her or influence her not to testify or to testify in a certain manner at any Grand Jury proceeding involving Mr. Epstein. EFTA00598947 8. Any and all agreements, memoranda, and/or notes of any kind, electronic or otherwise, between you and any member of the Palm Beach Police Department, any member of the Office of the State Attorney, and/or any member of the United States Attorney's Office relating to any criminal charges, formal or otherwise, regarding "A II " at any time. 9. Any and all notes, memoranda, or reports of meetings or communications between you and "S.G "*, her parents, or any lawyers who represent "S.G_"• 10. Any and all records of expenditures made or incurred by you, and all requests for expenditures relating to the criminal investigation of Mr. Epstein. 11. Any and all logs, pictures, videos, digital information, reports, memoranda or notes, and any record of expenditure, which relate to the institution of and/or maintenance of any video surveillance of Mr. Epstein, his residence, or his visitors during the following time periods: a January 1, 2004-December 31, 2004 b. January 1, 2005-December 31, 2005 c January 1, 2006-December 31, 2006 d. January 1, 2007-December 31, 2007 e. January 1, 2008-December 31, 2008 f. January 1, 2009-today's date. 12. Any and all reports, logs, pictures, videos, notes, records of expenditures or any other memoranda relating to any physical surveillance of Mr. Epstein, his residence, his visitors, or any individual who was believed to be a potential witnesses or co-conspirator other than the information relating to video surveillance that is requested in request number 11 13. Any and all reports (including forensic reports), memoranda, notes, and reports of any examination of any computer seized fiom Mr. Epstein's residence in October 2005 or on any other occasion. 14. Any and all reports, memoranda, or notes reflecting a criminal theft or burglary investigation of Mr. Epstein or his residence on any occasion prior to October 2005. 15. All cell phone records, both official cell phone and personal cell phone, used by you between during the following time periods: a. January 1, 2004-December 31, 2004 b. January 1, 2005-December 31, 2005 c. January 1, 2006-December 31, 2006 d. January I, 2007-December 31, 2007 e January 1, 2008-December 31, 2008 f. January 1, 2009-today's date. 16.. All calendars or diaries, electronic or hard-copy, kept for the periods between October 1, 2004 up through and including today, reflecting your schedules, activities, meeting, etc. EFTA00598948 17. Any and all reports, memoranda, and notes of any communication between Los and any member of the Office of the State Attorney relating to the criminal investigation and subsequent prosecution of Mr. Epstein from October 1, 2004 up through and including today. 18. All policies and procedures of the Palm Beach Police Department setting forth the procedures for police officers, including the Chief, any detective and officers when commenting to any media outlets, including but not liming to the local news, the national media, print outlets, and any web-based media format. 19. All personal notes contained either on your personal computer, work computer, and those that are handwritten containing any witnesses that you, or any other member of the Palm Beach Police Department interviewed or attempted to interview with regard to the Epstein investigation from January 1, 2004, up thorough and including today. 20. Any and all audio tapes of any witnesses that You or any member of the Palm Beach Police Department obtained statements or interviews from, either sworn or informal, with regard to the Epstein investigation 21. Any and all audio tapes, notes (hand-written or typed), memoranda, reports, messages, and/or any communications obtained or generated by you or any member of the Palm Beach Police Department, either sworn or informal, that relate to Jane Doe #4**, who is the Plaintiff in a Federal Civil Case No. 08-80380 filed against Jeffrey Epstein. * The initials Ail. and S.R. refer to the individuals identified in the Palm Beach County Probable Cause Affidavit ns it relates to the Jeffrey Epstein investigation. Should ou re uire the complete name of the individuals, please contact Jessica Cadwell at ** Should you need the full identity of Jane Doe #4, please contact Jessica Cadwell at ■ EFTA00598949