Jason Richards — Direct/Cross/Redirect

MR. PAGLIUCA: Special Agent Richards, what do you do?

MR. PAGLIUCA: And how long have you been an agent with the FBI?

MR. PAGLIUCA: So that would take us back to 2003, is that correct, when you started?

MR. PAGLIUCA: Can you tell us a little bit about your training to become an FBI agent.

MR. PAGLIUCA: And would that be in 2003 that you went -- is that in Quantico, Virginia?

MR. PAGLIUCA: As part of your basic training, do you learn how to do investigations in terms of talking to witnesses and recording information from those witnesses?

MR. PAGLIUCA: Were you first -- well, where are you stationed currently with the FBI?

MR. PAGLIUCA: And how long have you been there?

MR. PAGLIUCA: And where were you before 2014?

MR. PAGLIUCA: Okay. And prior to 2006, where were you stationed?

MR. PAGLIUCA: I want to direct your attention to 2006, when you were in the Palm Beach area. Okay?

MR. PAGLIUCA: Were you assigned to a particular unit in 2006?

MR. PAGLIUCA: And what is squad PV2?

MR. PAGLIUCA: PB2.

MR. PAGLIUCA: And were you involved at that point in an investigation regarding Jeffrey Epstein?

MR. PAGLIUCA: And did part of your job during that investigation involve talking to witnesses in that case?

MR. PAGLIUCA: You indicated that as part of your training as an FBI agent, you are trained to do interview techniques with witnesses, right?

MR. PAGLIUCA: Does that training and experience involve how to listen to people talk?

MR. PAGLIUCA: Okay. And when you're listening and trying to get the details as accurate as possible, are you trying to gather information via open-ended questions to elicit responses from witnesses?

MR. PAGLIUCA: As part of your training and experience, do you try to limit anybody from telling you anything?

MR. PAGLIUCA: And as part of your investigation and training, are you looking to get as much relevant information as possible from anyone you're interviewing about a particular topic or subject?

MR. PAGLIUCA: Now, I want to direct your attention to 2007, which would be about a year after you began working in Palm Beach; correct?

MR. PAGLIUCA: You were working with an agent Nesbitt Kuyrkendall. Do you recall Agent Kuyrkendall?

MR. PAGLIUCA: And you and Agent Nesbitt Kuyrkendall were interviewing witnesses together in tandem; is that right?

MR. PAGLIUCA: And is that part of standard practice for the FBI in interviewing witnesses?

MR. PAGLIUCA: And is that so you have a witness to the witness interview?

MR. PAGLIUCA: Was part of your practice and procedure in interviewing witnesses in 2007 based on your training with the FBI to take notes during witness interviews?

MR. PAGLIUCA: And then would you and Special Agent Kuyrkendall review those notes and turn them into what's referred to often as a 302?

MR. PAGLIUCA: And explain to the jury what a 302 is.

MR. PAGLIUCA: And is part of the training and practice of the FBI to review the 302 for accuracy prior to it being finalized?

MR. PAGLIUCA: And do you and Special Agent Kuyrkendall in this case initial the 302 to show that you've reviewed it and that it's accurate?

MR. PAGLIUCA: I'd like to display for the witness what's been marked as JR-1, which is 3505-005 in the 3500 material.

MR. PAGLIUCA: Thank you, your Honor.

MR. PAGLIUCA: So that should be for the witness, the Court, and the courtroom deputy only please.

MR. PAGLIUCA: Do you have that on your screen yet?

MR. PAGLIUCA: If we look at the lower left corner of this, do you see your name, Special Agent Kuyrkendall's name, and the initials?

MR. PAGLIUCA: And those are your initials?

MR. PAGLIUCA: And that means that you at the time reviewed this and determined that it was accurate at the time; is that right?

MR. PAGLIUCA: Have you had a chance to review this before your testimony here today?

MR. PAGLIUCA: I understand that this was a long time ago. And I'm assuming, but you tell me if I'm incorrect, that you don't have any current memory of doing this interview?

MR. PAGLIUCA: Right. And you've done a lot of interviews between 14 years ago and now, I assume?

MR. PAGLIUCA: Now, is part of the reason why you are trained to take notes and to record events accurately, so that months or years later you will have a document such as this that you can testify from and be confident that what you put in the document is accurate?

MR. PAGLIUCA: Okay. What I'd like to do is direct you to some specific statements in this JR-1 that we've marked for identification purposes. First of all, do you recall that on August 7th, 2007, you spoke with Carolyn? And we're identifying this person only by the name of "Carolyn."

MR. PAGLIUCA: And again, when you spoke with Carolyn, you were gathering information relative to your investigation at that time; correct?

MR. PAGLIUCA: When you spoke with Carolyn, consistent with your training and experience, you were attempting to get as much information as possible; is that correct?

MR. PAGLIUCA: And you were not limiting any of the responses given to you by Carolyn during that interview; correct?

MR. PAGLIUCA: In particular, I would like you to look at page 2, paragraph -- full paragraph 3 of Exhibit JR-1.

MR. PAGLIUCA: Middle of the page that begins with "Carolyn." Are you there?

MR. PAGLIUCA: Okay.

MR. PAGLIUCA: Let me just confer, your Honor, to make sure.

MR. PAGLIUCA: Do you recall at that time Carolyn told you that Carolyn obtained Epstein's phone number from a telephone book?

MR. PAGLIUCA: Okay. And do you recall at that time also that Carolyn told you that Epstein returned Carolyn's call?

MR. PAGLIUCA: I have no other questions, your Honor.

MR. PAGLIUCA: Thank you, your Honor.

MR. PAGLIUCA: Special Agent Richards, you're writing down accurately what's being told to you during these interviews; correct?

MR. PAGLIUCA: And you're writing it down accurately because you may be called to a witness stand to testify under oath about what people told you; correct?

MR. PAGLIUCA: Thank you.

MR. PAGLIUCA: No further questions, your Honor.

MS. MENNINGER: Your Honor, at this time we would call Agent Amanda Young.

MS. MENNINGER: Thank you, your Honor.