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he would start to masturbate, and he would ask me 
to straddle his face. He would ask me to, like, squeeze his 
nipples really hard while he came. 
Q. Did all of the things that you just described happen on 
trips to New York when you were 14, 15, and 16? 
A. Yes. 
Q. You testified that you were mostly alone with him when 
these incidents occurred in the New York house when you were 
14, 15, and 16. Just to be clear, were there times when 
Maxwell was present during those years? 
A. Yes. 
Q. Where would these incidents in New York typically happen 
within the house? 
A. In the massage room. 
Q. Can you please describe for the jury what the massage room 
in the New York house looked like. 
A. Well, it was off the master bathroom, and it looked like it 
was maybe supposed to be a giant walk-in closet. And it was 
very dark. There was a built-in bookcase on the right-hand 
side, and there was a stereo system. And there was, like, 
music playing. And I don't know if it was painted dark, but 
or maybe that was the lighting, but it sort of had this, like, 
red mood. And then there was just a giant black massage table 
in the middle of it. 
Q. Was there anything along the walls in the massage room? 
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A. My eyes didn't even look at the walls, mostly the floor, if 
not what was going on. 
Q. Was there any other furniture inside the massage room aside 
from the massage table? 
A. I don't know. 
Q. Earlier you testified that you recall traveling to New 
Mexico; is that correct? 
A. Yes. 
Q. Approximately when did you travel to New Mexico? 
A. The year? 
Q. Approximately how old were you when you traveled to New 
Mexico? 
A. Oh, 15 or 16. 
Q. Who went with you on that trip? 
A. Jeffrey and Ghislaine. 
Q. Where did you spend most of your time on the trip to New 
Mexico with Maxwell and Epstein? 
A. At Epstein's house, which was a ranch. 
Q. What do you remember about the ranch that you visited on 
that trip? 
A. I just remember that it was this giant ranch sort of in the 
middle of nowhere. And it seemed very empty on the interior, 
meaning there wasn't really any other people around. 
Q. When you were at the ranch in New Mexico, where did you 
spend most of your time? 
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A. In the guest bedroom that was assigned to me. 
Q. Were you by yourself in the bedroom? 
A. Yes. 
Q. And did you spend most of your time alone in that bedroom 
when you were in New Mexico? 
A. Yes. 
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Q. On that trip in New Mexico, was there ever a time when 
someone came into your room? 
A. Yes. 
Q. Can you describe to the jury what you remember about that? 
A. I just remember someone, at one point, just came into the 
room and said Jeffrey wants to see you and then escorted me to 
see him. 
Q. When that person came into your room and told you that he 
wanted to see you, how did you feel? 
A. I just, as usual, felt, like, my heart sink into my 
stomach, you know. 
Q. And why was your heart sinking into your stomach? 
A. Because I did not want to go see him. 
Q. What's the next thing you remember about that? 
A. I just remember being led to his bedroom and, you know, the 
same thing would happen. 
Q. Who was the person who came into your room to tell you that 
Epstein wanted to see you? 
A. I don't know. 
Q. During that trip to New Mexico, was your bedroom in the 
same building as Epstein and Maxwell's bedrooms? 
A. Yes. 
Q. When you traveled with Epstein and Maxwell, was there ever 
a time when you had trouble getting on a flight? 
A. Yes. 
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Q. Can you describe to the jury what happened. 
A. Well, I had traveled with them and I had to fly back to 
Palm Beach to go to school on a Monday, and I traveled with 
them on a private jet. Then, to get back, I was taking a 
commercial flight, but I was only 15, so I didn't have a 
driver's license or any ID, I didn't have a learner's permit 
yet. So I had no ID to get on the airplane. 
Q. What happened next after you couldn't get on the airplane? 
A. I remember calling and freaking out, saying how am I going 
to get on this plane. And Ghislaine made it happen for me. 
She sort of called somebody and helped me get on that flight. 
Q. Approximately how old were you when that happened? 
A. I was 15. 
Q. Earlier, you testified that Maxwell assisted with your 
travel arrangements on these trips when you were 14, 15, and 
16. Could you explain to the jury how Maxwell assisted with 
your travel during these trips? 
A. Well, sometimes it would be -- Jeffrey would ask her, hey, 
can you get -- not 
you know, tickets and the times and 
whatnot and make the arrangements to be picked up. 
Q. You testified that this began when you were 14. Can you 
explain to the jury how old you were when you moved away from 
Palm Beach? 
A. 17. 
Q. Can you describe for the jury what you looked like when you 
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were ages 14, 15, 16, and 17. 
A. What I looked like? 
Q. Can you describe what your physical appearance was like. 
A. Oh, I was -- I was kind of short. I was very thin. I was 
flat-chested until I was almost 16. 
Q. If you could please take a look at the binder in front of 
you on the witness stand. I'd ask you to just turn to what's 
been marked for identification as Government Exhibit 107. 
Do you recognize that? 
A. Yes. 
Q. What is Government Exhibit 107? 
A. That is a picture of myself at 15 years old when I thought 
it was a really good idea to bleach my own hair at home, which 
was not a good idea. 
MS. MOE: Your Honor, the government offers Government 
Exhibit 107 under seal. 
THE COURT: Government Exhibit 107 is admitted under 
seal consistent with my ruling allowing this witness to testify 
under a pseudonym to protect her privacy. 
(Government's Exhibit 107 received in evidence) 
MS. MOE: Thank you, your Honor. 
Q. 
if you could please take a look at the binder in 
front of you and turn to what's been marked for identification 
as Government Exhibit 108. 
Do you recognize that? 
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A. Yes. 
Q. What is Government Exhibit 108? 
A. That's a picture of me. 
Q. Approximately, how old were you when that picture was 
taken? 
A. 17. 
MS. MOE: Your Honor, the government offers Government 
Exhibit 108 under seal. 
MS. MENNINGER: No objection. 
THE COURT: Thank you. Government Exhibit 108 is 
admitted under seal consistent with my ruling, allowing this 
witness to testify using a pseudonym. 
(Government's Exhibit 108 received in evidence) 
MS. MOE: Thank you, your Honor. May the jurors turn 
to Government Exhibits 107 and 108 in their binders. 
THE COURT: Yes, please. Pick up your binders and 
look at GX107 and GX108. 
MS. MOE: Thank you. Just give the jurors a moment to 
turn to that. 
BY MS. MOE: 
Q. So again, just to be clear, now that we're all looking at 
Government Exhibit 107, approximately how old were you when 
that photograph was taken? 
A. 15. 
Q. Turning to Government Exhibit 108, approximately how old 
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were you when that photograph was taken? 
A. 17. 
Q. I want to step back and ask you a little bit about your 
home life during the years we've been talking about. When you 
were 14 to 17 and living in Florida, can you describe for the 
jury what your home life was like during those years? 
A. Well, it was 
it was not great. My father had just 
passed away, sort of suddenly, and we found ourselves losing 
our home and moving into a pool house and not being allowed to 
grieve the loss of my father and having a very depressed mom at 
home. 
Q. I think you mentioned that you felt like you weren't 
allowed to grieve your father. Can you explain to the jury 
what you meant by that? 
MS. MENNINGER: Objection, your Honor. Relevance. 
THE COURT: Overruled. You may answer. 
A. Well, I grew up with a mother who didn't allow us to talk 
about our feelings because that was a sign of weakness. So 
grieving would be a part of that because she was very concerned 
about appearance and what we would look like and that you 
always sort of put a pretty face on. So we really didn't 
discuss those kinds of things at home and weren't allowed to 
discuss it with anyone else. So, being a kid and losing your 
dad and not being allowed to talk about it, not having anyone 
to talk to about it, it was really difficult. 
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Q. During the years that we've been talking about, did your 
mother know that you were spending time with Epstein and 
Maxwell? 
A. Yes. 
Q. Would you ever talk with her about that? 
A. Not in detail, but, you know, my mom was so enamored with 
the idea that these wealthy affluent people took an interest in 
me. 
MS. MENNINGER: Objection. Hearsay, your Honor. 
We've strayed into hearsay. 
THE COURT: Just one moment, please. Overruled with 
respect to the answer that's been given, but is that the end of 
the question line, Ms. Moe? 
MS. MOE: Your Honor, this testimony is offered for 
the effect on the listener. We ask that the witness be able to 
explain what is going on during this time period and how that 
affected her. 
THE COURT: You may ask that question. 
MS. MOE: Thank you, your Honor. 
BY MS. MOE: 
Q. During the time period that we've been talking about when 
you were 14, 15, and 16, did your mother ever talk to you about 
Jeffrey Epstein and Ghislaine Maxwell? 
A. The most that she would talk to me about was saying that _ 
need to be --
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MS. MENNINGER: Objection. Hearsay, your Honor. Thtt 
was a different question. 
THE COURT: I'll sustain. If you reframe the question 
to elicit the information you indicated as opposed to asking 
what her mother said, you may proceed. 
MS. MOE: Your Honor, if I could just have one moment? 
THE COURT: You may. 
MS. MOE: Your Honor, could we briefly approach? 
THE COURT: Why don't we take our midafternoon break, 
because the jurors' snacks are here and it's time for that. So 
we'll take an approximately 10-minute break, members of the 
jury. Thank you. See you in about 10 minutes. 
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(Witness excused) 
THE COURT: Everyone may be seated. Go ahead, 
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Ms. Moe. 
MS. MOE: Thank you, your Honor, I'd like to ask the 
witness about her conversations with her mother during this 
time period about Epstein and Maxwell. As I think the witness 
began explaining during this time period, her mother would tell 
her about how great they were, how enamored she was with them, 
and that I expect she would say that that had an effect on her. 
None of that is offered for the truth, but for the effect on 
the listener. 
I think the defense has put at issue in this case why 
the victims continued seeing the defendant and Epstein and why 
they didn't tell about what happened to them later, and the 
circumstances under which all of this was happening, including 
her home life, the effect of her own mother and how her mother 
would talk about Maxwell and Epstein are all part of that and 
it's directly responsive to that issue. 
THE COURT: The initial questions that you're asking, 
you expect the witness to say what exactly was communicated to 
the witness by her mother? 
MS. MOE: Yes, your Honor. I expect the witness to 
testify that her mother encouraged the relationship and would 
often talk about them favorably and tell them she should be 
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grateful for everything they were doing for her. 
THE COURT: And you're not seeking to offer that 
information for the truth, but for the effect that it had on 
the witness? 
MS. MOE: Yes, your Honor. 
THE COURT: So you'll accept a limiting instruction? 
MS. MOE: Of course, your Honor. 
THE COURT: Ms. Menninger. 
MS. MENNINGER: Your Honor, I think the simple way to 
ask the question is, how did you feel, and if it was based on 
something your mother said to you, without getting into the 
content of what the mother had communicated to her. I think 
it's a real issue that may come up later with things that the 
mother has said to any number of people, and I feel like this 
opens the door to many other conversations that relate to the 
mother. 
So I'm not sure that just asking -- giving a bunch of 
hearsay from the mom, saying we're asking it for the effect on 
the listener and precluding cross examination about other 
conversations with the mom would be appropriate. 
THE COURT: So I don't know what you have in mind 
coming down the road. I think it's proffered by the government 
at this point anyway. I think there might be a way to 
streamline it. Ms. Moe, maybe you could think about that. 
But as proffered by the government, it's not being 
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offered for the truth, it's being offered for the effect on the 
listener. I would give the jury a limiting instruction that 
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the witness's testimony regarding what her mother said is not 
being offered for the truth of those statements, but for the 
impact or effect that it had on the witness. We'll keep it 
limited, Ms. Moe, as to eliciting statements for an 
out-of-court witness, but with that caveat. 
And then tell me, Ms. Menninger, what your concern 
down the road was so I have it in my head. 
MS. MENNINGER: Your Honor, if you're admitting it 
with that limiting instruction, I think we'll take up the 
issues with other statements by the mom when they come up. 
THE COURT: Okay. 
MS. MOE: Thank you, your Honor. Just to preview in 
order to streamline things because we're on the subject, I 
expect the next few questions to be about the issue of 
disclosure. In particular, I expect to ask the witness whether 
there was ever a time when she talked to a guidance counselor 
when she was a kid and whether she came to learn that her 
mother had found out that she talked to the guidance counselor, 
and I want to talk to her about how her mother reacted to that 
and told her that she should never talk about what goes on in 
their house. 
We're offering that, again, not for the truth of 
anything, it's certainly not our position that she shouldn't 
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have told someone that that is a true statement. It's offered 
to show the environment in which she was living and how that 
affected her and affected her decision not to disclose what was 
going on with her. 
THE COURT: But in particular, you want the witness to 
testify that her mother told her not to report what happened, 
not to tell anyone what happened. Did I get that right? 
MS. MOE: Yes, your Honor. I expect that she'll 
testify that she spoke with a guidance counselor after her 
father passed away, that her mother found out that she had 
spoken with a guidance counselor and had a very strong negative 
reaction to that, and told her that she shouldn't be talking 
about personal family matters and shouldn't be talking about 
what happens in their household. 
THE COURT: Ms. Menninger. 
MS. MENNINGER: I have no objection to that, your 
Honor. 
MS. MOE: Thank you, your Honor. 
THE COURT: Thank you for previewing it. 
Anything else to take up? 
MS. MOE: Not from the government, your Honor. 
THE COURT: Ms. Menninger? 
MS. MENNINGER: No, your Honor. Not now. 
THE COURT: We'll take a short break. Thank you. 
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THE COURT: Nothing to take up; correct? 
MS. MOE: Correct, your Honor. 
MS. MENNINGER: Correct, your Honor. 
THE COURT: We'11 bring in the jury. 
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(Jury present) 
THE COURT: Thank you, everyone. Ms. Moe, you may 
continue with your direct examination of the witness. 
MS. MOE: Thank you, your Honor. 
BY MS. MOE: 
Q. Before the break, we were talking about your interactions 
with your mother during this time period when you were 14, 15, 
and 16. I want to ask you, during that time period, did you 
ever talk with your mother about Jeffrey Epstein or Ghislaine 
Maxwell? 
A. Yes. 
Q. What kinds of things would she say to you about Maxwell and 
Epstein? 
now. 
THE COURT: I'm going to give the limiting instruction 
Members of the jury, the witness may provide some 
testimony regarding things that her mother said to her. I 
instruct you that that testimony is not being offered for the 
truth of the matter of what was said, but instead for the 
purposes of its impact on the listener of this witness. 
You may proceed. 
MS. MOE: Thank you, your Honor. 
Q. Would it be helpful if I ask the question again? 
A. Yes, please. 
Q. Sorry about that. During this time period that we've been 
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talking about when you were 14 and 15 and 16, did you ever talk 
with your mother about Jeffrey Epstein and Ghislaine Maxwell? 
A. Yes. 
Q. What kinds of things would she say to you about Epstein and 
Maxwell during that time period. 
A. What would she say? I'm sorry. I'm not really 
understanding your question. 
Q. Of course. When would you talk to your mother during those 
years about Maxwell and Epstein, what, if anything, would she 
say to you about her impressions of them? 
A. My mother seemed very impressed and enamored with the sort 
of the wealth, the affluence. She thought they seemed very 
generous and they must think I'm special and that I should be 
grateful for the attention that I received. 
Q. During this time period, did you ever tell your mother 
about the sexual abuse that you were experiencing when were you 
at Epstein's house? 
A. No. 
Q. Why didn't you tell your mother during those years? 
A. Because I felt very ashamed, I felt very disgusted, I was 
confused, I didn't know if it was my fault, and my mother and I 
did not have that kind of a relationship. We didn't talk about 
our feelings. We weren't allowed to. I was raised in a 
household where you were sort of spoken to, and you don't speak 
unless you're spoken to, and I would be afraid that I would be 
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in trouble if I said something. 
Q. During those same years, did you tell your brothers or any 
of your friends that you were being sexually abused by Maxwell 
and Epstein? 
A. No. 
Q. And why not? 
A. Because how do you tell or describe any of this to any one 
of your peers or your siblings when all you feel is shame and 
disgust and confusion and you don't even know how you ended up 
there. 
Q. Were there ever times when you were 14 or 15 and 16, while 
all of this was happening, where you thought about hurting 
yourself? 
A. Yeah. 
Q. Can you explain to the jury what that was like for you? 
A. Well, it was a multitude of things, of my father dying and 
losing our home and then having a manic depressed mother who 
didn't know how to cope and know how to take care of us and, 
you know, just kind of feeling like it was hopeless, I guess. 
It didn't seem like there was a lot of joy to look forward to 
and it was just -- it was all 
it was very painful. It was 
all very difficult. 
Q. Did there come a time when you were a kid when you spoke to 
a school guidance counselor? 
A. Yes. 
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Q. Approximately when was that? 
A. In the 7th grade. 
Q. How did you go to see the guidance counselor when you were 
in the 7th grade? 
A. Well, actually, she asked to speak to me. She called me in 
her office and said -- asked me what was going on at home, if 
we had been or I had been in grief counseling and how my mother 
was doing. So I told her how I was feeling and how sad I was 
and, you know, how unavailable my mother was and how 
unsupportive and there was really no one for me to talk to. So 
I spoke to her and she was -- she was lovely and she would - 
when she would see me. She would say if you need a place to 
go, just come to my office and sit there and we'll talk. 
Q. After you spoke with the guidance counselor, did there come 
a time when you learned that your mother had become aware about 
the conversations you were having with the guidance counselor? 
A. Yes. I came home from school one day and my mother said 
that the guidance counselor had called her and had said that 
she wanted to see her because she was very worried about me. 
My mother proceeded to berate me and scream at me and slap me 
and tell me how dare I talk about myself and our family and 
that it was an embarrassment, and that you don't tell other 
people about your feelings or what's going on at home. 
Q. I want to pause here and ask a few questions about the 
sexual abuse you described experiencing when you were 14 and 
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when you were 15 and when you were 16. 
Just to be clear, were there times when that happened 
when it was just you and Jeffrey Epstein? 
A. Yes. 
Q. Were there times when that happened when it was just you 
and Epstein and Maxwell? 
A. Yes. 
Q. Were there times when that happened when it was you and 
Epstein and Maxwell and other women? 
A. Yes. 
Q. All those three categories, what happened the most during 
those years? 
A. Me and Jeffrey. 
Q. What was the next most frequent thing that happened? 
A. The group situations. 
Q. Approximately how many times during the years that you were 
14 and 15 and 16 was Ghislaine Maxwell in the room while you 
were being sexually abused by Jeffrey Epstein? 
A. I don't know. 
Q. Why is it hard to remember the specific number? 
A. It's hard to remember because I was abused pretty much 
every time that I would go over to his house and it all started 
to seem the same after a while, whether it was just him or 
there were other women involved or me and Jeffrey and 
Ghislaine, it all started to seem the same after a while and 
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