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Q. Did anyone ever tell you how old 
was? 
A. No. 
Q. Do you know how old 
was when you met her? 
A. No, I didn't. 
Q. How did you meet 
A. Mr. Epstein brought her to the cockpit and introduced her 
to me. 
Q. What, if anything, stands out in your mind about 
demeanor when you met her that day? 
A. Just a mature woman with some piercing powder blue eyes. 
Q. About how many times do you recall seeing 
on 
Mr. Epstein's plane? 
A. At least one, the time that Mr. Epstein introduced. 
Q. Do you remember where you were going that day? 
A. I do not. 
Q. Do you remember where you were coming from? 
A. Yes. 
Q. Do you remember where you were coming from that day? 
A. Yes, we were departing West Palm Beach Airport. 
Q. What, if any, passenger with the first name 
do you 
remember flying on Mr. Epstein's plane? 
A. I do remember at least one person named 
Q. And what was that person's full name? 
A. It was 
Q. About when did you meet 
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A. Had to have been mid to late '90s. 
Q. Do you remember the exact year? 
A. I do not. 
Q. What did 
look like? 
A. A shorter woman with dirty blond hair. 
Q. Did anyone ever tell you how old 
was when you met 
her? 
A. No. 
Q. Do you know how old she was when you met her? 
A. No, I did not. 
Q. About how many times do you remember seeing 
as a passenger on Mr. Epstein's private planes? 
A. She was on the airplane a couple times. I couldn't guess 
the quantity, but definitely more than once. 
MS. COMEY: May I have a moment, your Honor? 
THE COURT: You may. 
(Counsel conferred) 
MS. COMEY: Nothing further, your Honor. 
THE COURT: Okay. Mr. Everdell, you may proceed with 
the cross-examination. 
MR. EVERDELL: Thank you, your Honor. 
At this point, with the Court's permission, I would 
put a binder up in the witness box. 
THE COURT: Okay. 
MS. COMEY: Your Honor, to be clear, I have not seen 
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what's inside this binder. 
MR. EVERDELL: This is in case we need to refer the 
witness to something. 
THE COURT: So you may bring it forward. Before the 
witness is directed to look at any document, you'll show it to 
the government. 
MR. EVERDELL: Yes. If we're going to refer to 
anything, we will refer what it is to the government so they 
can see it before we have the witness open the binder. 
THE COURT: Okay. 
MS. COMEY: Thank you, your Honor. 
THE COURT: Thank you. 
MR. EVERDELL: May I approach, your Honor? 
THE COURT: You may. 
MR. EVERDELL: May I remove my mask, your Honor? 
THE COURT: You may, Mr. Everdell. 
CROSS-EXAMINATION 
BY MR. EVERDELL: 
Q. Good morning Mr. 
A. Good morning, Mr. Everdell. 
Q. I'm going to ask you a few questions about what you just 
testified to on direct. 
A. Okay. 
Q. Now, you testified that you started working as a pilot for 
Jeffrey Epstein in about 1991; is that right? 
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A. That is correct. 
Q. And you were hired, along with your friend 
that right? 
A. That's correct. 
Q. Now, when you started in 1991, 
was the chief 
pilot and you were the co-captain? 
A. That is correct. 
Q. But that changed, I think, in about 2000; is that right? 
A. That is correct, approximately. 
Q. At that point you became the chief pilot and 
became the co-captain? 
A. That's correct. 
Q. And you continued to work for Epstein as his chief pilot 
until about 2019? 
A. Correct. 
Q. So you were a pilot for Jeffrey Epstein for almost 30 years 
from 1991 to 2019; is that right? 
A. That is correct. 
Q. And in that time, I think you testified that you flew 
several different planes for him; is that right? 
A. That is correct. 
MR. EVERDELL: If we could call up what is already in 
evidence as Government's Exhibit 311. 
THE COURT: 311 you said? 
MR. EVERDELL: 311, your Honor. 
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THE COURT: Okay. You may. 
MR. EVERDELL: And we can display that for the jurors. 
THE COURT: You may. 
Q. Do you see that, Mr. 
A. Yes, I do. 
Q. We saw that before. That's the Hawker Siddeley jet, right? 
A. Correct. 
Q. And that was used from about '91 -- 1991 to 1994; is that 
right? 
A. That's correct. 
MR. EVERDELL: Okay. We can take that down. 
Q. So you no longer flew the Hawker after about '94? 
A. No, the aircraft was sold after '94. 
Q. And there was another aircraft you mentioned, the 
Gulfstream, the G2B, right? 
A. Correct. 
MR. EVERDELL: If we can pull up what's already in 
evidence as Government's Exhibit 315. 
THE COURT: You may. 
MR. EVERDELL: Display that for the jurors as well. 
Q. Do you see that, Mr. 
A. Yes. 
Q. We saw that before, right, that is the Gulfstream jet with 
Mr. Epstein in front of it; is that right? 
A. Correct. 
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Q. Okay. And he got that, your recollection is, sometime 
around 1994? 
A. Correct. 
MR. EVERDELL: All right. We can take that down. 
Q. And you've also mentioned that he eventually got the Boeing 
727? 
A. Correct, in 2000. 
Q. That was roughly around 2000? 
A. Correct. 
MR. EVERDELL: If we can display what's already in 
evidence as Government's Exhibit 301. 
THE COURT: You may. 
MR. EVERDELL: And show that to the jurors as well. 
Q. That was -- that is the Boeing 727; correct? 
A. That is correct. 
MR. EVERDELL: Okay. You can take that down. 
Q. You occasionally flew other planes for him as well? 
A. Yes. 
Q. I think we saw in one of the photos, I won't call it up, 
but there was a small Cessna? 
A. Yes. 
Q. But from about 1994, after Mr. Epstein sold the Hawker, 
till about 2001 or 2000, I think is your recollection, when he 
bought the Boeing, you flew primarily the Gulfstream? 
A. That is correct. 
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Q. And from 2000 onwards or till 2004 or five, you were flying 
both the Gulfstream and the Boeing? 
A. That's correct. 
Q. Now, in the period from 1991, when you were first hired, to 
2005, you flew numerous flights for Epstein? 
A. Correct. 
Q. Would it be accurate to say that you flew over 1,000 
flights during that time period? 
A. I'd have to look at my records, but it was probably close 
to that, yes. 
Q. Give or take? 
A. Give or take, yes. 
Q. That's a lot of flights. 
A. We consider it more in hours than flights, but 
Q. Understood. 
And Epstein would frequently have other passengers on 
these flights, right? 
A. Yes. 
Q. And many of these passengers were female; correct? 
A. Correct. 
Q. And sometimes you saw the passengers, right? 
A. Yes. 
Q. There were times when you, I think, stood at the entrance 
of the plane near the cockpit when the passengers arrived and 
you might have greeted them? 
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A. Sometimes. 
Q. There were times when Epstein or Ghislaine introduced you 
to passengers? 
A. Correct. 
Q. There were times when the plane and the passengers had to 
clear customs, right, and the pilots and the passengers would 
have to get out of the plane and clear customs to do that? 
A. Yes, that's correct. 
Q. And you'd see the passengers then too? 
A. Sure. 
Q. Okay. And there were times when the passengers came up to 
the cockpit before takeoff and you might have met some of them 
then? 
A. Occasionally that would happen, sure. 
Q. Okay. Now, you testified that the cockpit doors for the 
Gulfstream and the Boeing were always closed during the flights 
while you were in the air; is that right? 
A. Yes. 
Q. But you left the door open to the cockpit as you were 
getting the plane ready for takeoff before you took off, right? 
A. Yes. 
Q. As you were in the cockpit, if you were looking back 
through the cockpit door, you could see the passengers in the 
entranceway if you wanted to, right? 
A. Most of them, yes. It wasn't a clear view to every seat in 
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the aircraft, but, yeah, I could see the passengers. 
Q. There were several ways that you could have observed and 
did observe the passengers that came onto his planes? 
A. Yeah, if I looked over my shoulder; correct, yes. 
Q. Or those other ways we discussed? 
A. At the entrance, yes. 
Q. Now, of the female passengers on these planes that you 
observed, you occasionally saw young girls who were traveling 
with their family members, isn't that right? 
A. There was some time when adults would bring their children 
onboard, sure. 
Q. But you never saw a female you thought was under the age of 
18 who was not with her family, right? 
A. Correct. No. 
Q. And apart from those times when you saw young girls 
traveling with their family members, you never saw any female 
on the plane who looked to you to be under the age of 20, isn't 
that right? 
A. Well, that's correct, yeah, I didn't notice anybody of a 
younger nature without an adult or, you know, a parent. 
Q. So in the roughly thousand or so, give or take, flights 
that you flew for Epstein from 1994 -- or 1991, I should say, 
to 2005, you never once saw a female on any of the planes who 
looked under the age of 20, apart from the ones who were 
traveling with their family members? 
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A. Correct. I didn't know anybody's, you know, exact age or 
age at all really. 
Q. But none of them appeared to you to be under 20? 
A. Correct. 
Q. Was that -- I didn't hear. 
A. Yes, that's correct, yes. 
Q. Now, that includes the woman that we have been referring to 
as 
; correct? 
A. Correct. I didn't know her age. 
Q. And she did not appear to you to be under the age of 20? 
A. I didn't know her exact -- I didn't know her age at all. 
But to my -- she looked like a woman. 
Q. She looked like a mature woman, I believe was your 
testimony before; is that right? 
A. Sure. Yes. 
Q. Okay. And it also includes the woman you referred to as 
A. Yes. 
Q. She also did not look below the age of 20 to you? 
A. I didn't know her age, but she didn't -- she didn't look 
young. I mean, wherever you decipher is the definition of 
"young," but she -- she was a woman in my category. 
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BY MR. EVERDELL: 
Q. She was a woman? 
A. Yes. 
Q. Mr. 
, in all these flights that you flew, the 
several hundred to a thousand flights that you piloted for 
Mr. Epstein in this time period, you also never saw any kind of 
sexual activity occur on the planes; isn't that right? 
A. I never saw any sexual activity, no. 
Q. And you certainly never saw anyone engaging in sex acts 
with underage girls on the plane? 
A. Absolutely not. 
Q. In fact, you never saw anyone engaging in sex acts with any 
of the women on the flights period; right? 
A. That is correct. 
Q. Now, you testified, I think we already established this, 
that when you were flying, in flight, the cockpit doors were 
closed? 
A. That is correct. 
Q. So if the cockpit doors were closed, you couldn't 
necessarily see what was going on in the cabin during the 
flights; right? 
A. Not at all, no. 
Q. But you were never instructed by Epstein or anyone else 
that you were not allowed to leave the cockpits during the 
flights; is that correct? 
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A. That's correct. Mr. Epstein invited us, that if we had to 
go to the bathroom, that we were welcome to walk to the back of 
the aircraft. 
Q. So he invited you to come anywhere you wanted to, even 
including in the back of the aircraft to use the restroom if 
you wanted to? 
A. Exactly. Yes, because there are times that if you have to 
use the restroom, like now. 
Q. We can take a break. 
A. I was hoping for a break in between. Am I the only one? 
THE COURT: Jury, I think it's time for our midmorning 
break. Why don't you finish the question and then we'll take a 
break. 
MR. EVERDELL: Yes, your Honor. 
Q. I'll just ask the question. He invited you to use the 
restroom at the back of the plane whenever you needed to? 
A. Yes, he offered, if we needed to use the restroom, to feel 
free to come into the back of the aircraft to use the restroom. 
Q. One last question before we break. To do that, you had to 
walk through the cabin to the back of the plane and go through 
the rooms of the plane to get to the restroom; isn't that 
right? 
A. If we were in the Gulf Stream, yes. In the Boeing, we had 
our own lavatory up front. But in the Gulf Stream, like, 
you're talking about from '94 to 2000, we would walk down the 
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middle of the aircraft because the bathroom was at the absolute 
rear, correct. 
THE COURT: Members of the jury, we'll take our 
midmorning break. See you in about 10 minutes. 
(Continued on next page) 
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(Jury not present) 
Everyone may be seated, the witness may step down for 
the break. 
(Witness not present) 
Are there matters to take up before the break? 
MS. COMEY: No, your Honor. 
MR. EVERDELL: No, your Honor. 
MS. STERNHEIM: Judge, may I just ask, it's very cold 
in here, can the temperature be risen just a little? 
THE COURT: I'm sweating. 
MS. STERNHEIM: Sorry. 
THE COURT: We'll get it raised. This is my light 
weather robe. We'll get it raised. 
MS. STERNHEIM: Thank you. 
THE COURT: I apologize. We'll see you in about 10. 
(Recess) 
THE COURT: Matters to take up, counsel? 
MS. COMEY: No, your Honor. 
MR. EVERDELL: No, your Honor. 
THE COURT: We can bring the witness back into the 
box. 
Mr. Everdell, do you have a time estimate? I won't 
hold you to it. 
MR. EVERDELL: Do you have an estimate for how long 
I've been going so far? I could probably --
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THE COURT: 20 minutes. 
MR. EVERDELL: I'd say maybe another hour or so. 
THE COURT: Okay. Ms. Sternheim, I have asked for 
4 
them to raise the temperature. 
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MS. STERNHEIM: Thank you, Judge. Feels better 
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already. 
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(Jury present) 
THE COURT: Please be seated. I hope you had a 
pleasant and timely break, members of the jury. Thank you for 
your continued attention and diligence. 
Mr. Everdell, you may continue with your cross 
examination of Mr. 
. And Mr. 
, I remind you that 
you are under oath. You may proceed. 
MR. EVERDELL: Thank you, your Honor. 
BY MR. EVERDELL: 
Q. Welcome back, Mr. 
A. Thank you. 
Q. Trust you're feeling more comfortable? 
A. Oh, much better. 
Q. Very good. Do you recall when we left off, we were talking 
about going to the restroom on the airplanes? 
A. Yes. 
Q. And I think you said that you were allowed, you were 
permitted and even invited to walk through the Gulf Stream to 
the back of the plane to use the restroom there if you needed 
to? 
A. That's correct. 
Q. So Mr. Epstein never told you, for example, you have to 
stay in the cockpit during the flight? 
A. Absolutely not. 
Q. Now if he were engaging in sex acts with underage girls in 
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the plane and he didn't want you to see that, he probably would 
have said something to you about that, wouldn't he? 
MS. COMEY: Objection, your Honor. 
THE COURT: Overruled. You may answer. 
A. Can you repeat the question. 
Q. Sure. If Mr. Epstein were engaging in sex acts with 
underage girls on his planes and he didn't want you to see it, 
he probably would have told you that you couldn't leave the 
cockpit during the flight; isn't that right? 
A. That's correct. 
Q. And he never told you that you could never mingle with the 
passengers; right? 
A. No, not at all. 
Q. In fact, you recounted how you did interact with the 
passengers on occasion; right? 
A. Absolutely on occasion, sure. 
Q. In fact, you were never given any rules about how you could 
or could not interact with the passengers; right? 
A. No, I was never told what to do with the passengers or what 
not to do. 
Q. And you were never given any rules about how you could 
interact with the other members of his staff or his assistants; 
isn't that right? 
A. That is correct, never. 
Q. Now, you did say that every once in a while you would leave 
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the cockpit to use the restroom? 
A. Correct. 
Q. And you did that both on the Gulf Stream and on the Boeing; 
is that correct? 
A. Yes. 
Q. The Gulf Stream bathroom, you said, was in the back of the 
plane; right? 
A. Yes. 
Q. And the Boeing bathroom was near the cockpit but outside 
the cockpit; is that right? 
A. Exactly, yes. 
Q. So if you went to the bathroom in the Boeing, you could 
still see the cabin where the passengers were, at least the 
first cabin? 
A. If the door was open. Each section of the aircraft had a 
door and typically the doors were open. 
Q. Well, in any of those trips to the restroom, you never saw 
any sexual activity on the plane? 
A. No, I never did. 
Q. And you had also, I think, occasion go to get coffee in the 
galley kitchen; is that right? 
A. In the Boeing, yes. I would go to the middle of the 
aircraft to get a cup of coffee on occasion, sure. 
Q. And as you said in the Boeing, the galley kitchens is in 
the middle of the aircraft; is that right? 
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A. That's correct. 
Q. So you would have to walk through at least that first cab':-: 
of passengers? 
A. That's correct. 
Q. And on those trips you took to get coffee in the galley 
kitchen, you never saw any sexual activity going on then, did 
you? 
A. No, never. 
Q. Now, after the flight landed, I believe it was part of the 
pilot's job to help clean up the cabin and straighten up a bit; 
isn't that right? 
A. Yes, it is. 
Q. And when you did that, you never saw anything like clothes 
strewn about the cabin; is that right? 
A. No, never. 
Q. You never saw any sex toys left in the cabin? 
A. Never. 
Q. You never saw anything like used condoms? 
A. Absolutely not. 
Q. You never saw anything that gave you the impression that 
any kind of sexual activity was taking place on the plane with 
anyone; is that right? 
A. That is correct, I never, no. 
Q. So sitting here today, based on what you observed, you have 
no reason to believe that Epstein or anyone else was engaging 
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in sexual activity with underage girls on the flights you 
piloted; isn't that right? 
A. Correct. 
Q. Mr. 
, I want to ask you some questions about how the 
flights were scheduled and set up. Okay? 
A. Sure. 
Q. Now, before a flight was scheduled, you and 
needed to be alerted ahead of time that Epstein needed to fly 
somewhere; isn't that right? 
A. Yes. 
Q. I think you said typically you get about a day's notice; 
isn't that right? 
A. That's correct. 
Q. And several different people would call you to schedule 
these flights; is that right? 
A. Yes. 
Q. And in the 1990s, focusing on that time period, you would 
occasionally get calls from Epstein himself to schedule 
flights? 
A. He would call on occasion, yes. 
Q. And every once in a while, you'd get a call from Ghislaine, 
as well? 
A. Sure. 
Q. But during that time period, it was usually Epstein's 
secretary or one of his other assistants in New York who would 
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