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FBI VOL00009
EFTA00068582
287 sivua
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200 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 call you to schedule the flights; isn't that right? A. It would be a variety. Whoever got the message would pass it along to us, correct. Q. Right. And I think you said that in the 1990s, you didn't have cellphones; right? A. Correct. It was a beeper, pager. Q. Beeper. This was over 20 years ago at this point; right? A. Coming in on 30, but yes, correct. Q. Coming in on 30. That's before everybody owned a cellphone; correct? A. Yes. Q. But you did have the beepers? A. Yes. Q. And you and would get a message on your beeper; right? A. Yes. Q. And you would call back Epstein's office, usually; right? A. Yes. Q. Because that's usually where the call came from, isn't it? A. That's correct. That was the number that would appear for departure. Q. And you would talk to Epstein's secretary or assistant or whoever was going to schedule that flight? A. Correct. Q. Now, occasionally, you said you talked to Ghislaine about SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068662
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201 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 this, about scheduling? A. Occasionally Ghislaine would reach out. Several people would reach out. Whoever Jeffrey told, hey, get the plane ready, that's the person that contacted me. Q. It was usually the case, if you spoke to Ghislaine about flight, she was going to be traveling on that flight? A. Most of the time, sure. Q. And in the 2000s now, fast forwarding to a later time period, you spoke to different people about scheduling flights; isn't that right? A. Yeah, whoever would get the message, correct. It would be different people. Q. Well, one person you spoke to in the 2000s was ; isn't that right? A. That's correct. Q. And was Epstein's secretary? A. That's correct. Q. And she worked in Epstein's New York office? A. That is correct. Q. Do you recall what number you used to call her on? A. Yes, the main office number. Q. Do you remember what that number was? A. Yes, I do. Q. What was it? A. 212-750-9895. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068663
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202 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. But the person I think you spoke most often to about scheduling flights in the 2000s was not , it was ; isn't that right? A. She would also schedule flights, yes. Q. You met , you said? A. Yes, I have. MR. EVERDELL: If we can pull up for the members of the jury and everyone else Government Exhibit 327, which is already admitted. Q. That's isn't it? A. That is , yes. Q. Now, you say you think you met her sometime in the early 2000s; is that right? A. It could have been late '90s. Again, we're 20, 21 years ago, but yeah, it was late '90. It could have been 2000. - remember Ms. obviously flying on the Boeing, which would have been 2000 and later. Yeah, it was late '90s. It's the best I could do as far as recollection. Q. Well, isn't it true that she first flew on one of Epstein's planes in September of 2001? A. I believe she -- well, she probably did because she was around in '01 when the Boeing was there. I haven't gotten any -- I don't have any documentation or -- but yes. MR. EVERDELL: Let me see if there is something that might refresh your recollection. I would like to pull up just SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068664
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LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 for the Court, the deputy, and for the witness 3527-07 at page 86. I'll repeat for clarity that's 3527-007 at page 86. THE COURT: Let me know when you're ready, Ms. Comey. MS. COMEY: I'm there. Thank you, your Honor. THE COURT: Thank you. BY MR. EVERDELL: Q. Mr. , if I could direct your attention to the sixth entry down on that list you're looking at. If you could just take a look at that. Just see if that refreshes your recollection about the first time flew. A. Is that the September 3rd date you're looking? Q. I'm asking, does that refresh your recollection? A. Well, it's a document of a regularly scheduled route. Obviously it's not my logbook. It was normal -- there was a typical routing that we would fly. It's the best I could say, but it would appear to be the -- it doesn't refresh of any, you know, certainty, but sure, that would be a date that we would do a trip like that. Q. Okay. So I'll just rephrase. , to the best of your recollection, was flying on Epstein's planes in the early 2000s? A. Yes. Correct. MR. EVERDELL: You can take that down. Q. Now, that is around the time when Epstein excuse me. When became Epstein's personal assistant; isn't SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068665
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204 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that right? A. I didn't know what her exact job detail was. I mean, I considered her position or her title, you know, throughout the same as far as to being Mr. Jeffrey's assistant or Ms. Maxwell's assistant, just that she was there as an employee. Q. Your recollection is that she was an employee who worked with Epstein; is that fair to say? A. Yeah. Exactly, yes. Q. But you're a little unclear exactly what her role was? A. Correct. Q. But she certainly did some work for Epstein in the time she worked in his office? A. Exactly, yes. Q. Do you recall, she was married to right: A. Later in life, I believe she got married to Q. So you said that would call you to arrange the flight departures? A. Sometimes, sure, yes. Q. And by that point in the 2000s or the early 2000s, you had cellphones; right? A. Correct. Q. So , when she did call you, would call your cellphone to arrange a flight; is that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068666
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205 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. That is correct. Q. In fact, you spoke to so often at that point that you had her number on speed dial in your phone; isn't that right? A. Most likely, yes. Q. Do you recall what phone number was? A. I do not. MR. EVERDELL: Let me show you something, see if it refreshes your recollection. I want to call up 3527-001, we'll go to the third page. That is just for the Court, the deputy, and the witness, please. MR. EVERDELL: May I proceed, your Honor? THE COURT: Yes. MS. COMEY: Thank you. Q. Mr. , do you have that document in front of you? A. Yes, I do. Q. Do you see just sort of maybe a third of the way down from the top of the page, there is an entry there. Does that refresh your recollection on what phone number was? A. Her number wasn't embranded in my mind as a memory, but the number does come back to me as being cellphone number. Q. So the number, was it A. That's correct, yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068667
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206 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. EVERDELL: Thank you. You can take that down. Q. So in the 2000s, that's the number you would speak to on about arranging flights? A. Correct. Q. Now, regardless of who you spoke to about scheduling flights, when you were told that Epstein needed to fly somewhere, you would need to be given certain information about the flight; correct? A. Sure. Q. Like, for example, you would need to be given the date of when Epstein wanted to fly? A. Correct. Q. You would need to be given roughly the time of departure: A. Yes. Q. And you would need to be given the destination where you're going to fly; right? A. Yes. That would be helpful, yes. Q. You might want to follow a flight plan or something like that? A. Yes. Q. But you wouldn't necessarily be told who was going to be going on the flight; right? A. Not at all. Q. If you had someone who was particularly important that was going to be on the flight, you might be told ahead of time? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068668
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207 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Exactly. Q. So, for example, I believe former president Bill Clinton flew on Epstein's planes a few times in the 2000s; isn't that right? A. Yes, he did. Q. So if he were going to be on the flight, you might be told that information in advance? A. Yes. Q. Because you might want to make sure the plane looked nice? A. Exactly. Q. You might want to invite some special caterer? A. Sure. Q. But otherwise, you might not know who would be traveling on the flight at all; is that right? A. Correct. Q. And even when the passengers arrived at the airport, even then, you wouldn't necessarily meet all the passengers; right? A. No, not at all. Q. A lot of the time you didn't meet them? A. Correct. Q. Sometimes you were just given their names? A. Yes. Q. And you wouldn't always be given all of their names; right? A. Correct. Q. Sometimes you would just be given a first name? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068669
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208 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Sure. Q. But even if you weren't told all the names or you didn't have all the names, you did try to keep track of how many people were on the plane; right? A. That's correct. Q. Because as you mentioned before in testimony, pilots need to fill out a passenger manifest for each flight; right? A. They don't have to on general aviation. It was more for weight and balance. It was my understanding we kept passenger information more for tax reasons on who flew on the aircraft in the early days. Might not be the case at this point, but we still tried to keep as accurate records, if we could, even if it wasn't necessary. Q. Fair enough. So but you did try to keep passenger manifests for flights on Epstein's planes? A. Absolutely, yes. Q. And a manifest, I think you described, among other things, contains the list of the passenger names if you have them; is that right? A. That's correct. Q. And if you didn't know their names, you might put in something like one female or one male or one passenger to note a named passenger? A. Exactly. We tried to at least identify the sex rather than just put one passenger. So that's why we had put male or SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068670
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209 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 female if we didn't catch a name. Q. Obviously, if you did know the name or it was a person you recognized from before, you would put their name on the manifest? A. Absolutely. Q. And you said that it was important to keep track of the head count, which is why you wanted to know how many people were on the plane; right? A. That is correct. Q. Now, you said weight was also a consideration; is that right? A. It's a consideration on some aircraft, not the kind that we're flying, but it's something that should take into account or as far as how heavy luggage is. But it is a consideration as a pilot to know how much something weighs as far as luggage and/or passenger. Q. And that's if you're flying a small plane, for example, you need to know the weight of the passengers? A. Exactly, yes. Q. But for the planes you were flying for Epstein, particularly the Gulf Stream and the Boeing, you didn't need to know the weight for those planes; right? A. It was not necessary, no. It's, like I said, more of a head count, but yeah, it's not a factor in these type of aircraft. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068671
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210 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Right, because the Boeing, as we saw it, it's huge; right? A. Correct. Q. And the Gulf Stream is not a little prop plane, it has a jet engine; right? A. Correct. It's not power challenged, correct. Q. So it wasn't your practice to ask passengers their weight before they boarded? A. No, absolutely not. Q. Now, it was sometimes the case, wasn't it, that if one of Epstein's friends or acquaintances or family members needed to go to the same place he was flying, he would take them on his plane; right? A. I'm sure on occasion. I don't know for a fact, but sure, if we were going to the same place, he may extend an invitation for somebody to come along. Q. He did have friends and family members and other people traveling on his plane? A. That is correct, yes. I see what you're saying. Q. It's like offering a lift in your car, except it's a jet? A. Correct, yes. Q. You call these people tagalongs; right? A. Yeah, there is several names, sure, but tagalongs or extra guest. Q. Now, in those cases, if the person or the tagalong was not a regular traveler, you might not know their name? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068672
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LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. That's correct. Q. Or you might just be given their first name? A. Correct. Q. Not be given a name at all? A. Correct. Q. So that's an example of where you might put one female, one male? A. That is correct, yes. Q. Now, the manifest, you testified that you kept the manifest; right? A. Yes. Q. And then eventually you gave them to the New York office? A. Correct. Q. I think you sent them, if I recall, to someone named in New York; is that right? A. Yes. Q. You did not send them to Ghislaine, though; isn't that right? A. No, they went to the main office, whether it be haven't heard that name in a long time. That was a memory refreshed. Thank you. Q. My pleasure. So you have no reason to believe that Ghislaine was reviewing these manifests; right? A. No, Ms. Maxwell had nothing to do with the passenger manifests. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068673
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212 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. So from your perspective, you had no reason to believe that Ghislaine would have known which passengers were on the flights that she didn't fly on herself? A. Correct. Q. I want to talk to you about a few specific flights. think you mentioned in your testimony a place called Interlochen; is that right? A. Yes. Q. Interlochen is, I think you recall, an arts center; is that right? A. Yes, correct. Q. It hosts an arts camp in the summer for musicians and singers and actors and other types of artists; is that right? A. That's correct. Q. And generally, in this summer camp, these artists, musicians, and singers are in high school; is that right? A. I didn't know where they -- I knew it was just an upcoming school for talented, I guess, children, because I would take it they're more on the younger side than older. Q. Understood. Are you aware that Epstein himself attended the Interlochen Summer Arts Camp when he was a young man? A. I did not. Q. Interlochen is located in Michigan? A. Correct. Q. And to get to Interlochen, you said you had to fly into SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068674
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213 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Traverse City, Michigan? A. That's correct. Q. That's the closest airport? A. That is closest. Q. And in the 1990s, you flew into Traverse City at least once a year or maybe twice a year in the summer months, you recall; right? A. That's correct. Q. Do you recall any of the passengers on those flights? A. I do not. Q. Isn't it true that Itzhak Perlman flew on some of those flights? A. As you said, it just dawned on me, yes, Itzhak Perlman did fly on some of those flights, correct. Q. Itzhak Perlman is a world famous violinist? A. Yes. Q. It's fair to say that Epstein went to Interlochen almost every summer in the 1990s; isn't that right? A. He went there often in the '90s, but like you, said we are going back a ways. Yes, correct. Q. You recall this being in the summer months? A. Summer months, yes. Q. These flights typically took place in August, didn't they? A. I don't know the exact month, but it was warm. Q. Let me see if I can show you something to refresh your SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068675
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214 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 recollection again. If we could pull up 3527-007 at page 2 just for the Court, the deputy, and the witness, please. We'll direct your attention, Mr. , from the bottom if you count up six or seven lines, if you look at those entries right there. A. Yes. Q. Okay. And you can look to the left-hand side, as well, in terms of the date. A. Yes. Q. Does that refresh your recollection about flying in the month of August to Interlochen? A. Sure it does, yeah. This certainly would be a trip that we would do. I recognize the identifiers. So it would be in the trip that we would do during that timeframe, yes. Q. So, you recall, I believe, right, that Epstein eventually had a cabin at Interlochen; isn't that right? A. That is correct. Q. So he would be going there at the end of the summers to stay in his cabin and see the performances at the end of the Interlochen Summer Camp; isn't that right? A. It was my understanding, which it could have been hearsay information, that I thought the cabin was bought or built for Itzhak Perlman, but that was just a rumor I heard, but I don't know whether or not Mr. Epstein actually stayed in the cabin or he donated it to the Interlochen School. I don't know a whole SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068676
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215 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 lot of facts on it, just sheer of what I know, what I remember. Q. But on those trips, Ghislaine wasn't with him every time he went, was she? A. I don't remember whether she was or not. I know Mr. Epstein was because he always traveled on the aircraft. Q. Let's take a look at that same document again to see if I can refresh your recollection. One moment. A. Sure. Q. I'll call up that same page if I could, 3527-007 at page 2, just for the Court, the deputy, and the witness. We'll look at the same entries as you did before, Mr. A. Okay. THE COURT: Describe those, please. MR. EVERDELL: Sorry. It's the sixth and seventh entries up from the bottom. Q. These are the ones we were looking at before; isn't that right, Mr. A. That's correct. Q. And if you look there, there is some indications of the passengers? A. Yes, I see that. Q. And does that refresh your recollection about whether or not there were flights to Interlochen that Ms. Maxwell did not fly on? A. I mean, it appears that way. Obviously this isn't my SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068677
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216 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 document, but I don't see Ms. Maxwell's name on there. It's just -- MS. COMEY: Your Honor, objection. THE COURT: Sustained. I'll have the jury disregarded observations of the document that are not in evidence other than to refresh his recollection, which we've moved beyond. MR. EVERDELL: Understood, your Honor. That's fine. Thank you, Mr. . We can take that down. BY MR. EVERDELL: Q. Mr. , I think you also flew Mr. Epstein a number of times to Columbus, Ohio; isn't that right? A. That's correct. Q. Columbus, Ohio is where Les Wexner lives? A. That's correct. Q. Les Wexner is the billionaire owner of the Limited? A. That's correct. Q. That's the clothing company? A. Yes. Q. It owns Victoria's Secret and Abercrombie & Fitch, among other companies? A. That's correct, yes. Q. And Les Wexner was a friend of Jeffrey Epstein's? A. I believe they were friends. Q. He was one of Epstein's clients, wasn't he? A. To my knowledge, Mr. Epstein would call him a client, yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068678
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217 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. And Epstein had a home and an office in Columbus, Ohio where Les Wexner's home was; isn't that right? A. That is correct. Q. So he had a few reasons to go to Columbus, Ohio? A. That's correct. Q. Now, you were asked a few questions by the government about a woman we are referring to as A. Yes. Q. Do you recall that? A. Yes. Q. Just to be clear, is not her real name; right? A. Correct. Q. But you do know what her real name is? A. Yes. Q. It's been shown to you? A. That's correct. Q. Now, you recall seeing on Epstein's plane on one occasion; is that right? A. One occasion for sure at the time that I had met her. Q. That's the only time you actually have a recollection? A. That I have a recollection of, correct. Q. And you recall this I think being in the 1990s; right? A. Yes. Q. Now you said, I believe, that you remember meeting her; is that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068679
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218 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. And that she was a singer; right? A. Yes. That's the way Mr. Epstein introduced her as. Q. And you said that I think she had striking blue eyes; is that right? A. Correct. Q. You'll forgive the question, Mr. , but I think you also remembered that at the time you saw her, you remembered she had large breasts; isn't that right? A. She was a mature woman, in my opinion. Q. Well, she looked to you like she was in her 20s, as we said before? A. Sure, yes. Q. Now, you remember that this meeting took place I think you said in Palm Beach? A. It was on the ramp in West Palm Beach, correct. Q. Now, it was sometimes the case that Epstein would invite people onto the plane before takeoff to show them the plane; isn't that right? A. Correct. Q. And sometimes Epstein brought them into the cockpit to meet the pilots? A. That's correct, yes. Q. And these people didn't always fly on the planes; isn't that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068680
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219 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. That's correct. He would bring passengers on just to show them the interior and the cockpit, correct. Q. Sometimes he would show them around, they would look around, maybe meet the pilots, and then leave before takeoff? A. That's correct, yes. Q. Sitting here today, you don't know whether the woman you met, , actually flew on that flight that you recall meeting her in the plane? A. I wouldn't be able to swear that she actually flew on it. I know I met her in the cockpit. Q. And you don't remember where that flight was going? A. No, I don't. Q. And you don't remember anybody else who was on that flight? A. I do not. Q. And again, you don't recall seeing specifically, seeing on the plane or any plane at any other time except that one time in Palm Beach that you recall? A. I can't visualize her sitting in the passenger compartment like I would, say, president Clinton. It was so long ago, but to answer your question, I can't visually see her sitting in the -- I see her standing in between the two pilot seats. That's my recollection of her. Q. On that one occasion? A. On that one occasion, yes, sir. Q. Now, you met, I believe, with the government on several SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068681