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FBI VOL00009
EFTA00068582
287 sivua
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220 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 times before coming here to testify today; isn't that right? A. Yes. Q. And at one of those meetings, they showed you the same document that I've been showing you just today to refresh your recollection; isn't that right? A. Was that reference to the logbook looking -- Q. Yes. A. Okay. I don't remember if I did see any from the government on that. I'm drawing a blank. I'm going to go with yes. Q. Well, do you recall them pointing out certain flights to you? A. Yes. Q. To see if you recall them? A. Yes. Q. You do remember that? A. Yes, I do. Yes. Q. And in particular, they pointed out certain flights to you where a female passenger was listed with just her first name. Do you remember that? A. Yes. Q. And that first name was the same as true first name; is that right? A. Correct. Q. And that did not list the passenger's last name, right, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068682
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221 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 just her true first name? A. Correct. Yes. Q. And there were three of those flights; is that right? A. As far as that same first name? Q. Yes. A. I'm sure, yeah, there is at least three. Q. There was one in '96, one in '97, and one in '98 they showed you; is that right? A. I don't remember the dates, Mr. Everdell. Q. Do you remember those three flights they showed you? A. Yes. Q. Well, when you met with the government and they showed you these three flights, you couldn't recall whether the woman we are referring to as actually flew on those flights or whether it was somebody else with her same first name? A. Correct. There was a -- the first names were the same, but there were no last names. Q. Now, sitting here today, you still don't know whether the women we're calling flew on any of those flights; isn't that right? A. Not to my knowledge. I mean, it was just -- I couldn't tell one from the other with no last name and 20 -- like you said, 20, 22 years ago. Q. Sure. But there were other people in Epstein's world who had that same true first name; isn't that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068683
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222 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, yes. Q. For example, Epstein had an assistant with that same first name; isn't that right? A. That is correct. Q. And it was spelled the same way, wasn't it? A. Yes. Q. And you met that person, didn't you? A. Yes, I did. MR. EVERDELL: One moment, your Honor. Your Honor, I apologize for the delay. We have a slight choreography issue that we're dealing with here. I wonder if it might be appropriate if we could take a brief break to deal with it or I can try to do it without the issues of the choreography. MS. COMEY: Your Honor, I think a brief break would help with the choreography. I apologize. THE COURT: You mean to send the jury back to the jury room? MS. COMEY: I think that might be necessary, your Honor. There is an exhibit that needs to be submitted under seal instead of on the screens. THE COURT: Okay. Is it possible to move past this moment and then return to it later? MR. EVERDELL: Your Honor, actually, we can do that. If I'm permitted to fix the problem and then display it later, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068684
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223 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 we just have to return to this topic when we can figure this out. As long as I'm able to return to this topic and display things to the jury, that's fine. MS. COMEY: That's fine with me, your Honor. THE COURT: I don't usually tell lawyers what topics -- you're not going to get an asked and answered objection, if that's -- MR. EVERDELL: Yes. Understood, your Honor. THE COURT: So we'll keep going for now. I presume we'll hit the lunch break time and then you can do the choreography. MR. EVERDELL: That's fine, your Honor. We'll do that. We're breaking for lunch when? THE COURT: We have jury lunches at 12:30. If you're otherwise done by then, we'll break early and do that. MR. EVERDELL: Let me see if I can also fix it in the meantime. THE COURT: Mr. Everdell, my deputy reminds me, we have a close room with bathrooms, we can just do a short break for the jury. MR. EVERDELL: Thank you, your Honor. THE COURT: So we'll do a five-minute break, members of the jury. Ms. will take you just to that first room where the restrooms are. Thank you. (Recess) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068685
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224 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury not present) THE COURT: Are you set, Mr. Everdell? MR. EVERDELL: Your Honor, I have the copies. What I need to do is insert them into the folders. MS. COMEY: No objection, your Honor. THE COURT: Go ahead, Mr. Everdell. (Pause) Are you ready, Mr. Everdell? MR. EVERDELL: Yes. THE COURT: The procedure will be you will direct the jury to open the folder under the chair and turn to a particular page? MR. EVERDELL: Yes. This one will be done on paper, your Honor. We'll have it on the screen for the Court, the deputy, and the witness, but the jurors will just have it in paper, as will the government, and it will not be displayed to the public. THE COURT: This is choreography to maintain the anonymity of the witnesses who might be permitted to testify under pseudonyms? MS. COMEY: That's exactly right, your Honor. And for that reason, we're going to ask that the two exhibits that the defense is about to offer be offered under seal. THE COURT: I am grateful to both counsel for working that through. Thank you. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068686
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225 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: Yes, your Honor. THE COURT: We'll bring in the jury. (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068687
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226 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury present) THE COURT: Members of the jury, I guess it ended up being more a medium break, but you're getting your steps in. So, we are ready to proceed, Mr. Everdell, whenever you're ready. MR. EVERDELL: Thank you, your Honor. BY MR. EVERDELL: Q. Hi again, Mr. A. Hi. Q. So when we broke, we were talking about other people in Epstein's world who had that same first name as we were talking about as ; right? A. Yes. Q. And you said that Epstein had an assistant with that same first name? A. Yes, there was another person with that same name. Q. And spelled the same way? A. Correct. Q. And you met that person? A. Yes. MR. EVERDELL: Now, just for the Court, the deputy, and for the witness, if you could please display LV3A and LV3B, if you can display them together. Q. Do you see those, Mr. A. Yes, I do. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068688
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227 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. Those are two photographs; is that right? A. That's two photographs. Q. Do you recognize the person in those photographs? A. Yes, I do. Q. Is it the same person in both photographs? A. Yes. Q. And you know that person's name? A. Yes. Q. Without telling us the name, is that the person we've been referring to just now that has the same first name as true first name? A. That's correct, yes, it is. Q. And is that a fair and accurate depiction of that woman? A. Yes. MR. EVERDELL: The defense offers LV3A and LV3B. MS. COMEY: No objection so long as they are sealed, your Honor. MR. EVERDELL: We offer them under seal, your Honor. THE COURT: LV3A and LV3B are admitted under seal consistent with my ruling allowed certain witnesses to testify under pseudonyms to protect their privacy. (Defendant's Exhibits LV3A, LV3B received in evidence) MR. EVERDELL: Thank you, your Honor. Now if I could, with the Court's permission, members of the jury, you can take out the manilla folders that are under your chairs, but please SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068689
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228 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 don't open them yet. I would just, with the Court's permission, instruct, especially the jurors who are here on the right side of the jury box, as you look at the photos, because they are under seal, please do it in such a way that you do not display what you're looking at to the members of the gallery. So keep that manilla folder upright so no one could see, if you would. Is that right all right, your Honor? THE COURT: Yes. MR. EVERDELL: Is it okay with the government? MS. COMEY: Yes, your Honor. MR. EVERDELL: If you would open the folders and please look at what's been marked as LV3A and LV3B. When you've had a chance to look, you can return the folders under your chair. And you can take that down. BY MR. EVERDELL: Q. Now, Mr. , you spoke to this person in the photos on a number of occasions; is that right? A. That's correct. Q. In fact, you've spoke to her frequently enough that you even had her phone number in your cellphone; right? A. That's correct. Q. And she traveled frequently with Mr. Epstein on his planes; isn't that right? A. Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068690
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229 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 that woman is not , is she? A. Correct. Q. And you testified earlier that you often didn't meet the passengers on the flights, you were just given their names sometimes before takeoff; right? A. Correct. Q. So, for all you know, there may have been many other people with that same first name as first name who traveled on Epstein's planes? A. True. Q. But the bottom line is, you don't know whether was on any of those three flights where there is a passenger listed with true first name? A. Not the three flights you made reference to. Without the last name, I didn't know which one you were referring to or who it was. Q. Thank you. I want to ask you just about a few more flights. A. Sure. Q. Are you familiar with Prince Andrew, the Duke of York? A. Yes, I am. Q. He is the son of Queen Elizabeth II of England, is he not? A. Yes. Q. Did he ever fly on Epstein's planes? A. Yes, he did. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068691
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230 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. Do you recall the first time when he flew on the plane? A. I do not. Q. Do you recall someone named Emmy Tayler? A. Yes. Q. She was one of Ghislaine's assistants, wasn't she? A. Yes, she was. Q. She started working for Ghislaine in around 1997 or so; isn't that right? A. I don't know the exact date and I actually didn't remember the name until you brought it up, but that's correct, that's a name from the past. Q. Well, did Emmy Tayler fly on Epstein's planes? A. Yes, she did. Q. Do you recall the first time she flew? A. I do not. Q. Are you familiar with the name Andy Farmer? A. Yes. Q. Do you recall meeting or seeing anyone named Andy Farmer on any flights? A. I don't remember. I know the name, but I think we're going back a long way. Q. Well, to your knowledge, is there any record of anyone named Andy Farmer ever flying on A. I don't know of any record. MR. EVERDELL: Just one moment, your Honor. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068692
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231 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. Q. Mr. I'll ask we put up for the Court, the deputy, and LV4 and LV5. , do you see those documents in front of you? A. Yes, I do. Q. Each of those documents has a name on it; isn't that right? A. Yes. MR. EVERDELL: Without objection, I believe we will offer these under seal as LV4 and LV5. MS. COMEY: No objection, as long as they're under seal, your Honor. THE COURT: LV4 and LV5 are admitted to the extent of my rulings that certain witnesses may testify pursuant to pseudonyms in order to protect them. (Defendant's Exhibits LV4, LV5 received in evidence) MR. EVERDELL: At this point, I will ask the members of the jury if the government is okay to pick up their folders one more time. MS. COMEY: No objection, your Honor. THE COURT: Go ahead. MR. EVERDELL: It's the same procedure as before. I'm going to ask you to look at the documents that are underneath the two photographs you've already looked at. Please do not show any of them to the members of the gallery. BY MR. EVERDELL: Q. Mr. , I'm going to start with what's now in evidence SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068693
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232 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 as LV4; all right? A. Yes. Q. I'm going to refer to the person there as Kate, okay? A. Okay. Q. Now, LV4 has a true name on that exhibit; is that right? A. Correct. Q. Do you recognize true name, the one that's on the paper of LV4? A. Not really. Q. Do you recall meeting or seeing anyone with true name on any of the flights? A. Not to my knowledge. It's not jumping out at me at all. Q. To your knowledge, there is no record with true name ever flying on any of Epstein's flights? A. I don't recall any of them. Q. Now please look at LV5. That has a full name on it, too, doesn't it? A. Yes. Q. And that person's first name is -; correct? A. Correct. Q. I'm going to refer to that person by her first name, , okay? A. Okay. Q. Do you recognize full name that's on the paper, LV5? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068694
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233 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. I do not. Q. Do you recall meeting or seeing anyone with full name on any flights? A. I do not. Q. And to your knowledge, there is no record of anyone with full name flying on any of Epstein's flights? A. Not to my knowledge. I don't have any memory at all. Q. Mr. , during your testimony so far, you've mentioned the names of some pretty important people; isn't that fair to say? A. Yes. Q. You already said that former president Bill Clinton flew on some of the flights? A. Yes, he did. Q. And Prince Andrew on some of the flights? A. Yes. Q. Itzhak Perlman, the famous violinist, on some of the flights? A. Yes. Q. Donald Trump, before he was president, also flew on Epstein's flights; isn't that right? A. Yes, he did. Q. He flew on them a number of times; right? A. There was more than once I believe, yes. Q. Sometimes he flew with his family members, too; right: SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068695
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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. I don't know -- I don't remember that. I certainly remember President Trump, but not nearly the other people associated with him. Like I said, if it was something special that would get embranded in my head, I certainly remember the president. Q. Did Robert Kennedy Jr. also fly on his plane? A. I don't remember. I'm not remembering that one. Q. What about Senator John the former astronaut? A. I do remember Senator yes. Q. Former Senator George Mitchell also flew on his plane? A. I do remember. Q. The actors Kevin Spacey and Chris Tucker also flew on his plane? A. I remember them, as well. Q. It's fair to say that these are all pretty high profile people; is that right? A. Correct. Q. And these are people who the public at large would be interested in? A. Sure. Q. And these are all people who are subject to a great deal of media attention and scrutiny; is that right? A. I would assume so, yes. Q. And these are all people who might have legitimate privacy concerns about their goings on? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068696
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235 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. Correct. Yes. Q. Mr. , I think you were asked as part of your employment to sign a nondisclosure agreement? A. That is correct. Q. Now, when you were asked to sign a nondisclosure agreement, you didn't think it was unusual, did you? A. Not at all. Q. And you certainly didn't take it to mean that you needed to sign it so you wouldn't disclose some kind of illegal activity that was happening on the plane, did you? A. No, of course not. Q. You never saw anything that came close to that; right? A. Correct. Q. You just took it to mean you couldn't write a book about the stuff and the people you were interacting with; right? A. That's correct. Several of my colleagues have signed the same or similar documents in my profession. It's a fairly normal request. Q. So for people who fly private jets, this is a fairly common occurrence? A. That is correct, sure. Q. You have a lot of people, high profile people we just mentioned, who don't want necessarily all their business written about in a book; right? A. Exactly. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068697
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236 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. I want to ask you a little bit about where you stayed when you flew to Epstein's residences. All right? A. Okay. Q. Now, I believe your home is near Palm Beach; is that right? A. Yes, it was. Q. So when you flew to Palm Beach, you stayed in your home; right? A. Correct. Q. That's where you're based? A. Correct. Q. When you flew to New York, where did you stay? A. The first part of my employment with Mr. Epstein, I stayed in a hotel, but then later on, I was offered to stay at a building he owned, an apartment building on East 62nd or 66th Street. So I had my own apartment. Q. Was that 301 East 66th Street? A. That is correct. Q. Is that where your partner, copilot Dave Rogers also stayed? A. That's correct. Q. And that's an apartment building? A. That is correct. Q. These are basically corporate apartments? A. Correct. Q. Do you know if Epstein owns that building or rents those SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068698
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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 apartments? A. I don't know the actual business of it. It was to my knowledge that he owned the building. Q. But it's safe to say that you and stayed there on your trips to New York? A. That is correct. Q. Do you know if any other Epstein employees stayed there? A. Yes. Q. So you saw some other employees in the building when you were there; right? A. Correct. Q. For example, you saw in the 66th Street building; is that right? A. That's correct. Q. Do you remember any others you saw there? A. The other person was the one we can't say the name. Q. Okay. So you saw the person whose photographs we just looked at, LV3A and LV3B; right? A. That is correct, yes. Q. You saw that woman in that apartment building? A. That is correct, yes. Q. But you never saw the woman we're referring to as there, did you? A. No, not -- no. Q. All right. Now, for the ranch in New Mexico, your SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068699
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238 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 is that Epstein bought the ranch I think sometime in the mid 1990s; is that right? A. That's correct. Q. And when he first bought the property, that large main house that we saw pictures of hadn't been built yet right? A. That's correct. Q. That house was under construction for several years; right? A. That's correct. Q. I think you said it was finished towards the end of the '90s, 2000? A. Correct. Q. So you stayed when you went to the ranch in the mid to late '90s -- well, where did you stay? A. In the early part of the mid '90s, I stayed at the Ranch Central in the bunkhouse rooms, and then later on I built a home on the ranch. Q. I'll ask you about that home in a bit. But for the first part, you stayed in Ranch Central; right? A. Ranch Central, correct. Q. And the ranch hands and the property manager stayed there, as well? A. They stayed in the other buildings associated with Ranch Central, but mostly the Ranch Central lodge or bedrooms were for guests that were on the aircraft. But everybody stayed, really, at Ranch Central, like you said, employees or workers SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068700
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239 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 on the ranch that lived there. Q. And you said that Epstein, before the main house was built, stayed in that triple-wide trailer you called the lodge; is that right? A. That's correct. Q. Okay. And you've described it already, I think from the outside, it had a deck; is that right? A. That's correct. Q. And it sort of looks nicer than a trailer does from the outside, it was outfitted that way? A. Correct, yes. Q. About how big was it? A. It was probably around two 2,000 square feet. Q. You went inside it? A. Yes. Q. How many times were you inside that triple-wide trailer? A. Many times. Q. And you described the interior before, but you mentioned a number of bedrooms. Can you just describe a little bit when you walk in the front door where things are situated from the front door entrance, the different rooms? A. Sure. When you walked in the front door, there was immediately to your left, there was a fireplace on the wall. Across from the fireplace, there was a couch that faced the fireplace. You went further in, you're in the middle of the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068701