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A. No. 
Q. There were house managers that did that on a day-to-day 
basis? 
A. That's correct. 
Q. Now, your recollection is that Ghislaine generally worked 
out of Epstein's offices in New York; isn't that right? 
A. Yes. 
Q. And you testified there was a room in Epstein's offices 
that had about five desks in it that was sort of off to the 
right of his office? 
A. That's correct. 
Q. And that's what you called the personal assistants' room; 
right? 
A. There was no official name for it, but it was my best 
description of who was in that room. 
Q. And Ghislaine was one of the personal assistants who had a 
desk in that room? 
A. That's correct. 
Q. Now, when you first met Ghislaine in 1991, she seemed to 
you to be just an employee of Epstein; isn't that right? 
A. It might in the first introduction. 
Q. So at that point early on, I'm talking '91, '92 when you 
first started working, it didn't seem to you like she had a 
personal relationship with Epstein; right? 
A. No. I believe when Mr. Epstein introduced her, that he 
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needed help because he was expanding, getting bigger, you know, 
first time he had his own private jet, that he needed help to 
handle everything else in his life so that he could focus on 
his business. And when you start buying homes and properties, 
he --
Q. I'm sorry to interrupt. 
A. He knew he was going to get busy. So Ghislaine was his 
go-to person to handle everything else that was not 
business-related with his company. 
Q. So I think you said at some point, though, in the mid '90s, 
it may have appeared to you that Ghislaine was involved in a 
personal relationship with Epstein; isn't that right? 
A. Yeah, I thought they were a couple in the mid '90s. It's 
just my own take on it. 
Q. And that was based on your observations of them together at 
the time and how they interacted with each other? 
A. Sure. Yes. 
Q. They made travel plans together, they talked to each other, 
things like that? 
A. Yes. 
Q. But I think you testified that it wasn't totally clear to 
you that Epstein and Ghislaine had a romantic relationship; 
right? 
A. Yeah, I don't know what the definition of a romantic 
relationship is as opposed to just relationship. To me, 
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romantic would mean a more involved relationship. I wasn't 
aware of anything more than a couple. 
Q. You never saw them kiss you said; right? 
A. No. 
Q. You never saw them hold hands? 
A. No. 
Q. Now, it's fair to say, isn't it, that a lot of women were 
flying on the plane with Epstein in the mid '90s; isn't that 
right? 
A. That's correct. 
Q. It's fair to say that there were plenty of times that 
Epstein was flying on the plane with these women without 
Ghislaine? 
A. There has been times, sure. 
Q. It appeared to you that these women were adult women? 
A. Oh, yes. 
Q. So from your vantage point, whether Ghislaine or any one of 
these other women was somebody romantically involved or 
something else, is a little blurry; right? 
A. Yes. 
Q. In fact, I think the only person you really considered to 
be a girlfriend of Epstein was ill 
; is that right? 
A. That's the way she was introduced, as one of Mr. Epstein's 
original first girlfriends, correct. 
Q. By the time you started, she was an ex-girlfriend; right: 
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A. Exactly. 
Q. She was with him in the 1980s? 
A. Yes, before my time. 
Q. Now, 
before she was married, went by ill 
A. That's correct. 
Q. She was a former Ms. Sweden? 
A. That's what I heard. 
Q. She later married 
—; 
is that right? 
A. That's correct. 
Q. 
is a 
is that 
right? 
A. From my understanding, yes. 
Q. He was one of Epstein's clients; isn't that right? 
A. I don't know if he was a client. I know he was a friend. 
Q. But during the period when Ghislaine and Epstein appeared 
to you to have some sort of a personal relationship, she 
continued to work for him as an employee; isn't that right? 
A. Who's that, Ms. Maxwell? 
Q. Ms. Maxwell, yes. 
A. Yes. 
Q. Ghislaine. I'm talking Ghislaine still took care of the 
houses? 
A. Yes. Yes. 
Q. She still shopped for him? 
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A. Yes. 
Q. And you talked to her about the work she did for Epstein, 
didn't you? 
A. Yes. 
Q. She would talk about all the work she was doing on these 
houses, wouldn't she? 
A. Yeah, she would tell what's going on and the troubles of 
decorating and house managers, et cetera, yes. 
Q. She'd talk about how demanding the job was; right? 
A. Yes. 
Q. Now, at some point, it appeared to you that whatever the 
personal relationship was between Epstein and Ghislaine sort of 
fizzled out; is that right? 
A. Yes. 
Q. And I think that was in about 2000, right, the best of your 
recollection? 
A. It was the early 2000s, correct. 
Q. Now, Ghislaine was still traveling with Epstein in the 
early 2000s; right? 
A. Yes. 
Q. She was still his friend? 
A. Yes. 
Q. But by that time, her role in Epstein's life was 
decreasing, wasn't it? 
A. I don't know how the decreasing point did, but it just 
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wasn't as personal, it was obviously more business, because in 
early 2000s is when we went around the world in the Boeing. It 
was just decreasing. 
Q. It was all business; right? 
A. It was all business. 
Q. And Epstein, at that time, brought in other people to help 
run his day-to-day business, didn't he? 
A. Yes. 
Q. You testified already that 
appeared around 
that time in the early 2000s; isn't that right? 
A. That's correct. 
Q. She was another one of Epstein's personal assistants? 
A. Yes. 
Q. And she became the person or one of the people you spoke to 
about arranging flights; right? 
A. That's correct. 
Q. And do you recall the name 
A. Yes, I remember that name. 
Q. She also became one of Epstein's assistants around that 
same point in the 2000s; isn't that right? 
A. Yes. 
Q. And you interacted with her? 
A. Yeah, not as much, but yeah, I did. It's not like I would 
with Ms. 
, but yes. 
Q. And there were, in fact, many other assistants who appeared 
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over the years in the 2000s, as well, weren't there? 
A. There was many, yes. 
Q. Now, you testified that by 2004 or so, to the best of your 
recollection, Ghislaine was traveling much less frequently on 
Epstein's planes; isn't that right? 
A. Yes. 
Q. She was moving on from Epstein, was she not? 
A. That's correct. 
Q. Isn't it true that by 2004, Ghislaine was in a committed 
relationship with another man? 
A. Yes. 
Q. You're familiar with Ted Waitt? 
A. Yes, I am. 
Q. He's the cofounder of Gateway Incorporated, the computer 
company, isn't he? 
A. That's correct. 
Q. And Ghislaine was in a relationship with Ted Waitt by 2004, 
wasn't she? 
A. I don't know if it was a relationship, but I know she was 
spending a lot of time with Mr. Waitt, and I think he was 
completing a boat that she was involved in decorating and 
building a helipad on it. So it was a different transfer to 
Mr. Weight. 
Q. And, in fact, I think Ghislaine introduced you to Waitt's 
pilots, you guys became friends? 
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A. Yes. 
MR. EVERDELL: Your Honor, this is a convenient 
stopping point. 
THE COURT: We'll break here for lunch. Members of 
the jury, we'll take about a 45-minute lunch break. Enjoy your 
lunch. Thank you for your continued attention. Witness may 
step down for the lunch break. 
(Continued on next page) 
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(Jury not present) 
(Witness not present) 
Matters to take up before the break. 
MS. COMEY: No, your Honor. 
MR. EVERDELL: Nothing, your Honor. 
(Recess) 
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AFTERNOON 
SESSION 
1:35 P.M. 
THE COURT: Matters to take up, counsel? 
MS. COMEY: Very briefly, your Honor. 
Some of the courtroom sketch artists have indicated 
confusion about the order about who they are allowed to draw 
and not. And so I think we would propose that before we call a 
witness who cannot be sketched, that that be put on the record. 
THE COURT: Okay. The only restriction is with 
respect to the witnesses who I've permitted to testify 
anonymously. 
MS. COMEY: That's correct, your Honor. And any 
sealed exhibits, if someone were to somehow glimpse a sealed 
exhibit, though I think that's unlikely given the precautions 
we're taking. 
THE COURT: Okay. So let's just talk through the 
protocol, also what the witness will be called using the 
pseudonym. 
MS. COMEY: Yes, your Honor. 
THE COURT: And then I'll swear them in. I would 
typically say, State your name for the record. I'll just say, 
I've granted you permission to testify under the pseudonym, 
fill in the blank. And then turn the witness over for 
questioning. 
MS. COMEY: Thank you, your Honor. 
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THE COURT: And when I do that, I'll ask the sketch 
artist not to draw exact likeness of that witness, consistent 
with my ruling. 
MS. COMEY: Thank you, your Honor. 
THE COURT: Okay. Thank you. 
MS. COMEY: Nothing further. 
THE COURT: Mr. Everdell? 
MR. EVERDELL: Nothing from the defense, your Honor. 
THE COURT: Okay. We can bring the witness back. 
And Ms. 
, please bring in the jury. 
(Jury present) 
THE COURT: Members of the jury, I hope you had a 
pleasant lunch. Thank you. 
THE LAW CLERK: Judge, one second. 
THE COURT: All right. Thank you. 
Everyone, I hope you had a good lunch. Thank you for 
your continued attention and diligence. 
Mr. Everdell, you may continue with your 
cross-examination of Mr. 
Mr. 
, I remind you you are under oath. 
THE WITNESS: Yes, ma'am. 
THE COURT: Go ahead. 
MR. EVERDELL: Thank you, your Honor. 
resumed. 
BY MR. EVERDELL: 
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Q. Good afternoon, Mr. 
A. Good afternoon, Mr. Everdell. 
Q. I just want to begin with a quick question about the ranch, 
all right? 
A. Yes. 
Q. You testified before that it had a lot of acreage? 
A. Yes. 
Q. I think you said roughly 10,000 acres or so? 
A. 10,000, yes. 
Q. And there was a lot of open space on that ranch, right? 
A. That's correct. 
Q. And one of the things that guests, I think, typically like 
to do when they were there was to go hiking, right? 
A. Correct. Yes. 
Q. Lots of places they could go hiking on the ranch? 
A. Sure they could, yes. 
Q. But it's true, isn't it, that the property had a lot of 
rattlesnakes on it, isn't it? 
A. Yes, there are several rattlesnakes, yes. 
Q. Okay. And it was wild country out there. 
A. Yes. 
Q. Okay. And so if you were going to hike on this property, 
you needed proper footwear to go hiking, right? 
A. Yes. 
Q. All right. So people would typically wear boots to go 
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hiking? 
A. That would be a first choice, yes. 
Q. And that would be recommended for any guest who wanted to 
go hiking, right? 
A. Yes. Correct. 
Q. Okay. Thank you. 
And I'll just say, I was reminded by the court 
reporter that we shouldn't talk over each other, so I'll try 
not to do it and we'll do the same, okay? 
A. Yes. 
Q. Thank you. 
All right. I want to talk to you a bit about your 
enter actions with Ghislaine. 
A. Okay. 
Q. You testified that you first met Ghislaine in about 1991, 
when you started to work for Mr. Epstein, right? 
A. That's correct. 
Q. And Ghislaine would have been about 29 or 30 years or so 
when you first met her? 
A. Yes. 
Q. And Epstein would have been about 37 or 38 at the time; is 
that right? 
A. That is right. 
Q. And you said that Ghislaine flew on numerous flights with 
you in the 1990s and 2000s, right? 
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A. That is correct. 
Q. And so you knew her and you interacted with her for, it 
would be, about 15 years, from the early 1990s to the mid 
2000s; is that right? 
A. That is correct. 
Q. Now, in that whole time period, Ghislaine never appeared to 
you to be pregnant, did she? 
A. No, not at all. 
Q. No one ever told you she was pregnant? 
A. No, never said that. 
Q. And you never saw any pictures of her pregnant at any of 
the residences? 
A. No, I did not. 
Q. Now, you had some regular interactions with Ghislaine about 
your job, right? 
A. Correct. 
Q. For example, I believe Ghislaine reviewed your expense 
reports? 
A. Yes, that was one detail, yes. 
Q. So you said you took your expense reports to the New York 
office maybe about once a week? 
A. Yeah, whenever I was in New York; correct. 
Q. And it was Ghislaine's job to review them and approve them, 
right? 
A. It was one of her duties, yes. 
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Q. And you also talked to her about scheduling maintenance 
visits for the planes, right? 
A. That's correct. 
Q. And you talked to her about scheduling your own vacations, 
right? 
A. Yes. 
Q. So generally speaking, these were the main interactions you 
had with Ghislaine regarding employment issues and your job? 
A. Yes, that was a good description of a lot of the 
interaction that I had with Ms. Maxwell; correct. 
Q. But now when Ghislaine had time when she wasn't working, 
she spent time on other pursuits, right? 
A. Yes. 
Q. She became a trained emergency medical technician, didn't 
she? 
A. I know she had some medical training, yes. 
Q. EMT? 
A. EMT, yes. 
Q. And she also became a trained helicopter pilot, too? 
A. Yes, she did. 
Q. You, yourself, are a trained helicopter pilot, right? 
A. Yes, I am. 
Q. And you traveled with Ghislaine when she went to school to 
become a trained helicopter pilot, right? 
A. Yes, we traveled frequently together. 
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Q. Now, Epstein bought his first helicopter, your recollection 
was, sometime around 1990, 2000; is that right? 
A. Yeah, '99 to 2000; correct. Yes. 
Q. So sometime, I believe, in the early 2000s, Ghislaine went 
to school to become a trained helicopter pilot; is that right? 
A. Yes, she did. 
Q. That school was in Pompano Beach, Florida? 
A. That's correct. 
Q. Pompano Beach is about an hour or so drive south of Palm 
Beach, right? 
A. Yeah, give or take traffic. It could be longer some days; 
but, yes, it's approximately an hour from Palm Beach to 
Pompano. 
Q. And the training sessions that she was taking were about 
one to three times per week, right? 
A. That's correct. 
Q. Each training session lasted about three to four hours, 
isn't that right? 
A. Yes, if not longer. Because there's a lot of preparation 
before you fly, and you're flying for an hour and a half, and 
then you're still talking about it afterwards, you know, with 
your instructor, and then your drive home. So it could be a 
long duration. 
Q. Right. So each training session was basically a full-day 
event, wasn't it? 
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A. Sure, it was. 
Q. You had to drive, take the course, talk to the instructor, 
drive back, all that took about a day, right? 
A. Yes. 
Q. So it's fair to say she was away from the Palm Beach 
residence for the whole day when she was taking these courses, 
right? 
A. Yes, good chance, yes. 
Q. And that helicopter course that she took took about eight 
months to a year to complete, isn't that right? 
A. Yes. 
Q. That course took a fair amount of time, didn't it? 
A. Took a lot of time, yes. 
Q. And it goes without saying that at the time, the time that 
Ghislaine spent at those training sessions in Pompano Beach, 
she was not at Epstein's residence in Palm Beach, isn't that 
right? 
A. That's a correct assumption. 
Q. Now, you also accompanied Ghislaine to a different 
helicopter training school in Dallas, Texas; is that right? 
A. That's correct. 
Q. Do you remember when that was? 
A. It was definitely once a year, because we were required to 
go back for recurrent training. But I don't know the dates, 
but it was definitely once a year we would go to Dallas for 
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training together. 
Q. And do you remember how long that training lasted on those 
trips? 
A. That class, it was typically, I believe, four days; two 
days of ground school, and two or three days of flight. It 
could be four to five days, if memory serves. 
Q. And those training sessions that you're referring to in 
Dallas, you said, took place every year you recall, right? 
A. Every year is a requirement for us as pilots. 
Q. Do you remember when in the year those took place? 
A. I do not. I remember it being warm, not extremely cold, so 
I would have to do the summer months; but, you know, the dates 
escape me without any documentation of when we took the 
courses. 
Q. Okay. You guys had fun on those trips, right? 
A. The training was hard, but we tried to make the best of it. 
Q. I mean, you occasionally went out to a steak dinner while 
you were there together? 
A. Yes, we did. 
Q. Those were fun events, right? 
A. Yes. 
Q. Now, once Ghislaine had her pilot's license, her helicopter 
pilot's license --
A. Yes. 
Q. -- she flew Epstein's helicopter; is that right? 
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A. Yes, she did fly the helicopter. 
Q. You accompanied her on those flights as the more 
experienced pilot? 
A. Yeah, I was going to go in that direction, but yes, I 
accompanied her as a safety pilot. We flew together. 
Q. And to your knowledge, that was Epstein's helicopter, not 
Ghislaine's helicopter, right? 
A. That's correct. 
Q. So Ghislaine couldn't call you up and say, I want to fly 
the helicopter. Have it ready for me. Right? 
A. She might have; but, no, that wasn't the normal situation. 
We always had a mission to go on, and it was probably 
Mr. Epstein driven. But to my knowledge, it was Mr. Epstein's 
helicopter, yes. 
Q. To your knowledge, it was Mr. Epstein who controlled 
whether or not the helicopter was flown or not? 
A. Correct. Yes. 
Q. Okay. Now, you said that when Ghislaine did fly the 
helicopter, you would fly with her as the more experienced 
pilot? 
A. Yes. 
Q. And you got to know her a little bit from that too, from 
your shared enjoyment of piloting helicopters, right? 
A. Yes, we talked a lot about aviation. 
Q. And you remember her as a nice person, right? 
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A. Yes. 
Q. And you felt comfortable around her? 
A. Yes, I did. 
Q. You never saw Ghislaine do anything or say anything that 
would lead you to believe she was helping Epstein or anyone 
else sexually abuse underage girls? 
A. No, not at all. 
Q. Now, Mr. 
, you testified before that you have two 
girls of your own. 
A. That is correct. 
Q. When you started working for Epstein in 1991, how old were 
your daughters? 
A. When I started working, well, one was one year old and one 
was not born yet. 
Q. And in the mid 1990s, how old would they have been then? 
A. Mid 1990s. So if you're going to use 1995, so one would be 
five years old and one would be one year old. 
Q. Okay. And by the time you get to the mid 2000s, let's call 
it 2004, just to pick a date, how old would they have been 
then? 
A. Okay. It's a math quiz. Let's see. 
Q. Sorry. 
A. We're '94. So we're talking 14 
11 and 14. 
Q. So I said 2004; is that right? 
A. 2004; correct. So one would be 14. One was born in '90, 
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