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and the other, '94. So, yeah, 14 and 11-ish. 
Q. So one was a teenager and one was a preteen? 
A. That's correct. 
Q. Now, your daughters occasionally spent time with Ghislaine 
on the ranch in New Mexico, especially after you built your 
house there; isn't that right? 
A. Yes. 
Q. They loved the animals, I believe, right? 
A. Yes. 
Q. Especially the horses? 
A. Yeah, they are horse lovers. 
Q. And sometimes Ghislaine would take them riding on the 
horses at the ranch; isn't that right? 
A. Yes, my daughters did ride at the ranch on the horses, yes. 
Q. They did that a fair amount? 
A. Yes. 
Q. And you trusted Ghislaine enough that you felt comfortable 
letting your two young daughters spent time with her; isn't 
that right? 
A. That is correct. 
Q. If you had any inkling whatsoever that Ghislaine was 
involved in helping Epstein sexually abuse young girls, you 
wouldn't have let that happen, would you? 
A. Absolutely not. 
Q. And if you had any inkling whatsoever that Ghislaine or 
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Epstein were involved in inappropriate sexual activity with 
underage girls, what would you have done? 
A. They would have never seen my daughters. 
Q. And you would have quit your job? 
A. Reported it, yes. 
Q. And you would have quit your job? 
A. I would have quit my job, that's correct. 
Q. But you didn't do that, did you? 
A. No, I didn't. 
Q. Because nothing you saw or heard in the roughly 30 years 
you worked for Epstein ever gave you even the slightest hint 
that anything like that was going on? 
A. This is absolutely correct. 
MR. EVERDELL: One moment, your Honor. 
THE COURT: Okay. 
(Counsel conferred) 
MR. EVERDELL: Nothing further, your Honor. 
THE COURT: All right. Thank you. 
Ms. Comey. 
MS. COMEY: Thank you, your Honor. 
THE COURT: You may redirect. 
REDIRECT EXAMINATION 
BY MS. COMEY: 
Q. Good afternoon. 
A. Good afternoon, Ms. Comey. 
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Q. Do you recall being asked questions about your daughters on 
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cross-examination, Mr. 
A. Yes, I do. 
Q. When your daughters were 14 years old, did you let them 
give Mr. Epstein a massage? 
A. No, I didn't. 
Q. Do you recall being asked about 
and another person who 
has the same first name as 
A. Yes. 
Q. Who did you meet first, 
or the person who is 
identified in Defense Exhibits LV3A and LV3B? 
A. The only way to kind of refresh my memory, Ms. Comey, to 
narrow down that, I could only -- like when I -- when I 
explained that I first met 
it was in between the two 
pilot seats. So I know that was one of Mr. Epstein's smaller 
aircraft; it wasn't the Boeing. 
So visually, I can picture the second 
You have 
to help me out which one it was. Not the one 
not the first 
, but the other 
I could visualize in the Boeing which 
would have been sometime 2000 and later. 
Q. So to the best of your recollection, did you meet the 
person we're calling 
in the 1990s? 
A. I would go with that one, yes, only because with that 
document of the airplane with, you know, that time frame, I 
remember the other 
was in the Boeing, the bigger plane. 
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Q. I just want to make this clear because I know we're dealing 
with some pseudonym issues, so just listen to the question 
please. 
A. Okay. 
Q. The person we're calling 
A. Yes. 
Q. -- did you meet her in the 1990s, to the best of your 
recollection? 
A. Yes. 
Q. And the person who is depicted in Defense Exhibits LV3A and 
LV3B, did you meet her in the 2000s, to the best of your 
recollection? 
A. Yes. To the best of my recollection, that's a perfect 
example of how I could remember; so that is correct, yes, 
Ms. Comey. 
Q. And do you have that memory because the person depicted in 
Defense Exhibits LV3A and 3B you remember on the Boeing? 
A. That's correct. That was my synopsis. 
THE COURT: Sorry. Just a moment. 
MR. EVERDELL: Objection. Leading. 
THE COURT: Overruled. 
You may finish. You may finish your answer. 
THE WITNESS: Oh, I'm sorry. 
A. That is correct, Ms. Comey. It was a way of correlating a 
name to a date or a person to a date. 
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Q. Do you remember being asked on cross-examination about how 
old you thought 
may have been? 
A. I remember that question, yes. 
Q. Did you ever meet 
at summer camp when she was a 
camper? 
A. I did not, no. 
Q. Did you ever pick 
up at high school? 
A. No, I did not, ma'am. 
Q. Did you ever talk with 
about camp? 
A. No, I did not. 
Q. Did you ever talk with 
about high school? 
A. No, ma'am. 
Q. Did you ever meet 
mother? 
A. No, I did not. 
Q. Did you meet 
other family members? 
A. I did not. 
Q. And finally, Mr. 
do you recall being asked about a 
Cobra vehicle? 
A. Yes, ma'am. 
Q. Do you remember exactly when Mr. Epstein gave you that 
vehicle? 
A. Also to clarify, it's a replica Cobra. Probably in the 
2000s, 2000; it's been around 20 years since I've had it. I 
would say 2000, give or take. I don't have an exact date. 
Q. As you sit here today, do you remember the exact date or is 
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that an approximation? 
A. It's just an approximation. I do not know the exact date. 
MS. COMEY: May I have a moment, your Honor? 
THE COURT: You may. 
(Counsel conferred) 
MS. COMEY: Nothing further. 
THE COURT: Okay. 
MR. EVERDELL: Nothing from the defense. 
THE COURT: All right. Thank you, Mr. 
You may step down. You are excused. 
THE WITNESS: Thank you very much, your Honor. 
THE COURT: Thank you. 
(Witness excused) 
THE COURT: Do you have a matter to take up? 
MR. EVERDELL: Yes, your Honor. You may want to 
collect the binders and folders before the next witness or at 
least the defense folders. 
THE COURT: Okay. Or we leave them there? 
MR. EVERDELL: There may be another -- it's fine, your 
Honor. 
THE COURT: Okay. Jurors, you know this, but don't 
look at anything unless I direct you to, please. And there may 
be instances in which I direct you to, but wait for that 
direction. 
Ms. Comey, the government may call its next witness. 
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MS. MOE: Thank you, your Honor. 
The government calls 
THE COURT: The witness testifying under the pseudonym 
may come forward. 
called as a witness by the Government, 
having been duly sworn, testified as follows: 
THE COURT: Please be seated. 
This witness will be testifying under the pseudonym 
Ms. Moe, you may proceed. 
MS. MOE: Thank you, your Honor. 
And with respect to the Court's order regarding sketch 
artists, is that now in effect? 
THE COURT: It is in effect. I've asked the sketch 
artist not to sketch the exact likeness -- ordered the sketch 
artist not to depict the exact likeness. 
And I will ask the witness to please remove your mask. 
You are in the Plexiglas box with the HEPA filter. Thank you. 
MS. MOE: Thank you, your Honor. 
DIRECT EXAMINATION 
BY MS. MOE: 
Q. Good afternoon. 
A. Good afternoon. 
Q. Just to be clear, are you testifying under the name 
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today? 
A. Yes. 
Q. Leading up to this trial, did you ask to testify under a 
pseudonym to protect your privacy? 
A. Yes. 
Q. I'd ask you to please take a look in the binder in front of 
you on the witness stand. If you could please turn to what's 
marked for identification as Government Exhibit 12. Just let 
me know when you are there please. 
A. Here. 
Q. Do you recognize that? 
A. Yes, I do. 
THE COURT: I just want to make sure that defense has 
what they need. 
MS. MENNINGER: I do. Thank you. 
THE COURT: Okay. Thank you. Go ahead. 
Q. What is Government Exhibit 12? 
A. My birth certificate. 
MS. MOE: At this time, your Honor, Government Exhibit 
12 is in evidence under seal. I'd ask the jurors be permitted 
to remove their juror binders and turn to Tab 12. 
THE COURT: Without objection, Ms. Menninger? 
MS. MENNINGER: No objection. 
THE COURT: Okay. Jurors, you may open the binder and 
look at what's been admitted as GX-12, please. 
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MS. MOE: Thank you, your Honor. 
BY MS. MOE: 
Q. Directing your attention to the top left corner of 
Government Exhibit 12, where it says "child's name." Do you 
see that? 
A. Yes. 
Q. Without saying that out loud, is that your true name? 
A. Yes. 
Q. Is that your date of birth? 
A. Yes, it is. 
Q. Thank you. You can close the binder. 
Now, 
I want to ask you, did there come a time in 
your life when you met someone named Jeffrey Epstein? 
A. Yes. 
Q. What year was that? 
A. 1994. 
Q. Did there come a time in your life when you had sexual 
contact with Jeffrey Epstein? 
A. Yes. 
Q. How old were you when that first happened? 
A. Fourteen years old. 
Q. Did that happen once or more than once when you were 14 
years old? 
A. More than once. 
Q. Was there ever anyone else in the room with you when you 
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had sexual contact with Jeffrey Epstein when you were 14 years 
old? 
A. Yes. 
Q. Who was most frequently in the room when you had sexual 
contact with Jeffrey Epstein when you were 14 years old? 
A. Ghislaine Maxwell. 
Q. I'd like to ask you to take a moment to look around the 
courtroom, and you can stand up if you need to if you can't 
see. Do you see Ghislaine Maxwell in the courtroom today? 
A. Yes. 
Q. Can you please point to where she's sitting and indicate an 
article of clothing that she's wearing. 
A. Right there in the corner wearing a 
sort of a beige 
turtleneck. 
MS. MOE: Your Honor, may the record reflect that the 
witness has identified the defendant? 
THE COURT: It may so reflect. 
Q. Now, I want to ask you more about that in a few moments, 
but first I want to take a step back. 
Directing your attention to 1993, where were you 
living that year? 
A. Palm Beach, Florida. 
Q. How old were you in 1993? 
A. Twelve, going on 13. 
Q. I'd ask you to take a look at the binder in front of you. 
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If you could please turn to what's been marked for 
identification only as Government Exhibit 106. 
Do you recognize that? 
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A. Yes. 
Q. What is Government Exhibit 106? 
A. That is a picture of myself. 
Q. Approximately how old were you when that photograph was 
taken? 
A. Thirteen years old. 
MS. MOE: Your Honor, the government offers Government 
Exhibit 106 under seal. 
MS. MENNINGER: No objection. 
THE COURT: Government Exhibit 106 is admitted under 
seal, consistent with my ruling, to protect the anonymity of 
this testifying witness. 
(Government's Exhibit 106 received in evidence) 
MS. MOE: Thank you, your Honor. 
May the jurors turn to Government Exhibit 106, please. 
THE COURT: Jurors, you may pick up the binder and 
please turn to GX-106. 
BY MS. MOE: 
Q. Who was living with you in your household in 1993 when you 
were approximately 13 years old? 
A. My mother and two of my brothers. 
Q. What type of work did your father do? 
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A. He was a conductor and composer. 
Q. Directing your attention to the fall of 1993, what happened 
in your family at that time? 
A. My father died of leukemia. 
Q. What was your home life like after your father passed away? 
A. It was not great. My father's employer had canceled his 
health insurance without him knowing, and ended up in the 
hospital and died very suddenly. And basically, my family went 
into complete bankruptcy and lost everything, and we had to 
move out of our home. 
Q. You testified that before he passed away, your father was a 
composer. Were you involved in the arts growing up? 
A. Yes. 
Q. Were your brothers involved in the arts? 
A. Yes. 
Q. Did you continue being involved in the arts after your 
father passed away? 
A. Yes. 
Q. Directing your attention to the summer of 1994, what did 
you do that summer? 
A. Me and my two brothers, we went to camp for the first time, 
Interlochen Arts Camp. 
Q. What is Interlochen Arts Camp? 
A. It's a camp for children with all kinds of artistic 
abilities: Music, musical theater, theater, orchestra. 
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Basically, what we used to joke about being band camp. 
Q. And where is that located? 
A. In Interlochen, Michigan, which is northern Michigan. 
Q. Did anyone else go to camp with you that summer? 
A. My two brothers. 
Q. Given your family's financial circumstances at the time, 
how were you and your brothers able to attend summer camp? 
A. That first summer, my oldest sister and her husband and her 
husband's family all pitched in to send us to camp. 
Q. What grade in school had you just finished when you started 
at summer camp that year? 
A. Seventh grade. 
Q. And when you arrived at camp that summer, how long had it 
been since your father passed away? 
A. So the end of October '93, so what is that, nine months? 
Q. Did there come a time that summer at Interlochen Arts Camp 
when you met a man and a woman? 
A. Yes. 
Q. Where were you when that happened? 
A. I was in the main campus area where all the students hung 
out during a break and where all the little cafes were and sort 
of the gift shop. And I was on a park bench or a picnic bench 
with my friends from camp. And we were eating ice cream. 
Q. What do you remember happening next? 
A. Well, we were sitting around and socializing. And we see 
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this tall thin woman approach us. Well, she was walking with a 
cute little Yorkie. And the Yorkie came by us and we asked if 
we could pet the dog. 
Q. What happened then? 
A. We started chitchatting, petted the dog. And the rest of 
my classmates had to go to class. And probably about a minute 
later, another man came and joined her. 
Q. Once the man joined her, what happened next? 
A. We continued chitchat, sort of talked to us. And the rest 
of my friends, my classmates, left, and I was there by myself. 
And I sat on the bench still eating my ice cream, and the man 
sat across from me. 
Q. Did you have a conversation with that man and that woman? 
A. Yes, I did. He seemed very interested to know what I 
thought about the camp, what my favorite classes were, what my 
least favorite classes, teachers, whatnot, what the experience 
was like. And proceeded to say that they were big benefactors 
of this camp; and that they went there every summer; and that 
they gave different kids scholarships. And so they wanted to 
really know what a student attending the camp, what their 
perspective was on it. 
Q. What, if anything, else did you discuss with them? 
A. Well, they asked me where I was from. And I said I lived 
in Palm Beach, Florida. And the man said, What a coincidence, 
we live there too. What are your parents' names? 
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And I said, Well, my father just passed away. But my 
mother's name is. 
And he said, I think we know your mom. It's kind of a 
smaller town. We definitely know her. 
And I said, You know, my parents were sort of out on 
the scene, and my father was a musician, and so that would make 
sense. 
And he had a newspaper under his arm. And then he put 
the newspaper on the picnic table and said, Well, what's your 
mom's name? 
Gave my mom's name. 
And he said, Well, what's her phone number? 
And I just kind of went, Okay. He's asking me for a 
number, so I gave it to him. And so I gave my mom's, which, 
you know, at the time was just a landline. 
Q. How did that conversation end? 
A. It just sort of ended like, It was, you know, so nice to 
meet you and I'm going to call your mom. That was it. 
Q. That man and that woman that you had this conversation 
with, who were they? 
A. Jeffrey Epstein and Ghislaine Maxwell. 
Q. What was your impression of them at that point? 
A. They seemed very friendly. I thought they were a married 
couple. They seemed inquisitive. And it made sense, I guess, 
if they spent time there, that they wanted to know what the 
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what the classes were like and what the campus was like. 
Q. Did you return home to Palm Beach when summer camp was 
over? 
A. Yes. 
Q. Where were you living at that point? 
A. We were living in a pool house in one of my parents' 
friend's backyards. 
Q. Why were you living in a pool house? 
THE COURT: I'm sorry, Ms. Moe, can you come a little 
closer to the mic? 
MS. MOE: Thank you, your Honor. 
Q. Why were you living in a pool house at the time? 
A. Because we lost our house and we were homeless. 
Q. When you were staying there, did you have your own bedroom? 
A. No. 
Q. Where did you sleep? 
A. I slept in a bed with my mom. 
Q. After you returned home from summer camp in 1994, did you 
ever hear from those two people that you met at camp? 
A. Yes. 
Q. When was the first time you heard from them? 
A. Well, it was a few days after I had started school again. 
Q. What grade were you in at that point? 
A. Eighth grade. 
Q. What school were you attending? 
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A. 
Q. Is that a middle school or a high school? 
A. Middle school. 
Q. So what happened when you heard from them? What do you 
remember about that? 
A. I just remember coming home from school one day, and my mom 
said, Someone you met at summer camp, someone from their office 
called me. 
And I said, Oh, well, I don't -- oh, that's right. 
I -- I barely remember, because it seemed so long ago. It was 
maybe four or five or six weeks, but, you know, being that 
young, it seemed like an eternity. And I said, Yeah, I met 
and they said that they know you. 
And my mom said, Well, we've been invited to his house 
for some tea some afternoon. 
Q. Did you end up going to his house for tea? 
A. Yes. 
Q. What do you recall about going over to the house for tea? 
A. He sent somebody to come pick us up, like a chauffeur. And 
we were driven to his house. 
Q. What was your impression of the house when you first 
arrived? 
A. Well, it was enormous. It was not a pool house in the back 
of someone's yard. It was this giant, like, beach-looking 
house with a big white fence around it. And these giant gates 
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opened up, and the car pulled in. And it was just this, you 
know, big beautiful house. 
Q. Who, if anyone, went with you when you went over for this 
tea? 
A. My mother. 
Q. What happened after you and your mother arrived at the 
house? 
A. Well, somebody opened the door for us and let us in the 
house and escorted us through the house and to Jeffrey's 
office, which was sort of like an open space. 
Q. And after you got to the office, what happened next? 
A. He was on the phone. He got off the phone, stood up, and 
introduced himself to me and my mother, and then sort of let us 
outside to the back patio, which had this great big dining 
table. And there was a big spread of, like, pastries and 
sandwiches and tea. 
Q. What happened during the tea with you and your mother and 
Jeffrey Epstein? 
A. Well, he was very inquisitive and asked me questions about 
what I was doing in school, what my interests were, what I 
wanted to do with my life, and was asking us about our family, 
asking my mother. It didn't last very long, I would say maybe 
30 minutes in total. 
But he proceeded to say, Well, I like to mentor young 
students who are artists. And I love music, and I love dance, 
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and I gave all kinds of scholarships. 
Q. How did that tea end? 
A. It ended with him saying, Well, I am 
I'm very impressed 
with your daughter and, you know, would love to see her sing 
next time. 
Q. After the day that you had this tea, did you ever see 
Jeffrey Epstein again? 
A. Yes. 
Q. In the months after that tea, how frequently did you begin 
seeing Jeffrey Epstein? 
A. On average, once or 
once every week or two. 
Q. We've been talking about a time period when you were 14 and 
living in Palm Beach. How old were you when you moved away 
from Palm Beach? 
A. When I moved away? 17. 
Q. I want to focus now first on the first few months that you 
spent time with Jeffrey Epstein when you were 14. During those 
first few months, when you spent time with Jeffrey Epstein in 
Palm Beach, who was typically there with you? 
A. At Jeffrey's house? 
Q. Yes. 
A. I was there by myself. 
Q. And when you would spend time with Jeffrey Epstein at his 
house in those first few months, who, if anyone, was there? 
A. Ghislaine Maxwell. 
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Q. What was your understanding at the time of what the 
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relationship was between Ghislaine Maxwell and Jeffrey Epstein? 
A. I didn't really understand. They never really shared that 
information. I just assumed that they were married. And then 
at a certain point I thought maybe they're best friends. And 
then I thought, Well, maybe she works for him because he would 
ask her to do things, make phone calls and things for him. So 
I guess I was just confused. 
Q. When you would see Epstein or Maxwell, how were those 
meetings typically arranged? 
A. It would be Ghislaine calling the house or Jeffrey's office 
calling the house, like an assistant or something. 
Q. Now, you mentioned earlier that you would go to these 
meetings alone. Just to be clear, did your mother go with you 
for these meetings? 
A. No. 
Q. Why not? 
A. She wasn't invited. 
Q. How would you typically get over to the house? 
A. Jeffrey would send his chauffeur for me. 
Q. Did you have your driver's license at the time? 
A. No. 
Q. Do you recall the driver who would pick you up? 
A. Yes. I don't remember his name, but he was a sweet 
Latin-American man. And I know his wife worked at the house as 
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