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Q. Did ever recall picking up from her
2 house?
3 A. Yes.
4 Q. And when he would pick her up from her house,
5 would he then bring her back to the Palm Beach house:
6 A. Yes.
7 Q. Did he remember who in general would tell him to
8 pick up from her house?
9 A. Maxwell would be the one to tell him to pick her
10 up.
11 Q. Did he recall ever driving to the movies?
12 A. Yes.
13 Q. What did he tell you about that?
14 A. That it would usually be Epstein, Maxwell, anc
15 They'd go to the movies and it would usually be late
16 at night.
17 Q. Did he tell you about what his memory was about
18 how old was?
19 A. He said she was young and that he knew that
20 because he had picked her up from school and that he knew
21 she was too young to drive.
22 Q. Switching gears. I want to talk to you about a
23 different aspect of your interviews with Based
24 on what he told you about his job duties, were there ever
25 times when he would have to clean Epstein's massage room?
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A. Yes.
2 Q. What did he tell you about that?
3 A. He said that he found sex toys in the massage room
4 and he had to wash them afterwards.
5 Q. Aside from those experiences, was he aware of
6 there being sex toys in the house?
7 A. Yes. There was a basket of sex toys that were
8 kept in Maxwell's closet.
9 Q. Did stop working for Epstein in
10 approximately 2002?
11 A. Yes.
12 Q. Was he told that he was being replaced?
13 A. Yes.
14 Q. And was he generally aware that the person who
15 replaced him was much younger?
16 A. Yes.
17 Q. Did tell you that a few months after he
18 left working for Epstein he became suicidal because of
19 issues in his marriage?
20 A. Yes.
21 Q. Did he tell you that he went to Epstein's house
22 and tried to take Epstein's gun?
23 A. Yes, he did.
24 Q. Did he tell you he took several thousand dollars?
25 A. Yes.
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Q. Did Epstein discover this and confront him about
2 it?
3 A. Yes, he did.
4 Q. Did admit to Epstein and the police what
he'd done?
6 A. Yes.
7 Q. Did Epstein also tell the police his gun was
8 missing?
9 A. Yes.
10 Q. Were there any charges filed?
11 A. No.
12 Q. Was he ever arrested?
13 A. I don't believe so.
14 Q. And did Epstein pursue any charges about this
15 incident?
16 A. No, he didn't pursue anything.
17 Q. Have you interviewed one of Epstein's former
18 pilots?
19 A. Yes.
20 Q. Is that pilot named
21 A. Yes.
22 Q. Was he one of the pilots for Epstein's private jet
23 in the 1990's?
24 A. Yes.
25 Q. Did he remember traveling on the je
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in the 90's?
2 A. He remembered her traveling, but he didn't
3 remember specifics.
4 Q. So just to be clear, is your testimony that he
5 didn't remember the specific dates of the flights, but he
6 remembered her traveling on the jet during the 1990's?
7 A. Yes.
8 Q. And did he remember specifically as
9 a person who traveled?
10 A. Yes.
11 Q. Did you discuss with him the flight records that
12 we talked about earlier that lists a person named as
13 passenger?
14 A. Yes.
15 Q. Did he have a specific memory of those exact
16 flights?
17 A. No.
18 Q. But was he aware of any other flying on the
19 jet besides in the 1990's?
20 A. No, no other at that time.
21 Q. Earlier when we were looking at Interlochen
22 attendance records for the summer of 1994, you noted tha
23 • was one of the names on that record. Is that
24 right?
25 A. Yes.
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Q. Is that
2 A. Yes.
3 Q. Have you interviewed
4 A. Yes, I have.
5 Q. Did he tell you that he remembered talking
6 that summer at camp about having met Jeffrey Epstein?
7 A. Yes.
8 Q. Did he tell you that he remembered going
9 over to Epstein's house in Palm Beach when they were in high
10 school?
11 A. Yes.
12 Q. Did he remember that would often talk about
13 spending time with Maxwell and Epstein during this time?
14 A. Yes.
15 Q. Did he remember telling him when they were
16 in high school about at least one trip to New York City that
17 she took with Epstein?
18 A. Yes.
19 Q. Did he remember describing Epstein's
20 townhouse in Manhattan?
21 A. Yes.
22 Q. And does he remember talking often about
23 Ghislaine Maxwell?
24 A. Yes.
25 Q. Now, based on your interviews with did he
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tell you whether he knew back then when they were in high
2 school whether was being sexually abused by Epstein?
3 A. He didn't know back then.
4 Q. Did III ever meet Ghislaine Maxwell?
5 A. Yes, he did.
6 Q. What did he remember about that?
7 A. He remembered Epstein, Maxwell, and being
8 near a movie theatre and he was approximately 16 at the time
9 and would've been 15, and just the little bit of
10 interaction they had. And then after that, had told
11 him that Maxwell had said something to the effect I could
12 teach a thing or two.
13 Q. Is that something that he remembers telling
14 him back then that Maxwell had said?
15 A. Yes.
16 Q. During the course of this investigation, have you
17 participated with interviews with an individual named
18
19 A. Yes.
20 Q. So for today's purposes I'm just going to refer to
21 her as How many times have you interviewed
22 A. Approximately twice.
23 Q. Now, does know Have they
24 ever met as far as you know?
25 A. As far as I know, no.
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Q. Turning to the next slide. Are these photographs
2 of when she was in high school?
3 A. Yes.
4 Q. And is her date of birth
5 A. Yes.
6 Q. When was approximately 16 and a junior in
7 high school, where was she living?
8 A. She was living in Arizona with her mother.
9 Q. Does she have any siblings?
10 A. An older sister.
11 Q. What did her older sister do?
12 A. Her older sister lived -- worked for Epstein.
13 Q. Where did she work for Epstein?
14 A. Here in New York.
15 Q. Did there come a time in approximately December
16 1995 when had a phone conversation with her sister
17 about traveling to New York City?
18 A. Yes.
19 Q. What did they discuss?
20 A. They discussed her coming to New York and meetinc
21 Epstein.
22 Q. What did her sister tell about why she
23 should meet Epstein?
24 A. She said that he could help her with college.
25 Q. And did she say -- did the sister say whether the
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sister wanted her to meet Epstein or did she say whether
2 Epstein wanted to meet
3 A. Epstein wanted to meet
4 Q. Now, let me just pause here. You testified that
5 this happened in approximately December of 1995. Just for
6 context, the years that we were talking about with
7 was that 1994 through 1997?
8 A. Yes.
9 4. So is this approximately the same time period
10 while what you described telling you happened?
11 A. Yes.
12 Q. So in January of 1996, did fly on a
13 commercial airline to New York City to spend a weekend with
14 her sister and meet Jeffrey Epstein?
15 A. Yes.
16 Q. Did she tell you that?
17 A. Yes.
18 Q. During the trip, did tell you that she met
19 Epstein at his townhouse in New York City?
20 A. Yes, she did.
21 Q. Did she tell you that Epstein discussed her plan.,,
22 for college applications and offered to help her?
23 A. Yes.
24 Q. What was first impression of
25 Jeffrey Epstein?
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A. She was very impressed by him.
2 Q. What did she -- what was her impression based on
3 this conversation of what Epstein was going to do for her?
4 A. That he was going to help her with her future
5 plans for college.
6 Q• During that trip to New York City, did she stay at
7 Epstein's townhouse or at her sister's apartment?
8 A. Her sister's apartment.
9 Q. During that trip, did she tell you that she saw
10 Epstein a second time when he took and her sister to
11 the movies?
12 A. Yes.
13 Q. What did she tell you happened at the movies?
14 A. She said that they were sitting in the theatre and
15 Epstein was between and her sister, and Epstein put
16 his hand on her leg, he rubbed her arm and held hands with
17 her.
18 Q. From what she told you what was her impression
19 about whether her sister could see what was going on?
20 A. She felt like her sister couldn't see.
21 Q. What was her reaction to this happening?
22 A. She was uncomfortable.
23 Q. After the movie did she tell her sister what had
24 happened?
25 A. No, she didn't.
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Q. Did she say why not?
2 A. She said that she knew -- her sister really
3 liked Epstein and that Epstein could help them, so she
4 didn't tell her.
Q. After this trip did go back home to
6 A. Yes.
7 Q. Did Epstein contact her afterwards?
8 A. Yes.
9 Q. Did he discuss with her her ongoing college plans?
10 A. Yes, he did.
11 Q. Did he invite her to a weekend at his ranch in New
12 Mexico in the spring of 1996?
13 A. Yes.
14 Q. Was she 16 at the time?
15 A. Yes, she was.
16 Q. From what she told you, what was
17 impression of who would be on this trip to New Mexico?
18 A. She knew Maxwell would be there.
19 Q. Did she -- was she told anyone else was going to
20 be present during this trip?
21 A. She said that there would be, like, other students
22 her -- kids her age.
23 Q. And what was her understanding of who these other
24 kids were and why they'd be there? Sorry, let me
25 A. Rephrase.
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Q. -- rephrase the questions. You testified that she
2 was told that on this trip that there would be other
3 students. Was she under the impression that there would be
4 other young students like her on the trip who were also
5 being mentored by Epstein?
6 A. Yes.
7 Q. Now, you testified just a moment ago that she was
8 also told that Maxwell would be there. Are you referring to
9 Ghislaine Maxwell?
10 A. Yes.
11 Q. At the point that she was told that
12 Ghislaine Maxwell would be on this trip, had she ever met
13 Ghislaine Maxwell?
14 A. No, she hadn't.
15 Q• Had she heard her sister talk about
16 Ghislaine Maxwell?
17 A. Yes.
18 Q. How did -- from what she described to you, how did
19 her expectation that Maxwell would be on this trip make her
20 feel about the trip?
21 A. It made her comfortable. Her sister had talked
22 highly of Maxwell.
23 Q. Did tell you that she flew to New Mexico
24 that spring when she was 16?
25 A. Yes.
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Q. Did she meet Ghislaine Maxwell when she arrived in
2 New Mexico?
3 A. Yes, she did.
4 Q. How did she describe Maxwell's demeanor and
5 attitude when she met her?
6 A. She described Maxwell as being very charming. She
7 gave her a tour of the house and Maxwell took
8 shopping, which made her feel special.
9 Q. What does she remember talking about with
10 Ghislaine Maxwell?
11 A. They talked about school, homework, trips.
12 Q. Did she talk with her about applying to college?
13 A. Yes.
14 Q. Did she talk about her classes in high school?
15 A. Yes.
16 Q. Did she talk with her about the homework that she
17 had to do that weekend?
18 A. Yes.
19 Q. Did she talk with Maxwell about her family?
20 A. Yes.
21 Q. Did she talk with her about her home life and
22 living with her mother?
23 A. Yes.
24 Q. From what told you, when she got there who
25 else was at the ranch besides Ghislaine Maxwell and
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1 Jeffrey Epstein?
2 A. It was just them.
3 4. Was it just the three of them the entire weekend
4 of the visit?
5 A. Yes.
6 Q. Were there any other school kids there?
7 A. No.
8 Q. When they were at the ranch, from what told
9 you, did Maxwell say anything to about massages?
10 A. Yes.
11 Q. Did she say anything to her about foot massages?
12 A. Yes.
13 Q. What did tell you about that?
14 A. Maxwell told to give Epstein a foot massage,
15 and then she showed her and instructed her how to do it.
16 was a little uncomfortable, but Maxwell was joking
17 around so she just followed her lead.
18 Q. Did tell you what Maxwell and Epstein took
19 her to the movies that weekend?
20 A. Yes.
21 Q. What did she tell you about that trip to t
22 movies?
23 A. She said that when they went outside the theatre
24 Maxwell was joking around and pulled Epstein's pants down a
25 little bit. And then once they went inside the theatre,
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1 Epstein -- when they were sitting down, Epstein touched
2 leg, he rubbed her arm, held her hand. And this
3 time he -- felt that he wasn't trying to hide it from
4 Maxwell.
5 Q. What was reaction to all of this?
6 A. She was uncomfortable.
7 Q. During the same weekend, was there another
8 occasion when Maxwell talked about massages?
9 A. Yes.
10 Q. What happened?
11 A. Maxwell had asked if she ever had a massage,
12 and Maxwell told her she could give her one. So was
13 on her back and Maxwell had pulled the sheet down exposing
14 her chest, she was nude from the top up, and proceeded to
15 massage around her chest and breast area.
16 Q. From what told you when she was describing
17 to you what you just described to the grand jury, how did
18 she feel while this was happening?
19 A. She felt really uncomfortable.
20 Q. Did also tell you about an incident that
21 happened one morning when she was in New Mexico?
22 A. Yes.
23 Q. What did she tell you happened?
24 A. She said she was in bed and Epstein came into the
25 room and told her that he wanted to cuddle. So he laid down
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next to her and spooned her. She told him she had to go tc
2 the bathroom to get out of the situation.
3 Q• What was her reaction to that when Epstein got
4 into her bed?
5 A. She was uncomfortable. She didn't know what to
6 do.
7 Q. Did go back home to when the weekend
8 was over?
9 A. Yes, she did.
10 Q. Did she tell anyone when she got home about what
11 happened?
12 A. No.
13 Q. Is that for the same reason you described earlier?
14 A. Yes.
15 Q. Did Epstein end up paying for to go on a
16 trip to Thailand that summer?
17 A. Yes.
18 Q. Did have any contact with Maxwell or Epstein
19 after that trip?
20 A. Not that she recalled.
21 Q. When you interviewed what was her demeanor
22 like when she described her interactions with
23 Jeffrey Epstein and Ghislaine Maxwell?
24 A. She became upset, emotional.
25 Q. Is currently pursuing a civil lawsuit
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against Maxwell and Epstein's estate?
2 A. Yes, she is.
3 Q. What does do for a living now?
4 A. She's a psychologist who works with trauma
5 victims.
6 Q. During the course of this investigation, have you
7 interviewed someone named
8 A. Yes.
9 Q. For today's purposes, I'm just going to refer to
10 her as How many times have you interviewed
11 approximately?
12 A. Approximately three times.
13 Q. Turning to the next slide. Is this a photograph
14 of that she provided to you?
15 A. Yes.
16 Q. And did she tell you that this was taken when she
17 was in -- approximately 16 or 17 years old?
18 A. Yes.
19 Q. Is date of birth
20 A. Yes.
21 Q. Did grow up in England?
22 A. Yes, she did.
23 Q. Did she tell you that there came a point when she
24 met Ghislaine Maxwell when she was about 17?
25 A. Yes.
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Q. How did she tell you that they met?
2 A. She said they met through a mutual friend.
3 Q. Did she tell you that this would've happened in 4
around 1994 or 1995?
5 A. Yes.
6 Q. And is that within the same time period that we've
7 been talking about today?
8 A. Yes.
9 Q. What happened after she was introduced to
10 Ghislaine Maxwell from what she told you?
11 A. She said Maxwell treated her like they were
12 sisters. Her quote was, "like naughty school girls" is how
13 Maxwell treated with -- her.
14 Q. Did she tell you that Maxwell seemed to
15 immediately take an interest in her?
16 A. Yes.
17 Q. Did she tell you that they began spending time
18 together in London?
19 A. Yes.
20 Q. And just to be clear, was Maxwell in her 30's
21 while this was happening?
22 A. Yes.
23 Q. Did Maxwell -- did ever remember Maxwell
24 ever talk about having a boyfriend named Jeffrey Epstein?
25 A. Yes.
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Q. What did she tell about that?
2 A. Maxwell told that Epstein was going to
3 like her.
4 Q. Did there come a time when she was 17 that
described that Maxwell introduced her to Jeffrey Epstein?
6 A. Yes.
7 Q. How did she describe that occurring?
8 A. Epstein had flown to London. He was at Maxwell's
9 residence in London and Maxwell had called over. So
10 went over and when she got there, Maxwell was saying
11 to Epstein kind of -- the words used was giving him
12 a resume of her attributes. Saying she's so pretty, she's
13 so strong, and then Maxwell asked her to give Epstein a
14 massage.
15 Q. Now, you testified just a moment ago that Maxwell
16 -- that described to you that Maxwell asked her to
17 give Epstein a massage during this first meeting. Is that
18 correct?
19 A. Yes.
20 Q. Did Maxwell say to her in sum and substance since
21 you're so strong I'd appreciate it if you give Jeffrey a
22 massage because he needs a massage every day or I get in
23 trouble?
24 A. Yes, she said that.
25 Q. Is that what said to you in sum and
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substance?
2 A. Yes.
3 Q. When that happened, did remember Maxwell
4 leading her to a room in the house?
5 A. Yes.
6 Q• What happened?
7 A. When went in the room, Epstein was in a
8 robe. He took his robe off and she started massaging him,
9 and then he touched and pulled her hand to his
10 penis.
11 Q. What does remember Epstein saying when he
12 did this?
13 A. Don't be frigid.
14 Q. What was her reaction to this happening from what
15 she told you?
16 A. She was taken back by it.
17 Q. When this episode ended and left the room
18 did she tell you that she remembered Maxwell being just
19 outside the room when she left?
20 A. Yes.
21 4• Did she remember Maxwell saying to her, did you
22 have fun? Did he like it?
23 A. Yes.
24 Q. Does she remember Maxwell calling her several days
25 afterwards or at some short period of time afterwards?
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A. Yes, she did.
2 Q. Did remember Maxwell saying to her on the
3 phone call in sum and substance, well, aren't you a clever
4 girl, Jeffrey was very impressed?
5 A. Yes.
6 Q. Shortly after this incident, does she remember
7 Maxwell asking her to come back over to the house?
8 A. Yes.
9 Q. And when she got there did she tell you she
10 remembered Maxwell saying to her, in substance, thank God
11 you're here; if it's not you or someone it falls to me?
12 A. Yes.
13 4• Does she remember Maxwell bringing her up the
14 stairs to the house on that occasion?
15 A. Yes, she did.
16 Q. What does she remember happening when Maxwell
17 opened the door to the room?
18 A. Epstein was standing there nude.
19 4• Does she remember Maxwell then saying I'll leave
20 you guys to it?
21 A. Yes.
22 Q. After these first two encounters, did Epstein and
23 Maxwell invite to travel with them to Palm
24 Beach, U.S. Virgin Islands, Paris, and New York for the next
25 several years?
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