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A. Yes, they did.
2 Q. Does she remember whether these trips began before
3 or after her 18th birthday?
4 A. She couldn't remember specifically.
5 Q. Before these trips started, you were describing
6 earlier when told you about the time that she spent
7 with Maxwell when they first met when she was 17. Is that
8 right?
9 A. Yes.
10 Q. During these conversations when she would spend
11 time with Maxwell, did remember talking with her
12 about her life and her family, and her personal
13 circumstances with Maxwell?
14 A. Yes.
15 Q. Now, you testified a moment ago that told
16 you that at some point she began traveling with Maxwell and
17 Epstein, and she wasn't sure whether or not whether these
18 trips started before she turned 18. Is that right?
19 A. Yes.
20 Q. Did describe to you that Epstein sexually
21 abused her during these trips, typically in the context of a
22 sexualized massage?
23 A. Yes, he did.
24 Q. Did Epstein give her money?
25 A. Yes.
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Q. Did she tell you that he would give her cash?
2 A. Yes.
3 Q. Did she describe to you that the abuse included,
4 among other things, Epstein groping her and using a massager
5 device on her genitals?
6 A. Yes.
7 Q. And was the massager device like a vibrator?
8 A. Yes, it was.
9 Q. From what told you, was Maxwell in the
10 room during these encounters?
11 A. Maxwell wasn't in the room.
12 Q. What did she tell you would typically happen when
13 left the room after these episodes; was Maxwell
14 typically nearby?
15 A. Yes. She was usually right near the room.
16 Q. Does she remember Maxwell asking her, after she'd
17 leave the room from one of these sessions, 'how was it, is
18 he happy?'
19 A. Yes.
20 Q. Did she also tell you that she remembers Maxwell
21 telling her at some point, in sum and substance, 'you know
22 how he is when he's not happy and you know what makes him
23 happy, he has to have sex all the time, he's like a super
24 hero?'
25 A. Yes, she said that.
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Q. Did tell you about an incident that
2 occurred after she turned 18 in Palm Beach when she was
3 staying at the Palm Beach house?
4 A. Yes.
5 Q. Did the incident she described to you involve a
6 school-girl outfit?
7 A. Yes, it did.
8 Q. Could you please describe for the grand jury what
9 told you about that incident?
10 A. said that Maxwell had shown her to a
11 bedroom and on the bed was a school-girl outfit and Maxwell
12 told her when -- confronted her about it and Maxwell
13 said 'well, I thought it would be adorable if you gave
14 Jeffrey his tea in this.' So felt like she had to
15 put it on so she put it on, took Epstein his tea, and
16 Epstein then slapped her on the buttocks and reached under
17 the skirt and touched her.
18 Q. What was her demeanor like when she described this
19 incident to you?
20 A. She was crying; she was very upset.
21 Q. When described seeing the school-girl
22 outfit and talking to Maxwell about it, did she remember
23 Maxwell telling her 'don't be so frigid?'
24 A. Yes.
25 Q. Does she remember that later in the day, after she
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had delivered Epstein his tea and he assaulted her, does she
2 remember Maxwell telling her 'I heard you did well?'
3 A. Yes.
4 Q. During the years that was in contact with
5 Maxwell and Epstein did she remember whether Maxwell would
6 ever ask her if she knew any other girls who could massage
7 Epstein?
8 A. Yes.
9 Q. Does she remember Maxwell saying, in sum and
10 substance, 'do you know anyone who can give him a blow job
11 today; I don't feel like it?'
12 A. Yes.
13 Q. Does she remember Maxwell saying, when she asked
14 her to bring other girls, that they have to look young at
15 least?
16 A. Yes.
17 Q. From your conversations with did she tell
18 you whether or not she ever brought any other girls?
19 A. didn't bring any girls.
20 Q. Did she tell you why not?
21 A. She didn't want anyone else to go through that.
22 Q. From your interviews with did she tell you
23 that there came a time when she was in her early 20s when
24 she stopped traveling with Maxwell and Epstein?
25 A. Yes.
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Q. Was she struggling with substance abuse at tha
2 point?
3 A. Yes, she was.
4 Q• Did she tell you that she got sober in her 20s?
5 A. Yes, she did.
6 Q. What is her current profession?
7 A. She runs a non-profit for people who struggle with
8 addiction and trauma.
9 Q. Did provide you with several emails that
10 she exchanged with Epstein in the early 2000s?
11 A. Yes, she did.
12 Q. And were those emails very friendly in tone?
13 A. Yes, they were.
14 Q. What did she say to you when you talked with her
15 about those emails?
16 A. She said she didn't, at the time, want to
17 acknowledge what was going on to her; that looking back on
18 it's different.
19 Q. Did your squad at the FBI execute a search warrant
20 at Jeffery Epstein's townhouse in Manhattan in July 2019?
21 A. Yes.
22 Q. Did you personally participate in the search of
23 Epstein's residence?
24 A. Yes, I did.
25 Q. Did the townhouse include a massage room?
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A. Yes.
2 Q. Have you yourself been in that massage room?
3 A. Yes, I have.
4 Q. Could you please describe for the grand jury what
5 that massage room looked like?
6 A. It was dark. It had dark draperies covering the
7 windows. There was a massage table. There were oils.
8 There was a hand-held massager in there along with
9 handcuffs, a whip, and along the walls were nude photographs
10 of young females.
11 Q. I believe you testified a moment ago tha-
12 told you that there was a time when Maxwell
13 asked her to wear a school-girl outfit for Epstein when they
14 were in Palm Beach. Did you find a school-girl outfit in
15 Epstein's New York townhouse?
16 A. Yes, we did.
17 Q. Where did you find it?
18 A. It was found in a room next to the massage room.
19 Q. And to be clear, did the FBI find sex toys during
20 the search?
21 A. Yes.
22 Q. What was found?
23 A. Butt plugs, dildo, vibrators.
24 Q. We've talked about three minor girls today,
25 and is that right?
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A. Yes.
2 Q. Have you reviewed the proposed indictment, marked
3 Grand Jury Exhibit 1?
4 A. Yes, I have.
5 Q. Is the individual referred to as Victim 1 in
6 the proposed indictment?
7 A. Yes.
8 Q. Is the individual referred to as Victim 2 in
9 the proposed indictment?
10 A. Yes.
11 Q. Is the individual referred to as Victim 3
12 in the indictment?
13 A. Yes.
14 Q. During all of Maxwell's interactions with the
15 victims when they were underage girls, based on the
16 timeframe and your knowledge of Maxwell's birth date, was
17 she in her 30s?
18 A. Yes, she was.
19 Q. Just one moment. All right. Switching gears.
20 Have you become aware that in or about 2016 Maxwell gave
21 sworn testimony in a civil deposition in connection with a
22 lawsuit?
23 A. Yes.
24 Q. Could you please explain for the grand jury what
25 is a deposition?
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A. It is a statement made under oath.
2 Q. And in the course of civil litigation is it common
3 for witnesses or the parties of the lawsuit to give a
4 deposition under oath where they testify about the substance
5 of the case?
6 A. Yes.
7 Q. And is deposition testimony live and in person and
8 under oath?
9 A. Yes.
10 Q. Is a court reporter present when a deposition
11 takes place?
12 A. Yes.
13 Q. Now before we talk about Maxwell's deposition
14 testimony, I want to talk with you about the lawsuit that
15 the testimony was about. Have you become aware that in or
16 about 2015 an individual named filed a
17 lawsuit against Ghislaine Maxwell here in the Southern
18 District of New York?
19 A. Yes.
20 Q. And was suing Maxwell for defamation?
21 A. Yes, she was.
22 Q. Was the lawsuit captioned against
23 Ghislaine Maxwell with Docket Number 15-CV-7433 here in the
24 Southern District of New York?
25 A. Yes.
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Q. Generally speaking, in broad strokes, what was the
2 lawsuit about? What was the claim that was bringing
3 against Maxwell?
4 A. had stated that she had been sexually
5 abused by Epstein and Maxwell as a minor. Maxwell came
6 forward publically and called her a liar. So
7 her for defamation.
8 MS. So just a small legal instruction on
9 this topic. Ladies and gentleman, I instruct you that the
10 allegations in the lawsuit are not being presented to you as
11 evidence that those incidents occurred. I instruct you that
12 you should not consider those allegations for their truth;
13 instead, the circumstances of the lawsuit are being
14 presented to you so that you can consider the context of the
15 case and the circumstances under which Maxwell made
16 statements under oath.
17 BY MS.
18 Q. Turning back to the deposition. Did Maxwell's
19 deposition take place over two different days?
20 A. Yes.
21 Q. On both days did she give testimony in Manhattan?
22 A. Yes, she did.
23 Q. Is that where the deposition took place?
24 A. Yes.
25 Q. And on both days was Maxwell sworn under oath?
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A. Yes.
2 Q. If you could flip through the remaining slides in
3 the presentation. Do those slides contain true and accurate
4 excerpts of the transcript of that deposition?
3 A. Yes.
6 Q. Turning to the next slide, is this the cover page
7 of the transcript of the first deposition that took place on
8 April 22, 2016?
9 A. Yes.
10 Q. And does it have the case caption on it?
11 A. Yes, it does.
12 Q. Turning to the next slide, is this an excerpt from
13 the transcript?
14 A. Yes.
15 Q. I imagine the grand juries can't read it from
16 their seats so if you could read it with me, I'll read the
17 questions and if you could read the answers.
18 Question: "Did Jeffrey Epstein have a scheme to
19 recruit underage girls for underage massages?"
20 And it appears there was an objection from the
21 lawyer.
22 Question: "If you know."
23 A. Answer: "I don't know what you are talking about."
24 Q. Just to be clear with the question and answer, is
25 the answer here Maxwell's testimony?
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A. Yes.
2 Q. Just to be clear, you testified earlier that
3 participated in sexualized massages with Epstein and
4 Maxwell; is that right?
5 A. Yes.
6 Q. And was a minor when that occurred?
7 A. Yes.
8 Q. And did you also testify earlier that Maxwell --
9 that told you that Maxwell asked her to
10 give Epstein massages when she was a minor?
11 A. Yes.
12 Q. If you could turn to the next slide, please.
13 this another excerpt from that same deposition?
14 A. Yes, it is.
15 Q. All right. I'll read the question and you can
16 read the answer.
17 Question: "List all the people under the age of 18
18 that you've interacted with at any of Jeffrey Epstein's
19 properties?"
20 A. Maxwell's answer: "I'm not aware of anybody that I
21 interacted with, other than obviously who was 1.7
22 at this point."
23 Q. Just to be clear, you testified earlier about two
24 girls under the age of 18 who interacted with Maxwell at
25 Epstein's properties; is that correct?
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A. Yes.
2 Q. And those individuals were and
3 who told you that, correct?
4 A. Yes, that's correct.
5 Q. Turning to the next slide, is this the cover page
6 of the transcript from the deposition that took place on
7 July 22, 2016?
8 A. Yes.
9 Q. And again, was this Maxwell giving testimony as
10 part of the testimony under oath here in Manhattan?
11 A. Yes.
12 Q. If you could please turn to the next slide. Is
13 that an excerpt -- are these two excerpts from that
14 deposition?
15 A. Yes.
16 Q. Again, I'll read the questions if you could please
17 read the answers.
18 Question: "Were you aware of the presence of sex
19 toys or devices used in sexual activities in Mr. Epstein's
20 Palm Beach house?"
21 There's an objection from the lawyer.
22 A. Maxwell's answer: "No, not that I recall."
23 Q. "Do you know whether Mr. Epstein possessed sex
24 toys or devices used in sexual activities?"
25 There's an objection from the lawyer.
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A. Maxwell's answer: "No."
2 Q. Just to be clear, you testified earlier that
3 told you he found sex toys in the massage room
4 in Palm Beach and also that he had seen that Maxwell had a
5 basket of sex toys in her closet there; is that correct?
6 A. Yes, that's correct.
7 Q. And is it correct that you testified earlier that
8 Epstein had used a vibrator on is that
9 correct?
10 A. Yes, that's correct.
11 Q. And did you also testify earlier that
12 told you he did that, as well?
13 A. Yes, that's correct.
14 Q. And did you also testify earlier that sex toys
15 were found by the police in the Palm Beach house in 2005; is
16 that right?
17 A. Yes.
18 Q. And did you also testify earlier that the FBI
19 found sex toys in Epstein's New York City townhouse in 2019?
20 A. Yes, that's correct.
21 Q. If you could please turn to the next slide. This
22 is on page 27. Is this -- are these also excerpts from that
23 same deposition?
24 A. Yes.
25 Q• Again, I'll read the questions if you could please
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read the answers.
2 Questions: "Other than yourself, and the blonde
3 and brunette that you have identified as having been
4 involved in three-way sexual activities, with whom did
5 Mr. Epstein have sexual activities?"
6 There's an objection from the lawyer.
7 A. Maxwell's answer: "I wasn't aware that he was
8 having sexual activities with anyone when I was with him
9 other than myself."
10 Q. Question: "I want to be sure that I'm clear, is i-
11 your testimony that in the 1990s and 2000s you were not
12 aware that Mr. Epstein was having sexual activities with
13 anyone other than yourself and the blonde and brunette on
14 those few occasions when they were involved with you?"
15 A. Maxwell's answer: "That is my testimony. That is
16 correct."
17 Q. Have you reviewed the deposition transcript --
18 A. Yes.
19 Q. -- in full? Now, the excerpt we just read has a
20 reference to a blonde and brunette. Are those individuals
21 completely different from the individuals we've been talking
22 about today?
23 A. Yes.
24 Q. Just to be clear, is it correct that you testified
25 earlier that and told you that Epstein
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sexually abused them repeatedly; is that correct?
2 A. Yes.
3 Q. And did you also testify earlier that Maxwell was
4 occasionally present when Epstein was abusing based
5 on what she told you?
6 A. Yes, that's correct.
7 Q. Turning to the next slide, is this also an excerpt
8 from the same deposition?
9 A. I'm sorry?
10 Q. I'm so sorry. Turning to the next slide, on page
11 28, is this also an excerpt from the same deposition?
12 A. Yes.
13 Q. Thank you. Okay. Again, if we could read that
14 together I'll take the question if you could take the
15 answer.
16 Question: "Let's just tie that down. Is it your
17 testimony that you've never given anybody a massage?"
18 A. Maxwell's answer: "I have not given anyone a
19 massage."
20 Q. "You never gave Mr. Epstein a massage; is that
21 your testimony?"
22 A. Maxwell's answer: "That is my testimony."
23 Q. "You never gave a massage; is that
24 your testimony?"
25 A. Maxwell's answer: "I never gave
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1 massage."
2 Q. Just to be clear, as you testified earlier, is it
3 correct that told you that Maxwell gave her a
4 massage when they were in New Mexico?
5 A. Yes.
6 Q. Have you told the grand jury everything that you
7 know about this case or have you just answered the questions
8 that I've asked?
9 A. I've just answered the questions you've asked.
10 Q. And when you testified about the documents that
11 you reviewed or the conversations that you had with others,
12 were you testifying to the exact words used or just the
13 substance of the documents or conversations?
14 A. The substance?
15 Q. And are you willing to return to the grand jury if
16 the grand jury has any further questions for you?
17 A. Yes.
18 MS. With the Foreperson's permission I'd
19 ask that the witness be excused at this time.
20 FOREPERSON. You're excused.
21 MS. Thank you.
22 (Witness Excused)
23 (Time Noted: 11:41 a.m.)
24 (Colloquy Follows)
25
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1 CERTIFICATE
2
3 I hereby certify that the foregoing is a true and
4 accurate transcription, to the best of my skill and ability,
5 from my electronic notes of this proceeding.
6
7 July 6, 2020
Date
8
Acting Grand Jury Reporter
Free State Reporting, Inc.
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25
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