Epstein Files

120 LBUCmaxl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Trial New York, N.Y. November 30, 2021 8:5...

121 LBUCmaxl 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: Looks like we have everybody. Matters to take up, counsel. MS. COMEY: Nothing from the government, your Honor. MR. EVERDELL: Nothing, your Honor, but note we have put t...

122 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. STERNHEIM: Judge, I have an issue I would prefer to raise at sidebar very quickly. THE COURT: Okay. (Continued on next page) (Pages 123 to 125 SEALED) SOUTHERN DISTRICT REPORTERS, P.C. (212) 80...

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126 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (In open court) THE COURT: I'll note I received a report from the district executive office that, once again, today, everyone who's appearing to watch the trial is being accommodated, either in this ...

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130 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (In open court) THE COURT: I spoke to the juror with the travel plans and the information is that dates can't be changed and they can't cancel and it would be of some significant hardship. The juror ...

131 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 or the 24th, and it's the weekend, Christmas weekend, 25th, 26th. The juror would be gone the 27th, 28th, would not make sense to return for one day of that week. So, really, it would be a 10-day brea...

132 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 was still available and we would have gone with the choice of seating the one juror, the number I don't remember off the top of my head, but the one juror who had dropped off of the alternate pool as ...

133 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 really, the option is just to encourage them to take a last shot at any effort to move it, but I think we're going to end up in the same place. I'm wishing we had kept that additional juror. I think I...

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137 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (In open court) THE COURT: I had an additional conversation with the juror. He was confident there was no way to move it. He said he could cancel it, they would lose money, it was a burden, he was di...

138 LBUCmax1 - direct 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: Thank you, members of the jury. I hope you had a pleasant evening. Thank you so much for being here ready to go on time. I greatly appreciate it. We will resume wi...

139 LBUCmaxl - direct Q. Based on your interactions with and observations of 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Mr. Epstein's employees, where in the hierarchy did Ms. Maxwell fall? A. Ms. Maxwell was number 2. It was definitely Mr. Epstein was a...

140 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 LBUCmax1 - direct remember? A. Throughout the entire or we're talking 1994 to '04? Q. Yes. A. The first one that comes to mind would be Then there was another woman named , the last name escapes me. Those...

141 LBUCmaxl - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. EVERDELL: No objection. THE COURT: Government Exhibit 327 and 310 are admitted. You may publish. (Government's Exhibits 327, 310 received in evidence) MS. COMEY: Thank you, your Honor. ...

142 LBUCmaxl - direct Court, and the parties Government Exhibits 334 and 335, please. 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 recognize these, Mr. A. Yes, I do. Q. Who do we see starting in Government Exhibit 334, the one on the left? A. Th...

143 LBUCmax1 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 employment with Mr. Epstein? A. I visited that ranch every visit that Mr. Epstein had to the ranch. Q. And about how often did Mr. Epstein go to the ranch? A. It wasn't that often. Certainl...

114 LBUCmax1 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. COMEY: Thank you, your Honor. Ms. Drescher, could we please show this to the jurors. BY MS. COMEY: Q. While that's up, Mr. , would you please describe the ranch property that Mr. Epste...

145 LBUCmaxl - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 firehouse with a fire engine, and that also had several garages for all the maintenance for the ranch. And then to the right of that, there was a greenhouse for growing vegetables, et cetera...

146 LBUCmaxl - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 past the runway. You continued up that road where you saw the photo with the Z on the entrance. That was the main entrance to the main house. And then the main house was built eventually on ...

117 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. COMEY: Q. In total approximately how many acres was Mr. Epstein's ranch? A. It was approximately 10,000 acres. I know there was some state land included in it, but everybody said it ...

148 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. What are they? A. Those are exterior photos of the main house at Zorro Ranch. Q. Are these fair and accurate depictions of the exterior of the main house on Mr. Epstein's Zorro Ranch? A....

149 LBUVMAX2 - direct room, which was tremendous in size; it had to have been 200 feet by 50 feet, and it had an extremely large picture window 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that overlooked the ravine or the house -- where the house you know,...

150 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 back up the stairs. We're on the main level. And then there was another staircase that brought you upstairs that housed the master bedroom, as well as approximately three -- three or four gu...

151 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 And then if you continued past the living room and made your left turn to the left side of the home, that was the master bedroom. And then you came back into the living room you continued st...

152 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 working for Mr. Epstein? A. Not as much as the other properties. On occasion I would go to pick up luggage and drop off luggage at that place. But I would almost say every trip, but we didn'...

153 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ms. Drescher, would you please show that to the jury. Q. And while that's up, Mr. would you please describe what the inside of this apartment looked like. A. I believe it was on the second ...

154 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Little St. James. Q. About how often did you visit Little St. James during your employment for Mr. Epstein? A. Every time we went to the St. Thomas U.S. Virgin Islands, where the island ...

155 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Government Exhibit 346 for the witness, the Court, and the parties. Q. Mr. , do you recognize that? A. Yes. Q. What is it? A. That is an aerial view of Little St. James Island. Q. And do...

156 LBUVMAX2 - direct Mr. Epstein's private island? A. Yes, it is. MS. COMEY: Your Honor, the government offers this in 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 evidence. MR. EVERDELL: No objection. THE COURT: Government 308 is admitted. You may publ...

157 LBUVMAX2 - direct MS. COMEY: Your Honor, the government offers this in evidence. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. EVERDELL: No objection. THE COURT: GX-326 is admitted. You may publish. (Government's Exhibit 326 received in evidence) M...

158 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Mr. , do you recognize this? A. Yes, I do. Q. What is it? A. That is a photo of Little St. James Island. Q. Is this a fair and accurate depiction of an aerial view of the entirety of L...

159 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 photo which was -- which they call the flag -- or the flagpole pool, which was a tremendous-size pool which also had a cabana built. And that was another office that Mr. Epstein spent a lot ...

160 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 it was kind of what I considered like an exploded house. Q. When Mr. Epstein was staying on this island, what airport did you fly into and out of? A. We flew into the main airport in St. Tho...

161 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 accurate estimation on that. Q. And about when do you remember her moving into the brownstone townhouse you mentioned? A. I'd only be guessing if I said the 2000s, but I don't have an exact...

162 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 level, the second and third floors, I believe were the guest bedrooms and the master bedroom. And then once you got to the top, which, if memory serves me correctly, might have been the fift...

163 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Are these both fair and accurate depictions of that aircraft? A. Yes, they are. MS. COMEY: Your Honor, the government offers both of these exhibits in evidence. MR. EVERDELL: No objecti...

16.1 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Do both of these exhibits fairly and accurately depict that helicopter? A. Yes, they do. MS. COMEY: Your Honor, the government offers these in evidence. MR. EVERDELL: No objection. TH...

165 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Between approximately 1994 and 2000, what plane did you fly most frequently for Mr. Epstein? A. From 1994 to 2000, that would be it would have been all been the Gulfstream G2B. MS. COME...

166 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 obviously if you make a left turn, that would bring you into the cockpit. You made a right turn, brought you into the passenger compartment. And as soon as you got into the passenger compart...

167 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. No, I could not. Q. Between approximately 2001 and 2004, which of Mr. Epstein's planes did you fly most frequently? A. Between 2001 and 2004, it was a combination of both the Boeing 727 ...

168 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 describe what the inside of this plane looked like. A. Sure. The best way to describe it, it was kind of like a recreational vehicle inside; it wasn't like a typical airliner would look. Yo...

169 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 And then once you continue further walking to the back of the aircraft, there was the master bedroom that had a queen-size bed and two captain's chairs inside there. And then you're still wa...

170 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. While Ms. Drescher puts that up, will you please describe once again what we see in this photograph, Mr. A. That's the middle of the aircraft or where actually the emergency exits are loc...

17i LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. It was always closed. Q. So were you able to observe the passengers on the flights you piloted on that plane? A. No. Q. What records did you keep as a pilot for Mr. Epstein? A. We kept ...

172 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. A passenger manifest is a document that we recorded what time we actually took off and landed. It had the date of the flight, it had the exact time of departure and arrival, and it also h...

173 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 passenger name, I wanted to put whether they were male or female, the passenger -- as a pilot's standpoint, it's more important how many people and how much they weigh compared to a person's...

174 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 maybe close to fall when cherry season was happening because _ think that's the cherry capital. Q. When traveling to Traverse City, Michigan, where, if anywhere, do you remember picking up M...

175 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. COMEY: Thank you, your Honor. It is hereby stipulated and agreed that Government Exhibit 11 is a true and correct certified copy of a birth certificate reported to the New York Departmen...

176 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 birth certificate reported to the general registrar -- register office of England and Wales. Government Exhibit 16 accurately reflects the date of birth of the person named on the certificat...

177 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. COMEY: Yes, your Honor. THE COURT: Okay. And the specific direction to the jury is to pick up the binder now or not yet? MS. COMEY: Pick up the binder now, but don't turn anywhere in th...

1 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Thank you. MS. COMEY: And your Honor, we have a hard copy for the Court, if that would be useful. THE COURT: That would help. Thank you. MS. COMEY: May Ms. Drescher approach? THE C...

179 LBUVMAX2 - direct Q. Is the first and last name on that document the name of the female singer you remember being a passenger on Mr. Epstein's plane? 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. EVERDELL: Objection. Leading. THE COURT: I'll allow i...

180 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Did anyone ever tell you how old was? A. No. Q. Do you know how old was when you met her? A. No, I didn't. Q. How did you meet A. Mr. Epstein brought her to the cockpit and introduced...

181 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Had to have been mid to late '90s. Q. Do you remember the exact year? A. I do not. Q. What did look like? A. A shorter woman with dirty blond hair. Q. Did anyone ever tell you how old ...

182 LBUVMAX2 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 what's inside this binder. MR. EVERDELL: This is in case we need to refer the witness to something. THE COURT: So you may bring it forward. Before the witness is directed to look at any docu...

183 LBUVMAX2 - 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. Q. And you were hired, along with your friend that right? A. That's correct. Q. Now, when you started in 1991, was the chief pilot and you were the co-captain? A. That...

124 LBUVMAX2 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Okay. You may. MR. EVERDELL: And we can display that for the jurors. THE COURT: You may. Q. Do you see that, Mr. A. Yes, I do. Q. We saw that before. That's the Hawker Siddeley j...

185 LBUVMAX2 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Okay. And he got that, your recollection is, sometime around 1994? A. Correct. MR. EVERDELL: All right. We can take that down. Q. And you've also mentioned that he eventually got the Boei...

186 LBUVMAX2 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. And from 2000 onwards or till 2004 or five, you were flying both the Gulfstream and the Boeing? A. That's correct. Q. Now, in the period from 1991, when you were first hired, to 2005, you...

187 LBUVMAX2 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Sometimes. Q. There were times when Epstein or Ghislaine introduced you to passengers? A. Correct. Q. There were times when the plane and the passengers had to clear customs, right, and ...

188 LBUVMAX2 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the aircraft, but, yeah, I could see the passengers. Q. There were several ways that you could have observed and did observe the passengers that came onto his planes? A. Yeah, if I looked ove...

189 LBUVMAX2 - 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. I didn't know anybody's, you know, exact age or age at all really. Q. But none of them appeared to you to be under 20? A. Correct. Q. Was that -- I didn't hear. A. Yes, that's c...

190 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. EVERDELL: Q. She was a woman? A. Yes. Q. Mr. , in all these flights that you flew, the several hundred to a thousand flights that you piloted for Mr. Epstein in this time period, yo...

191 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's correct. Mr. Epstein invited us, that if we had to go to the bathroom, that we were welcome to walk to the back of the aircraft. Q. So he invited you to come anywhere you wanted to,...

192 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 middle of the aircraft because the bathroom was at the absolute rear, correct. THE COURT: Members of the jury, we'll take our midmorning break. See you in about 10 minutes. (Continued on nex...

193 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) Everyone may be seated, the witness may step down for the break. (Witness not present) Are there matters to take up before the break? MS. COMEY: No, your Honor. MR. EVER...

194 LBUCmax3 - cross THE COURT: 20 minutes. MR. EVERDELL: I'd say maybe another hour or so. THE COURT: Okay. Ms. Sternheim, I have asked for 4 them to raise the temperature. 5 MS. STERNHEIM: Thank you, Judge. Feels better 6 already. 7 (Continued on next page) 8 9 10 11 12 13 14 ...

195 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: Please be seated. I hope you had a pleasant and timely break, members of the jury. Thank you for your continued attention and diligence. Mr. Everdell, you may conti...

196 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the plane and he didn't want you to see that, he probably would have said something to you about that, wouldn't he? MS. COMEY: Objection, your Honor. THE COURT: Overruled. You may answer. A....

197 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the cockpit to use the restroom? A. Correct. Q. And you did that both on the Gulf Stream and on the Boeing; is that correct? A. Yes. Q. The Gulf Stream bathroom, you said, was in the back o...

198 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's correct. Q. So you would have to walk through at least that first cab':-: of passengers? A. That's correct. Q. And on those trips you took to get coffee in the galley kitchen, you...

199 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in sexual activity with underage girls on the flights you piloted; isn't that right? A. Correct. Q. Mr. , I want to ask you some questions about how the flights were scheduled and set up. O...

200 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 call you to schedule the flights; isn't that right? A. It would be a variety. Whoever got the message would pass it along to us, correct. Q. Right. And I think you said that in the 1990s, you...

201 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 this, about scheduling? A. Occasionally Ghislaine would reach out. Several people would reach out. Whoever Jeffrey told, hey, get the plane ready, that's the person that contacted me. Q. It ...

202 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 the person I think you spoke most often to about scheduling flights in the 2000s was not , it was ; isn't that right? A. She would also schedule flights, yes. Q. You met , you said?...

LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 for the Court, the deputy, and for the witness 3527-07 at page 86. I'll repeat for clarity that's 3527-007 at page 86. THE COURT: Let me know when you're ready, Ms. Comey. MS. COMEY: I'm there. Th...

204 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that right? A. I didn't know what her exact job detail was. I mean, I considered her position or her title, you know, throughout the same as far as to being Mr. Jeffrey's assistant or Ms. Ma...

205 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. Q. In fact, you spoke to so often at that point that you had her number on speed dial in your phone; isn't that right? A. Most likely, yes. Q. Do you recall what phone...

206 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: Thank you. You can take that down. Q. So in the 2000s, that's the number you would speak to on about arranging flights? A. Correct. Q. Now, regardless of who you spoke to about...

207 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. Exactly. Q. So, for example, I believe former president Bill Clinton flew on Epstein's planes a few times in the 2000s; isn't that right? A. Yes, he did. Q. So if he were going to be on ...

208 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. Sure. Q. But even if you weren't told all the names or you didn't have all the names, you did try to keep track of how many people were on the plane; right? A. That's correct. Q. Because...

209 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 female if we didn't catch a name. Q. Obviously, if you did know the name or it was a person you recognized from before, you would put their name on the manifest? A. Absolutely. Q. And you s...

210 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. Right, because the Boeing, as we saw it, it's huge; right? A. Correct. Q. And the Gulf Stream is not a little prop plane, it has a jet engine; right? A. Correct. It's not power challenged...

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's correct. Q. Or you might just be given their first name? A. Correct. Q. Not be given a name at all? A. Correct. Q. So that's an example of where you might put one female, one male? A...

212 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. So from your perspective, you had no reason to believe that Ghislaine would have known which passengers were on the flights that she didn't fly on herself? A. Correct. Q. I want to talk t...

213 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Traverse City, Michigan? A. That's correct. Q. That's the closest airport? A. That is closest. Q. And in the 1990s, you flew into Traverse City at least once a year or maybe twice a year in...

214 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 again. If we could pull up 3527-007 at page 2 just for the Court, the deputy, and the witness, please. We'll direct your attention, Mr. , from the bottom if you count up six or ...

215 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 lot of facts on it, just sheer of what I know, what I remember. Q. But on those trips, Ghislaine wasn't with him every time he went, was she? A. I don't remember whether she was or not. I kno...

216 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 document, but I don't see Ms. Maxwell's name on there. It's just -- MS. COMEY: Your Honor, objection. THE COURT: Sustained. I'll have the jury disregarded observations of the document that ar...

217 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. And Epstein had a home and an office in Columbus, Ohio where Les Wexner's home was; isn't that right? A. That is correct. Q. So he had a few reasons to go to Columbus, Ohio? A. That's cor...

218 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. Yes. Q. And that she was a singer; right? A. Yes. That's the way Mr. Epstein introduced her as. Q. And you said that I think she had striking blue eyes; is that right? A. Correct. Q. Yo...

219 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's correct. He would bring passengers on just to show them the interior and the cockpit, correct. Q. Sometimes he would show them around, they would look around, maybe meet the pilots,...

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 ...

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...

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....

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...

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. ...

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

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 rea...

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. Y...

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 und...

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 takeof...

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...

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 tha...

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 tr...

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 Ep...

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 embrand...

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 agreem...

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 ...

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...

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...

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. O...

240 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 living room, which was you made a left turn that brought you into the master bedroom, and if you made a right turn, it took you to the two guest bedrooms on the right side of the trailer. Q. ...

241 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. And you built a house there? A. I built the house there, yes. Q. So from about 2000 onwards when you flew to the ranch, you'd stay at your home? A. That is correct. Q. Let me ask you bri...

242 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. So you wouldn't stay in the island residence, you'd stay at St. Thomas? A. I would bring the helicopter back and the crew would stay on St. Thomas in a regular hotel. Q. Now, we saw a num...

243 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 year, but you're correct that it was late '90s. Q. And that construction was going on for several years, wasn't it? A. Yes. Q. Including the helipad that was there? A. The helipad moved a c...

21.4 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. So he knew about your shared interest, you talked about this a lot? A. That is correct. Q. Now he, I believe, bought some cars that he registered in your name; isn't that right? A. Yes....

245 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 believe Epstein also bought a 34-foot JVC powerboat; right? A. Yes. Q. That was registered to you, as well? A. Yes, it was. Q. And you could use it if you wanted to; right? A. That's ...

246 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. Yes. Q. When was that? A. That was probably it was in my possession for 20 years. Probably around 2000. Q. Thank you. Now, Mr. , in your testimony a little while ago, you said that Eps...

217 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. Yes. Q. Did you ever mention this to Ghislaine that Epstein was paying for your daughters' tuitions? A. Yes. Q. So she was aware of this fact, too? A. Absolutely. Q. Did you ask Epstein...

248 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. Absolutely. Q. And you certainly didn't think that Epstein had any ulterior motive for being generous to your daughters, did you? A. No. Q. And he never asked you for anything in return, ...

249 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 didn't know their sexes, to be honest with you. Q. But to your knowledge, these were all adult professional masseuses? A. Oh, absolutely. Q. Now, Mr. , I want to ask you some questions...

250 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 residences. Q. This is something you know how to do well? A. Yeah, I had a knack for that, as well. Q. So your mechanics background helps with that? A. Yes, it did. Q. And he liked having s...

251 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 moved to a townhouse on 71st Street; right? A. That's correct. Q. That's the one we saw photographs of? A. Correct, that's the 9 East 71st Street. Q. That's right off Fifth Avenue and Centra...

252 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. Yes. Q. And I believe you said you think you went to all of them: A. Yes. Q. So when you first started working for Epstein in '91, she lived in an apartment on -- you said a small apartme...

253 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. And that was 301 East 65th Street; right? A. No, 301 -- well, 301 was the apartment. 66th Street, that address on 65th, which I want to say it was 116 or 114 East 65th Street -- MR. EVERDE...

254 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. Mr. , I have one related question about the home theater equipment you installed. You testified that you installed this type of equipment in virtually all of Epstein's residences; right? ...

255 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 my head on that. Q. Best guess is sometime in the mid '90s? A. Mid '90s, yes. Q. Do you recall how long the renovation lasted? A. It was a pretty serious renovation. I'd only be guessing if...

256 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. Yes. Q. And you testified that she was one of the assistants he had in his office; right? A. Yes. Q. He had lots of assistants; isn't that right? A. That's correct. Q. Now, in the mid '...

257 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. Q. If there was something wrong, ultimately it was her responsibility if there was a problem? A. It probably would have been the first phone call to Ms. Maxwell to say we got a p...

258 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. Q. She bought household items? A. Yes. Q. She decorated the planes, too; right? A. She had a lot put into the airplanes, stocking the airplane on what we carry as far as...

259 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. She took care of the horses; right? A. Yes, she did. Q. She took care of the other animals on the property? A. Yes. Q. This took a lot of Ghislaine's time and energy to do this job, didn...

260 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. 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...

261 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 ...

262 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. ...

263 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. 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...

264 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. 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 woul...

265 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 al...

266 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 freq...

267 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. 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...

268 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) (Witness not present) Matters to take up before the break. MS. COMEY: No, your Honor. MR. EVERDELL: Nothing, your Honor. (Recess) (Continued on next page) SOUTHERN DIST...

269 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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...

270 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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....

271 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 acreag...

272 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 r...

273 LBUVMAX4 - 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. 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...

274 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. ...

275 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 2000...

276 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 ...

LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 ...

278 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 safet...

279 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 s...

280 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 ...

281 LBUVMAX4 - redirect 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. R...

282 LBUVMAX4 - redirect Q. Do you recall being asked questions about your daughters on 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 cross-examination, Mr. A. Yes, I do. Q. When your daughters were 14 years old, did you let them give Mr. Epstein a massage? ...

283 LBUVMAX4 - redirect 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 ...

284 LBUVMAX4 - redirect 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 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?...

285 LBUVMAX4 - redirect 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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...

286 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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, ...

287 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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...

288 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 ...

289 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 ol...

290 LBUVMAX4 - direct If you could please turn to what's been marked for identification only as Government Exhibit 106. Do you recognize that? 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. What is Government Exhibit 106? A. That is a picture of ...

291 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 lik...

292 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 summ...

293 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 chitc...

294 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 p...

295 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 i...

296 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 ...

297 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 afte...

298 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 ...

299 LBUVMAX4 - direct Q. What was your understanding at the time of what the 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 relationship was between Ghislaine Maxwell and Jeffrey Epstein? A. I didn't really understand. They never really shared that informatio...

300 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 well. Q. When you began spending time with Maxwell and Epstein, what was your impression at the time of how old they were? A. I thought approximately the same age as my parents, my mom. Q. ...

301 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 me, you know, what I was up to, and ask me if I had any boyfriend at school. Q. During those first few months, as you were getting to know her, how did Maxwell come across to you? A. She se...

302 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 it's okay. And he said, No, no, no. It's okay. This is for your mother. I know she's having a hard time, so it's not a big deal. Q. After that happened, did he ever give you any money again...

LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 "grandfathered" meant, first and foremost. Q. Did there ever come a time when you went shopping with Maxwell and Epstein? A. Yes. Q. Approximately when was that? A. Sometime at the end of 1994 ...

?CA LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and they knew everyone. And they would sort of name-drop or sometimes put people on speakerphone whose voices I didn't know and then say, Oh, well, this was so-and-so and so-and-so; and just...

305 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 maybe a little bit odd. You know, there were some paintings of, like, naked women or half-naked women and, like, lots of kind of -- or animals, like creepy looking animals. Q. How did you fe...

306 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. The conversation just sort of ended abruptly. It was in his office. And he just took my hand and he said, Follow me. Q. Where did he take you? A. He took me outside in the backyard past t...

307 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. After that day that you just described, did there ever come a time when you saw Ghislaine Maxwell without her clothes on? A. Yes. Q. Approximately when was that? A. Shortly after the fir...

308 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. And I just want to be clear about this. For the incident that you just described when you were alone in a room with Epstein and Maxwell, how old were you when that happened for t...

309 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 rubbing his shoulders really hard, and like twisting his nipples hard, and rubbing his feet hard and, like, his head. Q. Where in the house would incidents like this typically happen? A. In...

310 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. Where did Epstein touch your body? A. He would touch-he would touch Q. During these incidents we've been discussing when you were 14, did you touch Epstein's body? A. Yes. Q. ...

LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you touched Epstein everywhere. Can you explain for the jury what you meant by that. A. I meant he -- he wanted to be massaged really from head to toe. He liked his head rubbed, his shoulders, he...

312 LBUVMAX4 - direct other people were present, how did incidents like that 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 typically start? A. It would be other people spending time at the house, sort of hanging out, seemingly casually. And then it was, once...

LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 she was not present? A. Yes. Q. Approximately how often would she be present during these incidents? A. I'm sorry, can you explain that? Q. If there were times when she was present and times wh...

314 LBUVMAX4 - direct 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 if there's anything he particularly liked. _ saw different acts, but Q. Again, to be clear, where in the house would incidents like this typically happen? A. The massage ro...

315 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. How often would it happen during those years? A. It would happen almost every visit with him, which would have been every two weeks. MS. MOE: Your Honor, if I could just have one moment. ...

316 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. In March of 2001. Q. I want to focus now on the years when you were 14, 15, and 16. About how many times did you travel with them during those years? A. Maybe ten times. Q. Where did yo...

317 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. I want to talk about some of the locations that you just mentioned. Did some of those trips include travel to New York? A. Yes. Q. Where did you stay when you traveled with Maxwe...

318 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 wood, and lots of, like, fabric wallpaper, like red curtains, lots of artwork, statues, paintings. Q. When you spent time in the house, what, if anything, did you notice about the artwork, t...

319 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. What rooms in the house did you spend time in when you would stay in the house in New York? A. What rooms would I spend time in? The room that I was given, which was the guest room on the...

320 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 he would start to masturbate, and he would ask me to straddle his face. He would ask me to, like, squeeze his nipples really hard while he came. Q. Did all of the things that you just descri...

321 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. My eyes didn't even look at the walls, mostly the floor, if not what was going on. Q. Was there any other furniture inside the massage room aside from the massage table? A. I don't know....

322 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. In the guest bedroom that was assigned to me. Q. Were you by yourself in the bedroom? A. Yes. Q. And did you spend most of your time alone in that bedroom when you were in New Mexico? A...

323 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. On that trip in New Mexico, was there ever a time when someone came into your room? A. Yes. Q. Can you describe to the jury what you remember about that? A. I just remember someone, at o...

LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Can you describe to the jury what happened. A. Well, I had traveled with them and I had to fly back to Palm Beach to go to school on a Monday, and I traveled with them on a private jet. Then, ...

325 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 were ages 14, 15, 16, and 17. A. What I looked like? Q. Can you describe what your physical appearance was like. A. Oh, I was -- I was kind of short. I was very thin. I was flat-chested unt...

326 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. What is Government Exhibit 108? A. That's a picture of me. Q. Approximately, how old were you when that picture was taken? A. 17. MS. MOE: Your Honor, the government offers Gov...

LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 were you when that photograph was taken? A. 17. Q. I want to step back and ask you a little bit about your home life during the years we've been talking about. When you were 14 to 17 and living ...

328 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. During the years that we've been talking about, did your mother know that you were spending time with Epstein and Maxwell? A. Yes. Q. Would you ever talk with her about that? A. Not in ...

329 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. MENNINGER: Objection. Hearsay, your Honor. Thtt was a different question. THE COURT: I'll sustain. If you reframe the question to elicit the information you indicated as opposed to askin...

330 LBUCmax5 - direct (Jury not present) (Witness excused) THE COURT: Everyone may be seated. Go ahead, 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ms. Moe. MS. MOE: Thank you, your Honor, I'd like to ask the witness about her conversations with her moth...

331 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 grateful for everything they were doing for her. THE COURT: And you're not seeking to offer that information for the truth, but for the effect that it had on the witness? MS. MOE: Yes, your...

332 LBUCmax5 - direct offered for the truth, it's being offered for the effect on the listener. I would give the jury a limiting instruction that 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the witness's testimony regarding what her mother said is not bein...

333 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 have told someone that that is a true statement. It's offered to show the environment in which she was living and how that affected her and affected her decision not to disclose what was goi...

3 3 4 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Nothing to take up; correct? MS. MOE: Correct, your Honor. MS. MENNINGER: Correct, your Honor. THE COURT: We'11 bring in the jury. (Continued on next page) SOUTHERN DISTRICT R...

335 LBUCmax5 - direct 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: Thank you, everyone. Ms. Moe, you may continue with your direct examination of the witness. MS. MOE: Thank you, your Honor. BY MS. MOE: Q. Before the break, we we...

336 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 LBUCmax5 - direct talking about when you were 14 and 15 and 16, did you ever talk with your mother about Jeffrey Epstein and Ghislaine Maxwell? A. Yes. Q. What kinds of things would she say to you about Epste...

LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in trouble if I said something. Q. During those same years, did you tell your brothers or any of your friends that you were being sexually abused by Maxwell and Epstein? A. No. Q. And why not? ...

338 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Approximately when was that? A. In the 7th grade. Q. How did you go to see the guidance counselor when you were in the 7th grade? A. Well, actually, she asked to speak to me. She called ...

339 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 when you were 15 and when you were 16. Just to be clear, were there times when that happened when it was just you and Jeffrey Epstein? A. Yes. Q. Were there times when that happened when it...

340 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you just become numb to it. Q. Is it fair to say that she was frequently in the room while you were being sexually abused by Jeffrey Epstein when you were 14, 15, and 16? MS. MENNINGER: Obj...

341 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. Would those women sometimes be involved in these encounters? A. Yes. MS. MOE: Just one moment, your Honor. THE COURT: Sure. Q. How would you typically transition from hanging a...

342 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. MOE: Thank you, your Honor. May the jurors turn to Exhibit 245 in their binders? THE COURT: Yes, please. You may pick up your binder and turn to GX245. BY MS. MOE: Q. Looking at Govern...

343 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 my attempt at being cool, I guess. Q. I want to ask you, , how did you feel at the time about the attention that Epstein and Maxwell were paying to you when you were in middle school and hi...

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348 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (In open court) THE COURT: You may proceed, Ms. Moe. MS. MOE: Thank you, your Honor. BY MS. MOE: Q. Let me back up and ask you a few questions. You testified in the beginning Epstein and M...

349 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 people their opinions on that. How do you navigate a healthy relationship with a broken compass? I didn't even understand what real love is supposed to look like. It ruined my self-esteem, m...

350 LBUCmax5 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 with Jeffrey Epstein? A. Yes. Q. Did you spend time with Ghislaine Maxwell that year? A. Yes. Q. During that year when you were a senior in high school, did you continue engaging in sexual...

351 LBUVMAX6 - direct BY MS. MOE: 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Where did you go when you moved away from New York City in October of '99? A. Los Angeles, California. Q. Why did you move to Los Angeles? A. Because I got a job Q. can yo...

352 LBUVMAX6 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Did there come a time when you stopped being in touch with Jeffrey Epstein? A. Yes. Q. Approximately when was that? A. The end of 2002. Q. And why did you stop seeing him at the end of ...

353 LBUVMAX6 - direct And do you want me to continue? Q. That's all right. Was that the last contact you had with him? 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. I think you mentioned that the person you were dating at that time you were enga...

354 LBUVMAX6 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to share, like, some of the things that had happened to me, not in detail, but, you know, it took a long time to really share any of that stuff with him. Q. Directing your attention to Septe...

355 LBUVMAX6 - direct A. Early 2020. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. To be clear, was that after you had told the government what had happened to you? A. Yes. Q. At the time that you sued Ghislaine Maxwell, did you also sue the Estate of J...

356 LBUVMAX6 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Because some of it has to go to counsel and litigation and filing documents and such. Q. How much did you ultimately receive? A. Approximately 2.9 million. Q. Has that money been wired t...

357 LBUVMAX6 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (At sidebar) THE COURT: The question is whether the jury's verdict will affect what she receives from the victim compensation fund? MS. MENNINGER: Right. I think she has a lack of personal...

358 LBUVMAX6 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the truth or not, which is precisely why I granted the Rule 17 subpoena and, I suspect, in the opening raised this issue precisely. So whether it's true or not, the question is what is her u...

359 LBUVMAX6 - direct lie. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. MENNINGER: In cooperating situations, your Honor, the sentence happens after the testimony. THE COURT: Well, they are not the same, but I think the point is the same. I'll give a ...

360 LBUVMAX6 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 have a financial stake -- THE COURT: That's what you argue to the jury. MS. MENNINGER: Your Honor, one other thing. If she did, in fact, give a statement to law enforcement in May of 2019, i...

361 LBUVMAX6 - direct (In open court) THE COURT: You may proceed, Ms. Moe. MS. MOE: Thank you, your Honor. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. MOE: Q. based on your understanding, will the jury's verdict in this case affect the award that...

362 LBUVMAX6 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to affect my career if somebody looks at me and that's all they see and that they won't hire me based on that. So I didn't really want any part of it; I just wanted it to go away. MS. MOE: Y...

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390 LBUVMAX6 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 evening. THE COURT: It's 5 o'clock. So we'll break for the Members of the jury, thank you for your attention and diligence. I remind you to please bear in mind all of my instructions and rul...

391 LBUCmax7 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: We have some matters to take up? MS. COMEY: Yes, your Honor. With respect to the Rule 16 issue, defendants Exhibit J36, what's never produced to the government in Rule 1...

392 LBUCmax7 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3, your Honor. THE COURT: How did page 3 impeach? MS. MENNINGER: Because it shows the house and the street that she lives on which is very different from what she described as her childhood home. She...

LBUCmax7 introduced, it's in violation of Rule 16. I think to the 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 extent there are other exhibits that the defense intends to offer that have not already been produced to us, we would ask that the Court order that ...

39.1 LBUCmax7 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 of the red house to impeach the testimony that she lives in a blue house, you show it to the government before or no? MS. MENNINGER: I did just show it to the government. THE COURT: Before the beginn...

395 LBUCmax7 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in '94, '95, and '96. So I'm not really sure. THE COURT: There was a witness who testified as to it being an accurate reflection of what the home looked like; right? MS. MENNINGER: Without saying whe...

396 LBUCmax7 that's the question. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 So government's objection, so when would you like to brief? MS. COMEY: Your Honor, may we have by 9:00 p.m. tonight? THE COURT: And Ms. Menninger? Or you could put in first. Yo...

397 LBUCmax7 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 at a high level of cross and what might troubleshoot these issues in advance in solution that avoids wasting the jury's be identified so we can order to work on a time and, most importantly, jeopar...

398 LBUCmax7 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: And just so -- I sealed the sidebar where we discussed identifying information about the witness and because I sealed a portion of the testimony so that the government can propose redaction...

399 LBUCmax7 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 know, as the Court may recall, testified earlier today about having disclosed having been abused to a person who we are identifying in this proceeding as We anticipate that would be the next witness...

400 LBUCmax7 godfather-like figure when she was growing up who helped the 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 family. I anticipate that will testify that told him during these conversations that the money was not for free, that she had to do thing...

401 LBUCmax7 Here defense counsel, in opening statements, suggested 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to the jury that a recent motive to fabricate in this case was civil litigation in a particular Jeffrey Epstein victim compensation fund. So this...

402 LBUCmax7 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and put it together by himself. THE COURT: You can cross him on that. MS. STERNHEIM: I understand that. I'm not challenging. I'm just saying that I think the full issue should be addressed at the con...

403 LBUCmax7 each of the witnesses in issue such that the rule would allow 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 prior consistent statements? I suppose a particular statement being offered is testimony, but I don't know that it has the question is wh...

404 LBUCmax7 this witness, it's about the direct of the next witness; fair to say? MS. STERNHEIM: Yes. And there could be redirect that 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 might, in some way, have bearing on this, but I will review it in connection...

405 Examination of: INDEX OF EXAMINATION Page 4 Direct By Ms. Comey 138 5 Cross By Mr. Everdell 182 6 Redirect By Ms. Comey 281 7 8 Direct By Ms. Moe 286 9 Cross By Ms. Menninger 363 10 GOVERNMENT EXHIBITS 11 Exhibit No. Received 12 327, 310 141 13 334, 335 ...

406 11, 12, 13, 14, 15, 16, 1004 176 106 290 107 325 4 108 326 5 245 341 6 DEFENDANT EXHIBITS 7 Exhibit No. Received 8 LV3A, LV3B 227 9 LV4, LV5 231 10 JOINT EXHIBITS 11 J-3 389 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P....