DOJ Epstein Files, Data Set 6 (EFTA00008920)

DOJ Data Set
Source
DOJ Epstein Files, Data Set 6
Date
2026-08-12
EFTA
EFTA00008920
Pages
1

OCR metadata differs from the recorded source declaration

2
3 UNITED STATES GRAND JURY
4 SOUTHERN DISTRICT OF NEW YORK
5x UNITED STATES OF AMERICA :
6 -V- : November 19, 2019 Additional
7 GHISLAINE MAXWELL
8 (2018R01618) :
9
10 United States Courthouse
300 Quaroppas Street
White Plains, New York
12 June 29, 2020
13 10:04 a.m.
14 APPEARANCES:
15 Assistant United States Attorney
16 Assistant onited states Actorney
17 Assistant United States Attorney
18
19
20
21
22
23 Acting Grand Jury Reporter
24
25
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(Colloquy Precedes)
(Witness Enters Room)
10:16 a.m.)
(Time Noted:
called as a witness, having been duly sworn by
the Foreperson cf the Grand Jury, was examined and
testified as follows:
BY MS. III:
Q. Good morning.
A. Morning.
Q. Can you please state your full name for the
record?
A.
Q. So : recognize that you are wearing a mask and
There’s a microphone in front of you, it
behind Plexiglas.
you could just make an effort to speak into the mic and keep
your voice up that would be great.
A. No problem.
Q. Where do you currently work?
A. The Federal Bureau of Investigation.
Q. What is your title?
A. Special agent.
Q. Hew long have you worked as a special agent?
A. About three years, three years now.
Q. where are you currently assigned?
A. I work for the on the Violent Crimes against
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1 Children squad.
2 What are your duties and responsibilities as a
Q.
3 special agent on that squad?
4 We investigate crimes that have to do with child
A.
5 sexual abuse material, sextortion, exploitation, and
6 enticement of minors, sex trafficking.
7 Maybe if she could take the mask
GRAND JUROR.
8 off. I’m having is anybody having difficulty
understanding her?
10 Thanks for letting me know.
Would that
MS.
11 be okay with you if the witness took her mask off?
12 We’re okay with the Plexiglas,
GRAND JUROR.
13 right?
14 Yeah.
GRAND JUROR.
15 MS. III.
Thanks very much.
Thank you.
16 BY MS. III:
17 Q.
So I’m just going to go back and ask
All right.
18 a few of those questions again just to make sure that
19 everyone can hear.
You testified earlier that you’re a
20 Is that correct?
special agent with the FBI.
21 A.
Yes.
22 Q.
Where are you currently assigned?
23 I work on the Violent Crimes against Children
A.
24 squad.
25 And what are your duties and responsibilities as s
Q.
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06/29/20 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 special agent on that squad? A. We investigate crimes that involve child sexual abuse material, sextortion, enticement, and exploitation of minors, sex trafficking, international parental kidnappings. MS. I. . Let me just pause here. Can everyone hear the witness? CRANE JUROR. Yes. MS. Okay. Thank you. And Special Agent , if you could just try to keep your voice up, I really appreciate it. It’s a little difficult under the circumstances. BY MS. III: Q. Have you participated in an investigation of Ghislaine Maxwell? A. Yes, I have. Q. Have you spoken to other people, including other law enforcement officers, about this investigation? A. Yes. Q. Have you reviewed reports and documents prepared by others regarding this case? A. Yes. Q. Is your testimony today based in part on those conversations with other law enforcement officers and documents that you have reviewed? A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcripttnn D.C. Area 301-261-1902 Balt. 6 Annap. 410-974-0947

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06/29/20 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ms. Ladies and gentlemen, let me just give you a brief instruction. Some of the testimony that you’ll hear today will include what’s called hearsay. As you know, that means that the witness will not be testifying solely from her own observations, but that she’ll also be reporting to you what others have told her and what she’s read in reports and documents prepared by other people. Hearsay evidence is admissible in these grand jury proceedings, and you’re free to rely on it in determining whether there’s probable cause to indict the proposed defendant. If, however, you would like to hear the testimony of any other witness, you have the right to request it and we will make reasonable efforts to bring that witness before you. BY MS..: Q. Special Agent , we placed on the desk in front of you a PowerPoint that is Grand Jury Exhibit 2, which we’re entering into the record. Do you recognize this? A. Yes. Q. What is it? A. It’s a PowerPoint presentation to assist in testifying today. Q. Did you participate in preparing this exhibit in FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947

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1 connection with your testimony today?
2 Yes, I did.
A.
3 If you could please turn to the first slide.
Who
Q•
4 are the individuals depicted in these photographs?
5 The picture on the left is Ghislaine Maxwell, and
A.
6 the picture on the right is Jeffrey Epstein with
7 Ghislaine Maxwell.
8 Q.
Based on your participation in this investigation
9 and your review of public source materials, have Maxwell and
10 Epstein been photographed together many times over the
11 years?
12 Yes.
A.
13 Based on your participation in this investigation
Q.
14 and your review of public materials, where is Maxwell from?
15 She grew up in the
Maxwell was born in France.
A.
16 United Kingdom, was educated in Oxford, and is from a
17 wealthy family.
18 Q.
Is she a citizen of France, the United Kingdom,
19 and the United States?
20 A.
Yes.
21 Q.
How old is she currently?
22 A.
58.
23 Has the FBI investigated Maxwell and Epstein’s
Q.
24 conduct with minors during the 1990’s?
25 A.
Yes
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1 Q.
Generally speaking, what have you learned about
2 the relationship between Maxwell and Epstein during the
3 1990’s?
4 A.
Epstein and Maxwell had a romantic relationship,
5 and she also worked for him; managing his homes, hiring and
6 firing individuals.
7 Q.
During that time period, was she one of his
8 closest associates?
9 A.
Yes.
10 Q.
During the course of this investigation, have you
11 learned where Epstein maintained properties in the 1990’s?
12 A.
Yes.
13 Where did he maintain properties?
Q.
14 New York, Palm Beach, and New Mexico.
A.
15 Q.
Turning to the next slide, did he maintain an
16 address in Manhattan located at 9 East 71st Street?
17 A.
Yes.
18 Q.
Does this slide fairly and accurately depict the
19 residence?
20 A.
Yes.
21 Q.
Can you please describe that property for the
22 grand jury?
23 It’s a seven story home; it’s located near Central
A.
24 It’s reportedly the largest residence in Manhattan.
Park.
25 Q.
Based on your participation in this investigation,
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1 did that house include a room that was used a massage room?
2 A.
Yes, it did.
3 We’ll talk more about that later, but
Q.
All right.
4 Did he maintain
for now, moving on to the other properties.
5 an address in Palm Beach, Florida, located at 358 El Brillo
6 Way?
7 A.
Yes.
8 Turning to the next slide.
Does this slide fairly
Q.
9 and accurately depict that residence?
10 A.
Yes, it does.
Q.
Could you please describe that property for the
11
12 grand jury?
13 It’s a waterfront estate. It has an in ground
A.
14 pool and a detached dwelling or pool house on the property
15 as well.
16 And from your participation in this investigation
Q.
17 and your review of other materials, did that house include a
18 room that was used as a massage room?
19 A.
Yes.
20 Did Epstein also
Q.
Turning to the next property.
21 own a ranch in New Mexico?
22 A.
Yes, he did.
23 And turning to the next slide.
Was that property
Q•
24 located at 49 Zorro Ranch Road in Stanley, New Mexico?
25 A.
Yes.
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1 Q.
Looking at the photograph on this slide, does this
2 accurately depict that property?
3 A.
Yes, it does.
4 And we’ve been talking about the properties that
Q.
5 Epstein owned during this time period.
Did he also own a
private jet?
7 A.
Yes.
8 Q.
Is it fair to say that he was a multimillionaire
9 during this time period?
10 A.
Yes.
11 During the 1990’s did Epstein have an employee
Q.
12 who ran his house in Palm Beach?
13 Yes, he did.
A.
14 Q.
What was his job?
15 His job was making sure that everything in the
A.
16 He referred he described that
house ran smoothly.
17 Epstein liked to have his house run live a five-star hotel;
18 that everything had to be in its proper place.
So he was
19 responsible for managing that.
20 Q.
Have you interviewed
21 A.
Yes.
22 How many times?
Q.
23 A.
Twice.
24 Q.
And is the information you’re about to provide
25 based on your interviews with
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06/29/20 10 1 2 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 begin working for Epstein in the early 3 1990’s? A. Yes, he did. Q. And at the time came to work for Epstein in Palm Beach, was Epstein dating Ghislaine Maxwell at that point? A. Not at that time. Q. Was it a few years before Epstein began dating Maxwell after started working there? A. Yes. Q. From what told you, how did i s work change once Maxwell arrived on the scene? A. described Epstein as being more pleasant to work with prior to Maxwell coming into the picture. Once she came into the picture, he said things became more secretive. He wasn’t allowed to be in the room with guests, wasn’t allowed to talk with them, associate with them. It became a different environment. Q. You talked about some of the rules that were placed changing. Were there any rule changes about eye contact once Maxwell began staying in the Palm Beach house? A. Yes. wasn’t allowed to make eye contact with Epstein and others. Q. In general, how did he describe what it was like FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. 6 Annap. 410-974-0947

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1 to work for Maxwell?
2 He said she was very demanding; she was on top of
A.
3 him all the time.
He described her as a “bitch.”
4 Is that the word that he used?
Q.
5 That is the word he used.
A.
6 I want to talk to you about
Q.
Shifting gears.
7 someone else that you’ve interviewed during this
8 investigation. During the course of this investigation,
9 have you participated in interviews with an individual named
10
11 A.
Yes.
12 So for these purposes I’m just going to refer to
Q.
13 her as
Is that okay?
14 A.
Yes.
15 How many times have you interviewed
Q.
16 A.
Approximately five times.
17 If you could please just page through the next two
Q.
18 slides in front of you.
Are these photographs of
19 A.
Yes.
20 Is it your understanding that these photographs
Q.
21 from approximately ages 13 to approximately 17?
depict
22 Yes, it does.
A.
23 Let’s take a look at some of those
Q.
Okay.
24 Is
photographs. I’m going to publish the next slide.
25 date of birth
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12
1 A.
Yes.
2 And are these two photographs of
Q.
3 A.
Yes, they are.
4 If you could turn to the second slide of
Q.
5 Are these also photographs of
photographs.
6 A.
Yes.
7 Q.
Based on your participation in this investigation
8 , where was she living when
and your interviews with
9 she was approximately 14?
10 She was living in Palm Beach, Florida.
A.
11 Who was she living with when she was 14?
Q.
12 Her mother and her siblings.
A.
13 What was her whole life like at that time?
Q.
14 At that time, her father had passed away the year
A.
15 prior, so the family was struggling financially and having
16 some difficulties.
17 father do before he passed away?
Q.
What did
18 What was his profession?
19 He was involved in the
A.
20
21 involved in the
Q.
Was
22 A.
Yes, she was.
23 Q.
Were her siblings?
24 A.
Yes.
25 0.
were they involved in?
What
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1 Singing, she was a singer.
A.
2 Like what kind of singer?
Q.
3 A.
Opera.
4 In the summer of 1994, how old was
Q.
5 She was 13 going on 14.
A.
6 You testified earlier that her birthday is in
7 Q.
of 1994?
, so did she turn 14 in
8 A.
Yes.
What did she do that summer?
Q.
10 She attended an arts camp at Interlochen Center
A.
11 for the Arts.
12 And is Interlochen Summer Arts Program located in
Q.
13 Michigan?
14 A.
Yes.
15 Q.
meet Jeffrey Epstein and
Did
lE Ghislaine Maxwell that summer?
17 A.
Yes, she did.
18 Q.
Did she meet them at summer camp?
19 A.
Yes.
20 What did she tell you about that?
Q.
21 She said that she was sitting at a picnic table
A.
22 with friends when Epstein and Maxwell walked by.
They
23 stopped to talk to her, engaged her in conversation, asked
24 her if she liked her classes, her teachers.
During that
25 conversation, they found out that she was also from Palm
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14
1 Beach and that he said that he gives scholarships to
2 students.
3 Was there
How did they leave the conversation?
Q.
4 any contact information exchanged?
5 phone number.
A.
They asked for
6 Q.
As part of your investigation, have you attempted
7 to gather records to corroborate that
, Maxwell, and
8 Epstein were all at that summer camp that summer?
9 A.
Yes.
10 Have
If you could turn to the next slide, please.
Q.
11 you obtained records from Interlochen for the summer of
12 1994?
13 A.
Yes.
14 And what are we looking at on this slide:
Q.
15 This shows who some of the individuals that
A.
16 were there were present for that camp in ’94.
On here is
17 and
and
18 Q.
And have you investigated whether Maxwell and
19 Epstein were also at Interlochen that summer of 1994 as
20 described?
21 A.
Yes.
22 Based on your review of records from Interlochen,
Q.
23 what is your understanding of Epstein’s relationship with
24 Interlochen?
25 My understanding was that he was a donor to the
A.
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1 school.
2 Q.
Did he make any substantial donations?
3 A.
He did.
4 Did he donate a lodge to the camp in the summer of 5
Q.
1994?
6 Yes, he did.
A.
Did he have a long standing relationship as a
Q.
donor to Interlochen?
9 A.
Yes.
1C Is this an excerpt of
Turning to the next slide.
Q.
11 a letter from Interlochen to Epstein?
12 Yes, it is.
A.
13 And does this letter thank Epstein for donating a
Q.
14 scholarship lodge?
15 A.
Yes.
16 Does it invite Epstein to visit in August of 1994?
Q.
17 A.
Yes.
18 In 1994, did Epstein have a private jet?
Q.
19 Yes, he did.
A.
20 Q.
Have you obtained the flight logs for that jet?
21 A.
Yes.
22 Q.
Do those logs include passenger lists and the
23 airport code for the airports that the plane flew into and
24 out of?
25 A.
Yes.
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06/29/20 16 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Turning to the next slide. Is this a page of the flight logs that you’ve reviewed? A. Yes. Q. And on this excerpt of the flight logs where the red arrow is, is that a log entry showing an August 18, 1994 flight to an airport with the airport code TVC? A. Yes. Q• Is TVC the airport code for Cherry Capital Airport in Traverse City, Michigan? car? A. Yes, it is. Q. About how far is that airport from Interlochen by A. It’s about 25 minutes give or take. Q. And who were the listed passengers on this flight? A. Jeffrey Epstein, (ph.), and (ph.). Q. Turning to the next slide. Is this the same excerpt but just with a different arrow? A. Yes. Q. Okay. So a few lines down is there a flight out of Traverse City just two days later on August 20th, 1994? A. Yes. Q. And do the passengers listed in the flight out of Traverse City include the initials G.M.? A. Yes, they do. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947

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1 Are those Ghislaine Maxwell’s initials?
Q.
2 A.
Yes.
3 Q.
Have you obtained any records from Interlochen to
4 indicate that Maxwell was at Interlochen in 1994?
5 A.
Yes.
6 If we could turn to the next slide.
Can you
Q.
7 please explain for the grand jury what we’re looking at on
8 this slide?
9 This was a letter from interlochen explaining
A.
10 addressed to Maxwell telling her that they had found an
11 envelope in the lodge that they had been staying in.
12 Q.
We were talking a few moments ago
All right.
13 described meeting Maxwell and Epstein at
about how
14 summer camp, and you testified that she provided them with
15 explain to you whether or not
her phone number.
Did
16 she had any contact with Epstein or Maxwell after she
17 returned home to Palm Beach?
18 A.
Yes.
19 Q.
When was the next time that happened?
20 A.
Shortly thereafter.
21 Q.
And how did that occur?
22 A.
She was invited to his house.
So her and her
23 mother went to Epstein’s house to visit.
24 Q.
What did
tell you about that visit to
25 Epstein’s house with her mother?
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1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 06/29/20 18 A. She said it was wait, can you rephrase that? Q. Of course. Did go to the house by herself or with her mother? A. With her mother. Q. Okay. And when they went to the house, what did they do there? A. They had tea. Q. Who was there when they had tea at the house? A. Epstein and Maxwell. Q. What did they discuss as they had tea? A. They just talked about her life and, you know, what she wanted to do. Q. Did Epstein make any offers? A. He said that he gives scholarships. He likes to mentor people. Q. How -did mother react when Epstein said this? A. She was happy for her daughter and oftentimes referred to Epstein as Godfather. Q. After that occasion when they went over to the house, thereafter did subsequently begin regularly spending time with Maxwell and Epstein at Epstein’s house in Palm Beach? A. Yes. Q. And did that start when she was approximately age FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Salt. fi Annap. 410-974-0947

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1 14?
2 A.
Yes.
3 Q.
Did it continue until she was about age 17?
4 Yes, it did.
A.
5 Q.
And during those years, did she regularly go over
6 to Epstein’s house in Palm Reach and spend time with Maxwell
7 and Epstein?
A.
Yes.
9 Q.
What happened in the summer of 1997 when
10 was 17 and about to turn 18?
11 A.
She moved to New York City.
12 Q.
Why did she move to New York City?
13 A.
She wanted to pursue a career in acting and
14 modeling.
15 Q.
We’ll talk about that in a moment, but for now
16 want to focus on the years you talked about in Palm Beach
17 from ages 14 to 17 when
would regularly go to
18 Epstein’s house. In the beginning, in the first few months
19 when she went there, what kinds of things did she do when
20 she would visit the house when Maxwell and Epstein were
21 there?
22 They’d hang out by the pool, he they would take
A.
23 her to the movies, take her shopping.
She described the
24 behavior as grooming.
25 When you say grooming, did she explain what she
Q.
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1 2 3 4 5 6 7 A 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 meant by that? A. She meant that they were building a relationship with her, giving her things, taking her places. And then usually when the grooming happens, an offender will – once they gain that trust, they will make the relationship Lurn sexual. Q. Now, you testified just a moment ago that described to you that she felt at this time period that they were grooming her. Is that right? A. Yes. Q. Is that something that she realized at the time when she was 14, or is that something that she’s described to you now? A. Something she’s described now. She didn’t realize that at the time. Q. So we’ll talk a little bit more about grooming in a moment, but just to give context are you familiar with the term grooming based on your experience investigating crimes involving a sexual exploitation of minors? A. Yes. Q. Generally speaking, – you were touching on this a moment ago, but if you just could explain in full. What is grooming? A. Grooming is when someone builds a relationship with a child. They find a vulnerability or a need and then FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 ©alt. & Annap. 410-974-0947

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21
3 they work on gaining a child’s trust, and then oftentimes
2 gaining a parent’s trust.
Once they have that trust, they
show that in ways that they care about them by giving them
4 And then once that’s established, they
gifts and promises.
then turn the relationship sexual, oftentimes making sexual
C comments and normalizing the behavior.
Now, during these visits that you’ve been
Q.
0 describing that
told you about, did
say whether
Epstein ever gave her anything?
10 A.
Yes, she did.
11 Q.
What did he give her?
12 He gave her cash.
Sometimes he’d tell her to give
A.
13 the cash to her mom because he knew that they needed it.
He
14 paid for her voice lessons as well.
lb Now, you were describing how
Q.
has
16 characterized these visits now.
But based on your
17 conversations with her, at the time did she feel that these
18 visits were strange at all?
19 A.
She thought they were strange, but Maxwell
20 normalized it for her.
She was like a cool older sister and
21 made comments like this is what grownups do.
22 Q.
You used the phrase cool older sister.
Is that a
23 phrase that
used to describe how she felt about
24 Maxwell at the time and what Maxwell was like?
25 A.
Yes, those are her words.
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1 Did there come a time these visits when
Q.
2 saw Maxwell topless by the pool?
3 A.
Yes.
4 What did she tell you about that?
Q.
5 She was a little taken back, but Maxwell just
A.
6 acted normal.
7 tell you about an incident several
Q.
Did
8 months into this arrangement when she was alone with Epstein
9 in the pool house?
10 A.
Yes.
11 Q.
And when they were alone together, did Epstein ask
12 what she wanted to do with her life?
13 A.
He did.
14 Q.
What did she say?
15 She said she wanted to be an actress and a model.
A.
16 How did Epstein respond?
Q.
17 He told her that he was best friends with the
A.
18 owner of Victoria Secret. Told her that she would have to
19 have photographs taken and that she got to be comfortable in
20 When she asked what
her underwear, and not to be a prude.
21 that meant, he pulled her to his lap and masturbated.
22 What was her reaction?
Q.
23 She froze.
She felt paralyzed.
A.
24 encounters with
Q.
After this incident, did
25 Epstein begin to include sexual contact?
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1 A.
Yes.
2 Over time, did the sexual abuse escalate?
Q.
3 It did.
A.
4 Q.
From what she’s described to you, did the abuse
5 include Epstein digitally penetrating
6 A.
Yes.
7 Q.
Did it include Epstein using a vibrator on her?
8 A.
Yes.
5 Q.
Did she describe to you that there were times when
10 Epstein would direct
to massage him while he
11 masturbated?
12 A.
Yes.
13 Q.
explain to you what her memories are
Did
14 like of the abuse?
15 A.
Yes.
16 Q.
What did she say about that?
17 She said that it happened so often that it all
A.
18 kinds it all runs together for her.
That it’s hard to
19 separate out some of the different instances of abuse.
20 Q.
You were describing how
explained to you
21 that the abuse began.
Did that occur based on what
22 told you within the first year that she met Epstein and
23 Maxwell?
24 A.
Yes.
25 also describe to you that once this
Q.
Now, did
FREE STATE REPORTING, INC.
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06/29/20
1 abuse started, Epstein would also bring her into his massage
2 room in the house?
3 A.
Yes.
4 And were there times where he did this where there
Q.
5 are other women present including Maxwell?
6 A.
Yes.
7 Q.
abused during those episodes?
Was
8 Yes, she was.
A.
9 a: “
Q.
During these group encounters what were
10 the adult women wearing?
11 They were usually just in their underwear.
A.
12 Q.
Once they were all in the massage room, how would
13 these episodes generally start?
14 They would generally start with one of the girls
A.
15 was usually massaging his feet.
massaging Epstein.
16 Maxwell was kind of teasing the girls; she’d grab the girls’
17 breasts and she would direct the girls on what to do.
18 Q.
When these episodes would start, in general was
19 Epstein generally lying face down on the massage table?
20 A.
Yes.
21 Q.
What_ would happen as things progressed generally
22 speaking trom what she described to you?
23 When Epstein would decide he was kind of done with
A.
24 the regular massage, he would turn over to his back and he’d
25 grab whichever girl he wanted to either touch him or
FREE STATE REPORTING, INC.
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Salt. & Annap. 410-974-0947
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06/29/20
1 whatever girl he wanted to touch.
2 Q.
Did these episodes include sex acts that over time
3 in various instances included Epstein masturbating, Epstein
4 receiving oral sex, and Epstein engaging in intercourse?
5 A.
Yes.
6 Q.
You were describing for a moment what
told
7 you about Maxwell’s role during these group encounters.
8 Would Maxwell sometimes guide the women and give
9 instructions about what to do?
10 A.
Yes, she would.
11 typically do during these
Q.
What would
12 episodes?
13 A.
She would try to not look at Maxwell because she
14 gave off that sister vibe so it felt weird for her.
She
15 would try to be invisible in that room so they would ignore
16 her as much as possible.
17 Q.
was approximately 14
In the beginning when
18 or 15, would she generally begin by just massaging Epstein’s
19 feet?
20 A.
Yes.
21 Q.
Is that something she was told to do?
22 A.
Yes.
23 Q.
you mentioned that she tried to be
Did she
24 Was I believe that was your testimony?
invisible.
25 A.
Yes.
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1 And over time has she described to you that
Q.
2 over time she believes she became more involved in the
3 sexual activity which varied in each encounter?
4 A.
Yes.
5 Were there times let me rephrase that.
How did
Q•
6 you touched on this for a moment, but just to be clear,
7 describe Maxwell’s attitude during these
how did
8 incidents?
It was very casual.
She acted like this was
A.
10 She gave off that vibe to her and yeah.
normal.
11 Did that make her feel more comfortable with what
Q.
12 was happening?
13 It did.
A.
14 sometimes fully nude during these
Was
Q.
15 episodes?
16 A.
Yes.
17 Q.
And during these episodes, did the abuse include
18 s breast?
Epstein touching
19 Yes.
A.
20 Did it include directing
to touch Epstein’s
Q.
21 genitals?
22 A.
Yes.
23 Q.
was approximately 14, does
Beginning when
24 she begin to travel with Epstein and Maxwell to New York
25 City on occasion?
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27
1 A.
Yes, she did.
2 Q.
Was that to the property you testified about
3 earlier? The townhouse on the Upper East Side?
4 A.
Yes.
5 Q.
traveled to New York City, did she stay
When
6 at Epstein’s townhouse in New York City?
7 A.
Yes, she did.
8 Q.
Did she recall that Maxwell and Epstein took her
9 shopping on one of her early trips to New York City?
10 A.
Yes.
11 Q.
Did she remember them buying her anything?
12 A.
She recalled them buying her white cotton
13 Her description was that they were, like, little
underwear.
14 girls underwear.
15 Q.
From ages 14 to 17, did Epstein ask
to
16 periodically fly to New York for weekends at that townhouse
17 in New York?
18 A.
T’m sorry, say it again?
19 Q.
You testified that she began traveling to New York
20 City aL age 14.
Did she then periodically travel to New
21 York City in a similar manner trom ages 14 to 17?
22 A.
Yes.
23 Q.
Were there times when she traveled on those trips
24 when she flew on Epstein’s private jet?
25 A.
Yes.
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28
1 Did she also sometimes fly commercially?
O.
2 Yes, she did.
A.
3 Was Maxwell sometimes present on the trips to New
Q.
4 York?
5 A.
Yes.
6 was sexually
Q.
You testified earlier that
7 Did she describe to you that she was
abused in Palm Beach.
8 also sexually abused on these trips to New York?
Yes, she did.
A.
10 to go on these trips?
Q.
Did Maxwell encourage
11 A.
Yes.
12 what did
tell you about
Q.
What does
13 her memory of how these trips were arranged?
14 She recalled that Maxwell was usually the one that
A.
15 If she was flying commercially,
would schedule her flights.
16 she would schedule the flights, sometimes calling her mother
17 to schedule.
18 Q.
Was that her general impression of how they were
19 arranged?
20 A.
Yes.
21 In addition to the trips to New York City that you
Q.
22 also remember traveling at least
just described, did
23 once to Epstein’s ranch in New Mexico?
24 A.
Yes, she did.
25 Did she remember whether or not she was sexually
Q•
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1 abused in New Mexico?
2 A.
She couldn’t recall.
She couldn’t remember.
3 get to the airport in
Q.
In general, how would
4 Florida when she would fly on Epstein’s jet?
What did she
5 describe to you?
6 Usually a driver
one of Epstein’s drivers would
A.
7 pick her up from her house and take her to the airport.
8 Now, you testified earlier that you reviewed
Q.
9 is that correct?
flight records for Epstein’s private jet.
10 Yes.
A.
11 Q.
And have you reviewed records from the 1990’s to
12 see if that there whether there’s a person named
13 listed on the records?
14 A.
Yes.
15 Turning to the next slide.
Is this an excerpt
Q•
16 from those records?
17 Yes, it is.
A.
18 And does the red arrow point to just one
Q.
19 Does the red arrow point to a November 11th, 1996
moment.
20 flight?
21 A.
Yes, it does.
22 And is this a does this flight log reflect that
Q.
23 it was a flight from Palm Beach, Florida to Teterboro, New
24 Jersey?
25 A.
Yes.
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30
Q.
Is there a private airfield in Teterboro, New
Jersey?
A.
Yes, there is.
Q.
What’s it called?
Teterboro Airport.
A.
Are the passengers listed on this entry J.E.?
O.
A.
Yes.
Q.
Are the do the entries also include
pluL
9 friend, Jeff Schantz (ph.), family,
(ph.) child,
10 (ph.), and
11 A.
Yes.
12 based on your awareness of
Q.
Was
13 date of birth and the date of this flight, was
16 on
14 the date of this flight?
15 A.
Yes, she was.
16 You testified earlier
Turning to the next slide.
Q.
17 What are we looking at on this
about Teterboro Airport.
18 slide?
19 A.
This is directions from Teterboro Airport to
20 Epstein’s residence here in Manhattan.
21 So based on your review of this map, if someone
Q.
22 were to fly into Teterboro Airport and travel to New York
21 City, would they would the most natural root be to travel
24 from Teterboro Airport and crossing into New York through
25 Manhattan?
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31
1 A.
Yes.
2 Q.
Turning to the next slide.
Is this also an
3 excerpt from the flight records that you’ve reviewed?
4 A.
Yes, it is.
5 And does this show a May 9, 1997 flight from
Q.
E Teterboro, New Jersey to Santa Fe, New Mexico?
7 Yes, it does.
A.
Q.
And are the passengers listed on this log J.E.,
9 G.M.,
10 A.
Yes.
11 Based on your knowledge of
birthdate and
Q.
12 have been 16 on the
the date of this flight, would
13 date of this flight?
14 Yes, she would’ve been.
A.
15 Turning to the next slide.
Is this also an
Q.
16 excerpt from the flight records?
17 Yes.
A.
18 And does the red arrow point to a flight entry on 19
Q.
May 3rd, 1998?
2C Yes, it does.
A.
21 Based on the airport codes, does this reflect that
Q.
22 there is a flight on that date from Palm Beach, Florida to
23 Teterboro, New Jersey?
24 A.
Yes.
25 Q.
And are the passengers listed on this log J.E.,
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 06/29/20 32 G.M., E.T., , Glen (ph.), III, (ph.), (ph.), (ph.), (ph.)? A. Yes. Q. Based on your knowledge of birthdate and the date of this flight, would have been 17 on this date? A. Yes. Q. Am I correct that you testified earlier that in addition to sometimes flying on Epstein’s private jet, she also traveled on commercial airlines, is that correct? A. Yes, it is. Q. Based on your review of these flight logs, does every flight entry list the name of every single passenger, or are there times when a passenger is noted female? A. There’s time where a passenger is just noted female. Q. I’m going to talk to you about two examples of that. Turning ahead two slides. Looking at slide 18, does this reflect a January 3rd, 1995 flight where the flight log says J.E., two females? A. Yes, it does. Q. And do the two entries below also just list female next to the initials J.E.? A. Yes, they do. Q. Turning to the next slide, slide 19. Is this FREE STATE REPORTING, INC. Court Reporting Transcription U.C. Area 301-261-1902 Balt. & Annap. 410-974-0947

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33
06/29/20
1 another example of an entry like that?
Focusing on the
2 entry on February 12th, 1995?
3 A.
Yes.
4 Q.
Does that entry also say female?
5 Yes, it does.
A.
6 Q.
Now, you testified that
sometimes flew on
7 commercial airlines and that arrangements for her travel
were made for her to fly commercially for these trips.
Is
9 that right?
10 A.
Yes.
11 Have you been able to obtain commercial flight
Q.
12 records?
13 We were not able to obtain those
A.
We tried.
14 records.
15 Q.
Why is that?
16 A.
Airlines do not keep records past a certain year.
1/ Does
recall group sexualized massages
Q.
16 involving Epstein and Maxwell in both the New York and
19 Florida residences during the time period we’ve been talking
20 about?
21 A.
Yes.
22 Q.
You testified earlier about the time that Epstein
23 and Maxwell would spend together and the activities that
24 they were involved in.
During this time period, did
25 have occasions to talk with Maxwell?
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34
1 She I’m sorry, can you ask the question again?
A.
2 During the beginning when she was 14 when she
Q.
3 began spending time with Epstein and Maxwell and through the
4 often have conversations with Maxwell about
years, did
5 her life?
6 A.
Yes.
7 Q.
Did they talk about that often?
8 They did.
A.
9 about her family, her
Q.
Did Maxwell ask
10 classes, and other aspects of her life?
Yes, she did.
11 A.
12 You testified earlier that just before she turned
Q.
13 Is that right?
moved to New York City.
18,
14 A.
Yes.
15 Did she go to school there in New York City for
Q.
16 her senior year?
17 Yes, she did.
A.
18 What school did she go to?
Q.
19 She went to
A.
20 Q.
What is
21 They cater to individuals who want to pursue
A.
22 careers in the arts.
23 Have you reviewed records from
0 -
24
25 A.
Yes.
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GM_GLSDN Y_00000425

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 19 20 21 22 23 24 25 06/29/20 35 Q. If you could turn to slide 17. Can you please explain for the grand jury what we’re looking at here? A. This is an excerpt from application to III On it is listed who is financially responsible for her, and that is Jeffrey Epstein. Q. From what told you, did Maxwell encourage to accept Epstein’s financial help? A. Yes. Q. When moved to New York City who was she living with? A. She lived with her mother and brother in apartment. Q. Did Epstein help pay for her rent? A. He did. Q. During that year, her senior year of high school when she was in New York City, did remain in contact with Epstein? A. Yes. Q. What was the nature of their contact like during this time period? A. During this time he was still sexually abusing her. Q. Did that continue to occur in his townhouse in Manhattan that year? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947

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1 A.
Yes, it did.
2 What happened at the end of her senior year of
Q.
3 high school?
4 She moved to Los Angeles to pursue a career in
A.
5 acting.
6 Did she get a job as an actress when she was 18?
Q.
7 She did.
A.
8 Q.
Has
lived in Los Angeles and worked as an
9 actress on television ever since then?
10 A.
Yes.
11 After she moved to Los Angeles did she continue
Q.
12 being in touch with Epstein?
13 For a short period of time.
A.
14 Did she ultimately break contact with him?
Q•
15 A.
Yes, she did.
16 Q.
Is
currently pursuing a civil lawsuit
17 against Maxwell and Epstein’s estate?
18 Yes.
A.
19 about whether when she
Have you talked with
Q.
20 was a teenage gill when all of this was happening whether
21 she told anyone that she was being sexually abused?
22 She felt
Yes, she said she didn’t tell anyone.
A.
23 She the nothing was talked about
like she couldn’t.
24 outside of that room, so it made it so that she couldn’t
25 And then she also her mother is Middle
talk about it.
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37
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1 Eastern, and her mother raised her that women are supposed
2 to do what they’re told even if someone is beating you.
3 And when she was 13 and her father passed, she was
4 she went to a guidance counselor at school to talk about
5 it, and her mother found out about it and smacked her.
So
6 she felt like she couldn’t talk to anyone about it.
7 ’s mother encourage her to accept
Q.
Did
8 Epstein’s financial assistance?
9 A.
Yes, she did.
10 Q.
Have you become aware that in 2005, police
11 officers from the Palm Beach Police Department executed a
12 search warrant at Epstein’s house at the El Brill() Way
13 address in Palm Beach?
14 A.
Yes.
lb Q.
Have you reviewed some of the materials seized
16 during the search?
17 A.
Yes.
18 Q.
Did they find massage tables ana sex toys?
19 A.
Yes, they did.
20 Q.
Did they find any photographs of
21 A.
Yes.
22 Q.
Was one of the photographs signed by
23 Yes, it was.
A.
24 Did it say
Q.
25
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1 Yes.
A.
2 During your interviews with
did
tell
Q.
3 you how she felt about Epstein and Maxwell in the ’90’s when
4 she was a young girl?
5 She expressed that she felt like they
A.
She did.
6 That they
loved her, she felt like they were her family.
7 supported her and that she felt she was made to feel like
8 that she needed to be grateful to them.
9 Did she tell you that she felt like they
Q.
Okay.
10 were trying to help her?
11 A.
Yes.
12 about how she feels
Have you talked with
Q.
13 about this now?
14 Yes.
A.
15 demeanor like when she described
Q.
What was
16 to you what Epstein and Maxwell had done to her?
17 She recognized that now, it’s
A.
She was upset.
18 affected her life to a great degree.
She’s struggled in
19 relationships with opening up to people and trusting people,
20 both personal and professional relationships.
21 Did she tell you that she struggled to tell anycne
Q.
22 what had happened to her for most of her adulthood?
23 A.
Yes.
24 When was the first time that you interviewed
Q.
25
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GM_GLSDNY_00000429

06/29/20 39 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Last fall. Q• Was that the first time she’d ever reported this to law enforcement? A. Yes, it was. Q. Now, you testified earlier about your interviews with who worked at Epstein’s Palm Beach house. Did he remember a girl named coming to the house during that time? A. Yes, he did. Q. Did he recall , Maxwell, and Epstein being in the Palm Beach house together? A. Yes. Q. What was his understanding of why was there? A. He thought that Epstein was helping her, that’s what Epstein had told him, and had told him that Epstein was helping her. Q. Did he ever observe Epstein interacting with physically? A. Yes. Q. What did he see? A. He saw Epstein kiss cheek and pat her on the bottom. Q. Did he have any knowledge about what was happening with Epstein or Maxwell when he wasn’t present? A. He didn’t. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. .6 Annap. 410-974-0947

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1 from her
ever recall picking up
Q.
Did
2 house?
3 A.
Yes.
4 And when he would pick her up from her house,
Q.
5 would he then bring her back to the Palm Beach house?
6 Yes.
A.
7 Did he remember who in general would tell him to
Q.
8 from her house?
pick up
9 Maxwell would be the one to tell him to pick her
A.
10 up.
11 to the movies?
Did he recall ever driving
Q.
12 A.
Yes.
13 What did he tell you about that?
Q.
14 That it would usually be Epstein, Maxwell, and
A.
15 They’d go to the movies and it would usually be late
16 at night.
17 Did he tell you about what his memory was about
Q.
18 was?
how old
19 He said she was young and that he knew that
A.
20 because he had picked her up from school and that he knew
21 she was too young to drive.
22 I want to talk to you about a
Switching gears.
Q.
23 . Based
different aspect of your interviews with
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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GKLGLSDNY_0000043I

1
2
3
4
5
6
8
9
10
11
12
A.
Q.
A.
Yes.
What did he tell you about that?
He said that he found sex toys in the massage room
and he had to wash them afterwards.
Q. Aside from those experiences, was he aware of
there being sex toys in the house?
A. Yes. There was a basket of sex toys that were
kept in Maxwell’s closet.
Q. stop working for Epstein in
Did
approximately 2002?
A. Yes.
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. tell you that a few months after he
Did
18 left working fcr 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 tcok several thousand dollars?
25 A. Yes.
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1 Q. Did Epstein discover this and confront him about
2 it?
3 A. Yes, he did.
4 Q. admit to Epstein and the police what
Did
5 he’d done?
6 A. Yes.
7 Q. Did Epstein also tell the police his gun was
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. traveling on the je
Did he remember
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43
1 in the 90’s?
2 A.
He remembered her traveling, but he didn’t
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?
A.
Yes.
8 specifically as
Q.
And did he remember
9 a person who traveled?
IC A.
Yes.
11 Q.
Did you discuss with him the flight records that
12 we talked about earlier that lists a person named
as a
13 passenger?
14 A.
Yes.
15 Q.
Did he have a specific memory of those exact
16 flights?
17 A.
No.
19 But was he aware of any other
flying on the
Q.
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 that
23
was one of the names on that record.
Is that
24 right?
25 A.
Yes.
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44
1 Q.
Is that
2 A.
Yes.
3 Have you interviewed III
Q.
4 Yes, I have.
A.
5 Did he tell you that he remembered
talking
Q.
6 that summer at camp about having met Jeffrey Epstein?
7 A.
Yes.
8 going
Did he tell you that he remembered
Q.
9 over to Epstein’s house in Palm Beach when they were in high
10 school?
11 A.
Yes.
12 would often talk about
Q.
Did he remember that
13 spending time with Maxwell and Epstein during this time?
14 A.
Yes.
15 telling him when they were
Did he remember
Q.
16 in high school about at least one trip to New York City that
17 she took with Epstein?
18 Yes.
A.
19 describing Epstein’s
Did he remember
Q.
20 townhouse in Manhattan?
21 A.
Yes.
22 talking often about
Q.
And does he remember
23 Ghislaine Maxwell?
24 A.
Yes.
25 did he
Now, based on your interviews with
Q.
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06/29/20
1 tell you whether he knew back then when they were in high
2 was being sexually abused by Epstein?
school whether
3 A.
He didn’t know back then.
4 Did III ever meet Ghislaine Maxwell?
Q.
5 A.
Yes, he did.
6 What did he remember about that?
Q.
7 A.
He remembered Epstein, Maxwell, and
being
8 near a movie theatre and he was approximately 16 at the Lime
9 would’ve been 15, and just the little bit of
and
10 And then after that,
had told
interaction they had.
11 him that Maxwell had said something to the effect I could
12 teaci
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 So for today’s purposes I’m just going to refer to
Q.
21 her as
How many times have you interviewed
22 A.
Approximately twice.
23 Q.
Have they
Now, does
know
24 ever met as far as you know?
25 A.
As far as I know, no.
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06/29/20 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Turning to the next slide. Are these photographs of when she was in high school? A. Yes. Q. And is her date of birth A. Yes. Q. When was approximately 16 and a junior in high school, where was she living? A. She was living in with her mother. Q. Does she have any siblings? A. An older sister. Q. What did her older sister do? A. Her older sister lived – worked for Epstein. Q. Where did she work for Epstein? A. Here in New York. Q. Did there come a time in approximately December 1995 when had a phone conversation with her sister about traveling to New York City? A. Yes. Q. What did they discuss? A. They discussed her coming to New York and meeting Epstein. Q. What did her sister tell about why she should meet Epstein? A. She said that he could help her with college. Q. And did she say – did the sister say whether the FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. S Annap. 410-974-0947

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1 sister wanted her to meet Epstein or did she say whether
2 Epstein wanted to meet
3 Epstein wanted to meet
A.
4 Now, let me just pause here.
Q.
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 So is this approximately the same time period
Q.
10 telling you happened?
while what you described
11 A.
Yes.
12 So in January of 1996, did
fly on a
Q.
13 commercial airline to New York City to spend a weekend with
14 her sister and meet Jeffrey Epstein?
15 A.
Yes.
16 Did she tell you that?
Q.
17 A.
Yes.
18 Q.
tell you that she met
During the trip, did
19 Epstein at his townhouse in New York City?
20 A.
Yes, she did.
21 Did she tell you that Epstein discussed her plans
Q.
22 for college applications and offered to help her?
23 A.
Yes.
24 first impression of
What was
Q.
25 Jeffrey Epstein?
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1 She was very impressed by him.
A.
2 What did she what was her impression based on
Q.
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 During that trip to New York City, did she stay at
O.
7 Epstein’s townhouse or at her sister’s apartment?
8 A.
Her sister’s apartment.
9 During that trip, did she tell you that she saw
Q.
10 Epstein a second time when he took
and her sister to
11 the movies?
12 A.
Yes.
13 What did she tell you happened at the movies?
Q.
14 She said that they were sitting in the theatre and
A.
lb and her sister, and Epstein put
Epstein was between
16 his hand on her leg, he rubbed her arm and held hands with
17 her.
18 From what she told you what was her impression
Q.
19 about whether her sister could see what was going on?
20 She felt like her sister couldn’t see.
A.
21 What was her reaction to this happening?
Q.
22 She was uncomfortable.
A.
23 After the movie did she tell her sister what had
Q.
24 happened?
25 No, she didn’t.
A.
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06/29/20
1 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.
S 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 O.
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
’s
17 impression of who would be on this trip to New Mexico?
18 A.
She knew Maxwell would be there.
19 Did she was she told anyone else was going to
Q•
20 be present during this trip?
21 A.
She said that there would be, like, other students
22 her kids her age.
23 And what was her understanding of who these other
Q.
24 kids were and why they’d be there? Sorry, let me
25 A.
Rephrase.
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1 2 3 4 5 6 7 0 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 06/29/20 50 Q. rephrase the questions. You testified that she was told that on this trip that there would be other students. Was she under the impression that there would be other young students like her on the trip who were also being mentored by Epstein? A. Yes. Q. Now, you testified just a moment ago that she was also told that Maxwell would be there. Are you referring to Ghislaine Maxwell? A. Yes. Q. At the point that she was told that Ghislaine Maxwell would be on this trip, had she ever met Ghislaine Maxwell? A. No, she hadn’t. Q. Had she heard her sister Calk about Ghislaine Maxwell? A. Yes. Q. How did – from what she described to you, how did her expectation that Maxwell would be on this trip make her feel about the trip? A. It made her comfortable. Her sister had talked highly of Maxwell. Q. Did tell you that she flew to New Mexico that spring when she was 16? A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Halt. 6 Annap. 410-974-0947

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51
1 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 She described Maxwell as being very charming.
She
A.
7 gave her a tour of the house and Maxwell took
8 shopping, which made her feel special.
9 What does she remember talking about with
Q.
10 Ghislaine Maxwell?
11 They talked about school, homework, trips.
A.
12 Did she talk with her about applying to college?
Q.
13 A.
Yes.
14 Did she talk about her classes in high school?
Q.
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 Did she talk with Maxwell about her family?
Q.
20 Yes.
A.
21 Q.
Did she talk with her about her home life and
22 living with her mother?
23 Yes.
A.
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 Was it just the three of them the entire weekend
Q.
4 of the visit?
5 A.
Yes.
6 Were there any other school kids there?
Q.
7 A.
No.
Q.
When they were at the ranch, from what
told
9 about massages?
you, did Maxwell say anything to
10 A.
Yes.
11 Did she say anything to her about foot massages?
Q.
12 A.
Yes.
13 Q.
What did
tell you about that?
14 to give Epstein a foot massage,
Maxwell told
A.
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 tell you what Maxwell and Epstein took
Q.
Did
19 her to the movies that weekend?
20 A.
Yes.
21 What did she tell you about that trip to the
Q.
22 movies?
23 She said that when they went outside the theatre
A.
24 Maxwell was joking around and pulled Epstein’s pants down a
25 And then once they went inside the theatre,
little bit.
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53
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 Lo hide it from
4 Maxwell.
C 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?
A.
Yes.
1C 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 arid 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 She felt really uncomfortable
A.
2C Q.
also tell you about an incident that
Did
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 So he laid down
room and told her that he wanted to cuddle.
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54
1 She told him she had to go to
next to her and spooned her.
2 the bathroom to get out of the situation.
3 What was her reaction to that when Epstein got
Q.
4 into her bed?
5 She was uncomfortable. She didn’t know what to
A.
6 do.
7 Q.
go back home to Arizona when the weekend
Did
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 Is that for the same reason you described earlier?
Q.
14 A.
Yes.
15 to go on a
Q.
Did Epstein end up paying for
16 trip to Thailand that summer?
17 A.
Yes.
18 Q.
have any contact with Maxwell or Epstein
Did
19 after that trip?
20 A.
Not that she recalled.
21 what was her demeanor
Q.
When you interviewed
22 like when she described her interactions with
23 Jeffrey Epstein and Ghislaine Maxwell?
24 She became upset, emotional.
A.
25 currently pursuing a civil lawsuit
Is
Q.
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06/29/20 55 1 2 3 4 5 6 7 9 lc 11 12 13 14 15 16 17 18 19 2C 21 22 23 24 25 against Maxwell and Epstein’s estate? A. Yes, she is. Q. What does do for a living now? A. She’s a psychologist who works with trauma victims. Q. During the course of this investigation, have yn interviewed someone named A. Yes. Q. For today’s purposes, I’m just going to refer to her as . How many times have you interviewed approximately? A. Approximately three times. Q. Turning to the next slide. Is this a photograph of that she provided to you? A. Yes. Q. And did she tell you that this was taken when she was in – approximately 16 or 17 years old? A. Yes. Q. Is ’s date of birth A. Yes. Q. Did grow up in England? A. Yes, she did. Q. Did she tell you that there came a point when she met Ghislaine Maxwell when she was about 17? A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. d Annap. 410-974-0947

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3
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7
8
9
56
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Q.
How did she tell you that they met?
She said they met through a mutual friend.
A.
Did she tell you that this would’ve happened in 4
Q.
around 1994 or 1995?
A.
Yes.
And is that within the same time period that we’ve
Q.
been talking about today?
A.
Yes.
Q.
What happened after she was introduced to
10 Ghislaine Maxwell from what she told you?
11 She said Maxwell treated her like they were
A.
12 Her quote was, “like naughty school girls” is how
sisters.
13 Maxwell treated with her.
14 Did she tell you that Maxwell seemed to
Q.
15 immediately take an interest in her?
16 A.
Yes.
17 Did she tell you that they began spending time
Q.
18 together in London?
19 A.
Yes.
20 And just to be clear, was Maxwell in her 30’s
Q.
21 while this was happening?
22 A.
Yes.
23 Did Maxwell did
ever remember Maxwell
Q.
24 ever talk about having a boyfriend named Jeffrey Epstein?
25 A.
Yes.
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1 Q.
What did she tell
about that?
2 that Epstein was going to
A.
Maxwell told
3 like her.
4 Q.
Did there come a time when she was 17 that
5 described that Maxwell introduced her to Jeffrey Epstein?
6 A.
Yes.
7 How did she describe that occurring?
Q.
8 Epstein had flown to London. He was at Maxwell’s
A.
So
residence in London and Maxwell had called
over.
10 went over and when she got there, Maxwell was saying
11 to Epstein kind of the words
used was giving him
12 Saying she’s so pretty, she’s
a resume of her attributes.
13 so strong, and then Maxwell asked her to give Epstein a
14 massage.
15 Now, you testified just a moment ago that Maxwell
Q.
16 that
described to you that Maxwell asked her to
17 /s tha
give Epstein a massage during this first meeting.
18 correct?
19 A.
Yes.
20 Did Maxwell say to her in sum and substance since
Q •
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 said to you in sum and
Is that what
Q.
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06/29/2
:
1 substance?
2 A.
Yes.
3 remember Maxwel:
Q.
When that happened, did
4 leading her to a room in the house?
5 A.
Yes.
6 Q.
What happened?
7 went in the room, Epstein was in a
A.
When
8 Me took his robe off and she started massaging him,
robe.
9 and pulled her hand to his
and then he touched
10 penis.
11 Q.
remember Epstein saying when he
What does
12 did this?
13 Don’t be frigid.
A.
14 What was her reaction to this happening from what
Q.
lb she told you?
16 She was taken back by it.
A.
17 left the room
Q.
When this episode ended and
18 did she tell you that she remembered Maxwell being just
19 outside the room when she left?
20 A.
Yes.
21 Did she remember Maxwell saying to her, did you
Q•
22 Did he like it?
have fun?
23 A.
Yes.
24 Does she remember Maxwell calling her several days
Q.
25 afterwards or at some short period of time afterwards?
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1 A.
Yes, she did.
2 remember Maxwell saying to her on the
Q.
Did
3 phone call in sum and substance, well, aren’t you a clever
4 girl, Jeffrey was very impressed?
5 A.
Yes.
C Q.
Shortly after this incident, does she remember
7 Maxwell asking her to come back over to the house?
A.
Yes.
9 And when she got there did she tell you she
Q.
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 Does she remember Maxwell bringing her up the
Q.
14 stairs to the house on that occasion?
15 A.
Yes, she did.
16 What does she remember happening when Maxwell
Q.
17 opened the door to the room?
18 A.
Epstein was standing there nude.
19 Does she remember Maxwell then saying I’ll leav
Q.
20 you guys to it?
21 A.
Yes.
22 After these first two encounters, did Epstein and
Q.
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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1 Yes, they did.
A.
2 Does she remember whether these trips began before
Q.
3 or after her 18th birthday?
4 She couldn’t remember specifically.
A.
5 Before these trips started, you were describing
Q.
6 told you about the time that she spent
earlier when
7 with Maxwell when they first met when she was 17. Is that
8 right?
9 A.
Yes.
10 During these conversations when she would spend
Q.
11 remember talking with her
time with Maxwell, did
12 about her life and her family, and her personal
13 circumstances with Maxwell?
14 A.
Yes.
lb Now, you testified a moment ago that
told
Q.
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 describe to you that Epstein sexually
Q.
Did
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 Yes.
A.
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1 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 Maxwell wasn’t in the room.
A.
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 Did she also tell you that she remembers Maxwell
Q.
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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 06/29/20 62 Q. Did tell you about an incident that occurred after she turned 18 in Palm Beach when she was staying at the Palm Beach house? A. Yes. Q. Did the incident she described to you involve a school-girl outfit? A. Yes, it did. Q. Could you please describe for the grand jury what told you about that incident? A. said that Maxwell had shown her to a bedroom and on the bed was a school-girl outfit and Maxwell told her when – confronted her about it and Maxwell said ‘well, I thought it would be adorable if you gave Jeffrey his tea in this.’ So felt like she had to put it on so she put it on, took Epstein his tea, and Epstein then slapped her on the buttocks and reached under the skirt and touched her. Q. What was her demeanor like when she described this incident to you? A. She was crying; she was very upset. Q. When described seeing the school-girl outfit and talking to Maxwell about it, did she remember Maxwell telling her ‘don’t be so frigid?’ A. Yes. Q. Does she remember that later in the day, after she FREE STATE REPORT:NG, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. fi Annap. 410-974-0947

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1 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 Does she remember Maxwell saying, in sum and
Q.
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 Does she remember Maxwell saying, when she asked
Q.
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 did she tell you
Q.
From your interviews with
23 that there came a time when she was in her early 2Os when
24 she stopped traveling with Maxwell and Epstein?
25 A.
Yes.
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1 Q.
Was she struggling with substance abuse at that
2 point?
3 Yes, she was.
A.
4 Did she tell you that she got sober in her 20s?
Q.
5 Yes, she did.
A.
6 What is her current profession?
Q.
7 She runs a non-profit for people who struggle with
A.
8 addiction and trauma.
9 Q.
provide you with several emails that
Did
10 she exchanged with Epstein in the early 2000s?
11 Yes, she did.
A.
12 Q.
And were those emails very friendly in tone?
13 Yes, they were.
A.
14 What did she say to you when you talked with her
Q.
15 about those emails?
16 She said she didn’t, at the time, want to
A.
17 acknowledge what was going on to her; that looking back on
18 it’s different.
19 Did your squad at the FBI execute a search warrant
Q.
20 at Jeffery Epstein’s townhouse in Manhattan in July 2019?
21 A.
Yes.
22 Did you personally participate in the search of
Q.
23 Epstein’s residence?
24 A.
Yes, I did.
25 Did the townhouse include a massage room?
Q.
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1 Yes.
A.
2 Have you yourself been in that massage room?
Q.
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 There was a massage table.
There were oils.
windows.
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 that
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 And to be clear, did the FBI find sex toys during
Q.
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 is that right?
and
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06/29/20 66 1 2 3 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. Have you reviewed the proposed indictment, marked Grand Jury Exhibit_ 1? A. Yes, I have. Q. Is the individual referred to as Victim 1 in the proposed indictment? A. Yes. Q. Is the individual referred to as Victim 2 in the proposed indictment? A. Yes. Q. Is the individual referred to as Victim 3 in the indictment? A. Yes. Q. During all of Maxwell’s interactions with the victims when they were underage girls, based on the timeframe and your knowledge of Maxwell’s birth date, was she in her 30s? A. Yes, she was. Q. Just one moment. All right. Switching gears. Have you become aware that in or about 2016 Maxwell gave sworn testimony in a civil deposition in connection with a lawsuit? A. Yes. Q. Could you please explain for the grand jury what is a deposition? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947

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1 It is a statement made under oath.
A.
2 And in the course of civil litigation is it common
Q.
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, 1 want to talk with you about the lawsuit that
15 Have you become aware that in or
the testimony was about.
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 against
Q.
Was the lawsuit captioned
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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1 Generally speaking, in broad strokes, what was the
Q.
2 was bringing
What was the claim that
lawsuit about?
3 against Maxwell?
had stated that she had been sexually
4 A.
5 Maxwell came
abused by Epstein and Maxwell as a minor.
6 So
sued
forward publically and called her a liar.
7 her for defamation.
8 So just a small legal instruction on
MS.
9 Ladies and gentleman, I instruct you that the
this topic.
10 allegations in the lawsuit are not being presented to you as
11 I instruct you that
evidence that those incidents occurred.
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. III:
18 Did Maxwell’s
Turning back to the deposition.
Q.
19 deposition take place over two different days?
20 Yes.
A.
21 On both days did she give testimony in Manhattan?
Q.
22 A.
Yes, she did.
23 Is that where the deposition took place?
Q.
24 Yes.
A.
25 And on both days was Maxwell sworn under oath?
Q.
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1 A.
Yes.
9 Q.
IE 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?
A.
Yes.
6 Turning to the next slide, is this the cover page
Q.
7 of the transcript of the first deposition that took place on
8 April 22, 2016?
9 A.
Yes.
10 And does it have the case caption on it?
Q.
:1 Yes, it does.
A.
12 Turning to the next slide, is this an excerpt from
Q.
13 the transcript?
14 A.
Yes.
15 Q.
I imagine the grand juries can’t read it from
:6 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 Answer: “I don’t know what you are talking about.”
A.
24 Just to be clear with the question and answer, is
Q.
2S the answer here Maxwell’s testimony?
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1 A.
Yes.
2 Just to be clear, you testified earlier that
Q.
3 participated in sexualized massages with Epstein and
4 Maxwell; is that right?
5 A.
Yes.
6 was a minor when that occurred?
Q.
And
7 A.
Yes.
8 Q.
And did you also testify earlier that Maxwell
told you that Maxwell asked her to
that
10 give Epstein massages when she was a minor?
11 A.
Yes.
12 If you could turn to the next slide, please.
Q.
Is
13 this another excerpt from that same deposition?
14 A.
Yes, it is.
15 I’ll read the question and you can
Q.
All right.
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 Maxwell’s answer: “I’m not aware of anybody that I
A.
21 , who was 17
interacted with, other than obviously
22 at this point.”
23 Just to be clear, you testified earlier about two
Q.
24 girls under the age of 18 who interacted with Maxwell at
25 Epstein’s properties; is that correct?
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1 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.
Ts
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 Maxwell’s answer: “No, not that I recall.”
A.
23 “Do you know whether Mr. Epstein possessed sex
Q.
24 toys or devices used in sexual activities?”
25 There’s an objection from the lawyer.
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1 Maxwell’s answer: “No.”
A.
2 Just to be clear, you testified earlier that
Q.
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 Yes, that’s correct.
A.
7 And is it correct that you testified earlier that
Q.
is that
Epstein had used a vibrator on
9 correct?
10 A.
Yes, that’s correct.
11 And did you also testify earlier that
Q.
12 told you he did that, as well?
13 A.
Yes, that’s correct.
14 And did you also testify earlier that sex toys
Q.
15 were found by the police in the Palm Beach house in 2005; is
16 that right?
17 A.
Yes.
18 And did you also testify earlier that the F8T
Q.
19 found sex toys in Epstein’s New York City townhouse in 2019?
20 A.
Yes, that’s correct.
21 If you could please turn to the next slide.
This
Q.
22 Is this are these also excerpts from that
is on page 27.
23 same deposition?
24 A.
Yes.
25 Again, I’ll read the questions if you could please
Q.
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 read the answers. Questions: “Other than yourself, and the blonde and brunette that you have identified as having been involved in three-way sexual activities, with whom did Mr. Epstein have sexual activities?” There’s an objection from the lawyer. A. Maxwell’s answer: “I wasn’t aware that he was having sexual activities with anyone when I was with him other than myself.” Q. Question: “I want to be sure that I’m clear, is it your testimony that in the 1990s and 2000s you were not aware that Mr. Epstein was having sexual activities with anyone other than yourself and the blonde and brunette on those few occasions when they were involved with you?” A. Maxwell’s answer: “That is my testimony. That is correct.” Q. Have you reviewed the deposition transcript – A. Yes. Q. – in full? Now, the excerpt we just read has a reference to a blonde and brunette. Are those individuals completely different from the individuals we’ve been talking about today? A. Yes. Q. Just to be clear, is it correct that you testified earlier that and told you that Epstein FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947

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1 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 Yes, that’s correct.
A.
7 Turning to the next slide, is this also an excerpt
Q.
8 from the same deposition?
9 A.
I’m sorry?
10 I’m so sorry. Turning to the next slide, on page
Q.
1 1 28, is this also an excerpt from the same deposition?
12 Yes.
A.
13 Again, if we could read that
Okay.
Q.
Thank you.
14 together I’ll take the question if you could take the
Is answer.
16 Is it your
Question: “Let’s just tie that down.
17 testimony that you’ve never given anybody a massage?”
18 Maxwell’s answer: “I have not given anyone a
A.
19 massage.”
20 “You never gave Mr. Epstein a massage; is that
Q.
21 your testimony?”
22 Maxwell’s answer: “That is my testimony.”
A.
23 a massage; is that
“You never gave
Q.
24 your testimony?”
25 Maxwell’s answer: “I never gave
a
A.
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06/29/20 75 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 it 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. IN 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
8 Date
Acting Grand Jury Reporter
9 Free State Reporting, Inc.
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