Draft: efta00068582

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: x 20 CR 330 (AJN) Jury Trial New York, N.Y. November 30, 2021 8:50 a.m. HON. ALISON J. NATHAN, APPEARANCES DAMIAN United States Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and-BOBBI C. STERNHEIM -and-RENATO STABILE Also Present: District Judge, FBI NYPD Sunny Drescher, Paralegal, U.S. Attorney's Office Ann Lundberg, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300¶

	(Jury not present)
	THE COURT: Looks like we have everybody. Matters to
	take up, counsel.
4	MS. COMEY: Nothing from the government, your Honor.
5	MR. EVERDELL: Nothing, your Honor, but note we have
6	put the folders under the chairs as we agreed yesterday.
7	And the government has seen -- well, I THE COURT:
8	guess you didn't see them, but you are aware of them?
9	We have seen the outside of the folders, MS. COMEY:
10	your Honor.
11	Mr. Everdell, there are two folders. THE COURT:
12	MR. EVERDELL: There is one folder with two documents.
13	THE COURT: One folder with two documents. And then,
14	as we discussed, he'll direct us as necessary to make sure
15	everybody can follow along.
16	I think the only thing I wanted to raise is that,
17	assuming the timing works out, I would like to speak with the
18	juror who had the trip planned, with the court reporter
19	present, of course, to see if there is additional information
20	about the ability to change that plan to make sure it's not
21	weighing on my mind. Without objection to that?
22	MS. COMEY: No objection, your Honor.
23	MR. EVERDELL: No objection, your Honor.
24	So if they're here a little on the early THE COURT:
25	side, I'll do that before, otherwise I'll do it at the break.

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300¶

	MS. STERNHEIM: Judge, I have an issue I would prefer
	to raise at sidebar very quickly.
	THE COURT: Okay.
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	(In open court)
	I'll note I received a report from the THE COURT:
	district executive office that, once again, today, everyone
4	who's appearing to watch the trial is being accommodated,
5	either in this court or in the overflow courtrooms. There are
6	empty seats available for everybody who wishes to observe the
7	public trial.
8	With that, anything else before we wait for the
9	jurors?
10	MS. COMEY: No, thank you, your Honor.
11	MR. EVERDELL: No, your Honor.
12	THE COURT: Thank you so much.
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SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300¶

(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 is, I think, more concerned about the spouse's reaction. At one point, they did say, "If I have to proceed, I can. I understand." On the other hand, they mentioned some level of distraction and concern.¶

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So, I'll hear your suggestion.¶

MR. PAGLIUCA: Your Honor, I understood that the Court was going to -- there were two options the Court was considering. One was seeing if the juror could change plans, and if that didn't work, the Court was considering breaking for the juror's anticipated vacation. That's what I understood the Court to say.¶

If the juror can't change the plans, our preference would be, not frankly that we want to delay the trial, but my preference would be to keep the juror and accommodate the juror's travel plans, your Honor.¶

MS. COMEY: Your Honor, the government's preference would be to keep the trial moving, keep the trial days as scheduled, and excuse the juror if those days become necessary for this case.¶

24 25 THE COURT: Just to be clear about what we're talking about. So given the holiday, we're not going to sit the 23rd¶

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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 break in the trial. I don't think that makes sense, Mr. Pagliuca. I know I mentioned that, but I'm not sure I had that fully in mind at the time, and that's practically what we would be talking about.¶

MR. PAGLIUCA: I appreciate that, your Honor. Again, I frankly don't want to delay this trial. The intention here is, first, I don't know which juror this is, and that would make a difference in my analysis here, frankly.¶

THE COURT: I mean, to be candid, that's why I'm not telling you, because -- I'm not telling either side because 1 think under the veil of ignorance is a better place for everybody to be.¶

17 19 20 22 23 MR. PAGLIUCA: Let me be more specific, your Honor. I'm not asking to know the specific juror, but what would make a large difference to me is whether this person is in the alternate pool versus the main pool of jurors. I would have less of a problem excusing the juror if the juror was in the alternate pool as opposed to the main pool. And the reason 1 say that is we carefully exercised peremptory challenges in this case, both to the main pool and the alternate pool. Had we understood that if this juror's plans couldn't be changed, we would have made a different choice while the entire venire¶

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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 opposed to doing something else. That would have been the choice we would have made at that point.¶

THE COURT: But you actually had that option with this information available to you yesterday. The government supported that move of having seven alternates and you declined that option. So even with the information that we might face this issue, you chose not to go that route.¶

MR. PAGLIUCA: But, your Honor, my view, that's because we understood that the Court was not going to excuse the juror. That was my clear understanding. The transcript says whatever it says.¶

THE COURT: Fair enough. It was not with a 10-day pause in the trial in mind, and I suppose the new information is the juror telling me that there is some level of distraction as a result of this concern, which was not what was indicated yesterday when the discussion was that they would make every effort to try to move it. Having apparently now made that effort, they can't move it.¶

22 23 MR. PAGLIUCA: I understand, your Honor. I think my position is clear and the Court will do as the Court sees fit.¶

24 25 THE COURT: I don't want to do a 10-day break in the middle of the trial. That doesn't make sense. I think,¶

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 have to excuse the juror. I'll have a discussion in which I just say one more time, is there anything else to explore regarding cancellation or moving it, and if the answer to that is no, I think I will excuse the juror. I'll step down. (Continued on next page) (Pages 134 to 136 SEALED)¶

	(In open court)

	THE COURT: I had an additional conversation with the
	He was confident there was no way to move it. He said juror.
4	he could cancel it, they would lose money, it was a burden, he
5	was distracted by it, so I had to excuse juror number 58.
6	All our other jurors are here. They're just finishing
7	up settling in. So we can proceed as soon as Ms.
8	brings them out.
9	Anything to take up?
10	MS. COMEY: No, thank you, your Honor.
11	MR. EVERDELL: No, your Honor.
12	THE COURT: I think they'll be ready momentarily. So
13	I'll sit.
14	Your Honor, would you like the witness in MS. COMEY:
15	the witness box?
16	THE COURT: That would be great. Thank you.
17	(Witness present)
18	We need about two more minutes.
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SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300¶

	13 - direct LBUCmaxl

	(Jury present)
	I hope THE COURT: Thank you, members of the jury.
	Thank you so much for being here you had a pleasant evening.
4	ready to go on time. I greatly appreciate it. We will resume
5	with the direct examination of Mr.
6	Mr. , I remind you are under oath.
7	THE WITNESS: Thank you, your Honor.
8	THE COURT: Ms. Comey, you may proceed.
9	MS. COMEY: Thank you, your Honor.
10	, resumed.
11	DIRECT EXAMINATION CONTINUED
12	BY MS. COMEY:
13	Good morning, Mr. Q.
14	A. Good morning, Ms. Comey.
15	Q. I'd like to pick up where we left off yesterday talking
16	about Mr. Epstein's employees and his office.
17	THE COURT: Ms. Comey, could you adjust the microphone
18	a little bit higher
19	MS. COMEY: Yes. Thank you, your Honor. Is this
20	better?
21	THE COURT: Yes, that's better.
22	MS. COMEY: Thank you, your Honor.
23	, I'd like to pick up where we left off Q. Mr.
24	yesterday talking about Mr. Epstein's office and his employees.
25	A. Yes.

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	Based on your interactions with and observations of Q.
	Mr. Epstein's employees, where in the hierarchy did Ms. Maxwell
	fall?
4	Ms. Maxwell was number 2. It was definitely Mr. Epstein A.
5	was a big number 1.
6	What makes you say that Ms. Maxwell was the number 2 in Q.
7	your experience?
8	A. She was the one that pretty much handled most of the
9	finance, my expenses, spending in the office.
10	What, if any, assistants did Mr. Epstein have, other than Q.
11	Ms. Maxwell?
12	As far as secretaries or personal assistants, is that what A.
13	you mean?
14	Q. Personal assistants.
15	He had an array of personal assistants, almost like A.
16	professional shoppers, because there was a lot of items that
17	needed to be purchased for all of the properties that were
18	being acquired. So there were several people that were
19	personal assistants.
20	Q. How about Ms. Maxwell, did she have personal assistants?
21	A. Yes, I would consider Ms. Maxwell a personal assistant.
22	My question was, did Ms. Maxwell have her own personal Q.
23	assistants.
24	A. Oh, I see. Yes, she had assistants, as well.
25	Q. What were the names of some of the personal assistants you
	SOUTHERN DISTRICT REPORTERS, P.C.

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	- direct LBUCmax1
	remember?
	or we're talking 1994 to '04? Throughout the entire A.
	Yes. Q.
4	The first one that comes to mind would be A.
5	, the last name Then there was another woman named
6	Those are the two that are coming to mind right escapes me.
7	away.
8	About when did you meet Q.
9	It had to have been the late '90s to my recollection. A.
10	look like between when you first met Q. What did
11	her and the mid 2000s?
12	She looked the same except for different hair lengths and A.
13	maybe a little different hair color.
14	Ms. Drescher, I would like to please pull MS. COMEY:
15	up for the witness, the parties, and the Court Government
16	Exhibits 327 and 310, please.
17	, do you recognize these? Mr. Q.
18	Yes, I do. A.
19	What are they? Q.
20	with the green The photo on the left is Ms. A.
21	And then to the right in the photo, it's actually a dress.
22	Then there is photo of myself at the front of the aircraft.
23	in the photo. Mr. Epstein. And that's also
24	Your Honor, the government offers these MS. COMEY:
25	two exhibits in evidence.

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	- direct LBUCmaxl
	No objection. MR. EVERDELL:
	THE COURT: Government Exhibit 327 and 310 are
	admitted. You may publish.
4	(Government's Exhibits 327, 310 received in evidence)
5	MS. COMEY: Thank you, your Honor.
6	BY MS. COMEY:
7	Q. While Ms. Drescher puts these up on the screen for the
8	jury, Mr. , could you tell us, for Government Exhibit
9	310, the photo on the right, could you tell us what we see in
10	that photo?
11	In that photo, that's the one with the aircraft in it? A.
12	Yes. Q.
13	That appears to be a photo of -- it was probably the late A.
14	'90s, mid to late '90s, Mr. Epstein purchased that twin engine
15	Cessna 421, and he had a runway at the ranch. So that photo
16	appears to be taken at the ranch at one of the ends of the
17	runway, judging by the square, you know, the asphalt bottom
18	with the square on top there, because it was a dirt runway and
19	at the end of the runway, there was an asphalt base to turn the
20	aircraft around.
21	But in the photo, obviously, it's a picture of me with
22	the luggage and Mr. Epstein and Ms.
23	MS. COMEY: We can take that down, Thank you.
24	Ms. Drescher.
25	I would like to now pull up for the witness, the

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	- direct LBUCmaxl
	Court, and the parties Government Exhibits 334 and 335, please.
	Do you recognize these, Mr. Q.
	A. Yes, I do.
4	Who do we see starting in Government Exhibit 334, the one Q.
5	on the left?
6	A. The one on the left is a picture of Ms. Maxwell and to the
7	right of her is a photo of Ms.
8	How about Government Exhibit 335, who do we see in that Q.
9	exhibit?
10	A. The same, Ms. Maxwell on the left and Ms. on the
11	right.
12	MS. COMEY: Your Honor, the government offers these in
13	evidence.
14	MR. EVERDELL: No objection.
15	THE COURT: Government 334 and 335 are admitted and
16	you may publish.
17	(Government's Exhibits 334, 335 received in evidence)
18	MS. COMEY: Thank you, your Honor.
19	Ms. Drescher, could we please put those up for the
20	We can take those down. jury. Thank you.
21	, about when do you recall first visiting Q. Mr.
22	Mr. Epstein's ranch in New Mexico?
23	I believe the ranch -- his ranch was purchased in A.
24	approximately 1994. I'd call it the mid '90s.
25	About how often did you visit that ranch during your Q.

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	employment with Mr. Epstein?
	A. I visited that ranch every visit that Mr. Epstein had to
	the ranch.
4	And about how often did Mr. Epstein go to the ranch? Q.
5	It wasn't that often. Certainly not enough. It was A.
6	probably, maybe five, six times a year.
7	Q. What was that ranch called?
8	It was called Zorro Ranch. A.
9	MS. COMEY: Ms. Drescher, would you please pull up
10	Government Exhibit 328 for the witness, the Court, and the
11	parties.
12	Do you recognize this? Q.
13	A. Yes, I do.
14	Q. What is it?
15	That is a photo of the entrance driveway to Mr. Epstein's A.
16	main property on Zorro Ranch.
17	Is this a fair and accurate depiction of a portion of Q.
18	Mr. Epstein's property in New Mexico?
19	A. Yes, it is.
20	Your Honor, the government offers this in MS. COMEY:
21	evidence.
22	MR. EVERDELL: No objection.
23	THE COURT: Government 328 is admitted and you may
24	publish.
25	(Government's Exhibit 328 received in evidence)

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	LBUCmaxl
	Thank you, your Honor. MS. COMEY:
	Ms. Drescher, could we please show this to the jurors.
	BY MS. COMEY:
4	, would you please describe the While that's up, Mr. Q.
5	ranch property that Mr. Epstein owned in New Mexico.
6	The property in general, the whole -- A.
7	Yes, please, the whole property. Q.
8	You started entering the ranch off of The whole property. A.
9	So you drove down a dirt Highway 41 in Stanley, New Mexico.
10	road approximately a half mile and you would enter an area
11	which the ranch called the Ranch Central, and that housed many
12	buildings.
13	Just to the left, there were two homes, and that was
14	mainly for the ranch staff that lived on the ranch for support.
15	To the right, there was a So there were two homes to the left.
16	And then you continued, you're small office for the ranch.
17	And then you went still still in the Ranch Central area.
18	further into the ranch, probably a hundred feet.
19	And then on the right side, there was a building that
20	had rooms, there was approximately five bedrooms with a western
21	And that would be for whether it be, motif on the outside.
22	the -- any of the guests that would have came on the aircraft
23	And then to stay, the chef, the pilots all still stayed there.
24	it was a motel style building.
25	And then across the street from that, there was a
	SOUTHERN DISTRICT REPORTERS, P.C.

LBUCmaxl - direct¶

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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.¶

And then across the street from the greenhouse, there was a stable with a stable area that housed -- it had to have been 10 to 15 horses. That was the ranch central area.¶

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 And then you continued through Ranch Central and continued up a dirt road approximately, I don't know, it had to have been two or three miles and you got to a Y in the road where if you went to the left -- I'll take you to the left first. Once you got to the Y in the road, you took a left and actually you're going to pass by, during that drive, a runway we had on the property, which, as you saw, the twin-engine Cessna was parked on. So we had a runway and a hangar to house the aircraft. So you pass the runway and you continued up the road to -- it was called the lodge. It was actually the first home site that was selected to build the main house, and that was a triple-wide trailer that also had a western faux facade built around it. Once you went past the triple-wide lodge, you went about, you know, maybe a thousand yards and there was a log cabin that was built up on the cliff, because both the lodge and the log cabin were on cliffs that overlooked the ravine to the north.¶

And we go back to the Y in the road that brought you¶

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300¶

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	You continued up that road where you saw the past the runway.
	photo with the 2 on the entrance. That was the main entrance
	And then the main house was built to the main house.
4	eventually on that cliff overlooking the ravine.
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	BY MS. COMEY:
	Q. In total approximately how many acres was Mr. Epstein's
	ranch?
4	A. It was approximately 10,000 acres. I know there was some
5	state land included in it, but everybody said it was around
6	10,000 acres.
7	Q. And all of the structures you just described, were they all
8	located on that property owned by Mr. Epstein?
9	A. Yes.
10	Q. Have you been inside the main house on the ranch property?
11	A. Yes, I have.
12	Q. For what purpose?
13	A lot of the times -- it was on occasion A. Several purposes.
14	I would meet with Mr. Epstein and discuss future aircraft
15	maintenance or purchases for the aircraft. And then other
16	times would be to pick up and drop off luggage. And that was
17	another residence that I installed a lot of the home theater
18	He was an audiophile, so he liked very and audio equipment.
19	high-quality music; so I installed a home theater, like I had
20	done at the other properties as well.
21	MS. COMEY: Ms. Drescher, can we please pull up
22	Government Exhibits 323 and 706 for the witness, the Court, and
23	the parties.
24	Q. Mr. , do you recognize these?
25	A. Yes.
	SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

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	Q. What are they?
	A. Those are exterior photos of the main house at Zorro Ranch.
	Are these fair and accurate depictions of the exterior of Q.
4	the main house on Mr. Epstein's Zorro Ranch?
5	A. Yes, they are.
6	MS. COMEY: Your Honor, the government offers these in
7	evidence.
8	No objection. MR. EVERDELL:
9	THE COURT: Government 323 and 706 are admitted and
10	you may publish.
11	(Government's Exhibits 323, 706 received in evidence)
12	MS. COMEY: Thank you, your Honor.
13	While Ms. Drescher shows those to the jury, I'd like to ask Q.
14	you, Mr. to please describe the interior of this main
15	residence.
16	As you come into the entrance, I'll take you to the A. Okay.
17	front door, since it's a quite large property. You entered in
18	the front door, and I'll take it starting to the left. If you
19	enter the main door at the front of the house, you made a left,
20	and the house was actually a square house with an open
21	So it was courtyard in the middle that had access to the sun.
22	a -- virtually a square house that circled the courtyard in the
23	middle.
24	So we make a left, and that brought you down a
25	And the first room you came to was the main living hallway.

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 that overlooked the ravine or the house -- where the house you know, to take advantage of the view. Inside that room had a tremendous stereo system that I installed. And then came out of that living room and you continued down the hallway. At the corner of that library with a desk in it where also housed an impressive audio was, we you hallway there was Mr. Epstein's he spent most of his time, and system.¶

You came out of that room and that led you -- now you're on the -- you're still walking down circling the house. That brought you into what was the dining room for the house. And he didn't use it as a dining room actually; we made that into a movie theater room with a projector that came down. So that was actually the home theater of the house. And you continued through that room. That brought you into a butler's pantry. And then from the butler's pantry, you went into the main kitchen, which also had a dining room table. Once you went through the kitchen, that brought you to another room, which was kind of a morning room, just a small little family room off to the kitchen.¶

As you continue around, there was a staircase that would -- I'll take you downstairs first. You went downstairs. And that brought you to a gym and an indoor swimming pool that also led to the outside patio. Once you came -- I'll bring you¶

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	We're on the main level. And then there back up the stairs.
	was another staircase that brought you upstairs that housed the
	master bedroom, as well as approximately three -- three or four
4	guest bedrooms upstairs.
5	When you first visited this ranch, was the main house you Q.
6	just described completed?
7	A. No, it was not.
8	Q. About when was construction on this main house completed?
9	It was under construction for a while, that's why he had A.
10	the triple-wide trailer to stay during the construction. But I
11	would estimate probably late '90s, maybe 2000 is when the house
12	got finished.
13	And so in the mid to late '90s, when you visited the ranch, Q.
14	where did Mr. Epstein stay?
15	He would stay up at the lodge or the triple-wide mobile A.
16	home I described.
17	Could you describe what the interior of that triple-wide Q.
18	lodge looked like.
19	A. Sure. As I mentioned, it was a triple-wide trailer that
20	had a wood western facade built around it to make it a little
21	more attractive than just a mobile home. Once you went in the
22	front door, there was a large wooden deck in the front of the
23	house like you would see in a western movie. And you went in
24	the front door, you walked into the living room which had a
25	fireplace to the left.

LBUVMAX2 - direct¶

	And then if you continued past the living room and
	made your left turn to the left side of the home, that was the
	And then you came back into the living room master bedroom.
4	you continued straight ahead from the entrance door, that
5	brought you into a kitchen that led to a large outside deck
6	that overlooked the ravine. And then you came back into the
7	kitchen, and to the right side of the house there were -- there
8	was a small -- or a family room to the right side and also
9	there was two guest bedrooms there.
10	Did the inside of this structure look like a trailer? Q.
11	Not the way it was decorated. A. It was very high-end.
12	What airport did you fly to when Mr. Epstein was staying on Q.
13	this ranch?
14	A. Typically, depending upon what aircraft he selected, if we
15	were flying the Gulfstream, which is a smaller, lighter
16	And if we aircraft, we would use Santa Fe, New Mexico Airport.
17	were flying the Boeing, which is a large airliner, we would fly
18	into Albuquerque due to weight restrictions.
19	Q. I'd like to turn now to Mr. Epstein's Paris property.
20	About when do you remember first visiting
21	Mr. Epstein's apartment in Paris?
22	It had to have been maybe the late '90s, Ms. Comey. A. I
23	couldn't really narrow it down, but it had to have been in the
24	'90s, I would -- yes.
25	About how many times did you visit that apartment while Q.

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300¶

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	- direct LBUVMAX2
	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
4	I would almost say every trip, but we didn't go to Paris that
5	often, so I'll even go as far as saying most every trip.
6	Other than to pick up luggage, did you go to that apartment Q.
7	for any other reason?
8	A. Yeah. I also did some audio work on the home theater that
9	he had in the Paris apartment as well.
10	MS. COMEY: Ms. Drescher, could we please pull up
11	Government Exhibit 705 for the witness, the Court, and the
12	parties.
13	, do you recognize this? Q. Mr.
14	A. Yes.
15	Q. What is it?
16	A. That is the exterior of the Paris apartment.
17	Is this a fair and accurate depiction of the exterior of Q.
18	the building in which Mr. Epstein's apartment was located?
19	A. That is correct, yes, it is.
20	Your Honor, the government offers this in MS. COMEY:
21	evidence.
22	No objection. MR. EVERDELL:
23	THE COURT: GX-705 is admitted and you may publish.
24	(Government's Exhibit 705 received in evidence)
25	MS. COMEY: Thank you, your Honor.

LBUVMAX2		- direct
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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 or third floor, we're going back a little ways. But it was -- once you went in the front door, it was a little on the unique side. It was a very long type of apartment. Once you went in the front door, there was an entrance foyer. And if you continued straight through that foyer, it would take you into the kitchen. And then to the left of the kitchen, I think, led down to a hallway with some guest bedrooms.¶

Once you came back to the kitchen, to the right there was a dining room. And then to the right of the dining room there was Mr. Epstein's office where he had a home theater set up in his office as well. And then once you came out back into the foyer, I believe if you went to the right, it took you to either more guest bedrooms, and definitely the master bedroom was down the hallway.¶

Q. When Mr. Epstein stayed at this apartment, what airport did you fly out of?¶

A. We flew into Paris-LeBourget.¶

22 23 Q. Turning now to Mr. Epstein's island, about when did you first visit that island?¶

A. It was approximately mid to late -- late '90s.¶

Q. And what was that island called?¶

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300¶

4¶

5¶

6¶

	154
	- direct LBUVMAX2
	A. Little St. James.
	Q. About how often did you visit Little St. James during your
	employment for Mr. Epstein?
4	Every time we went to the St. Thomas U.S. Virgin Islands, A.
5	where the island was located.
6	About how often did you fly Mr. Epstein to the U.S. Virgin Q.
7	Islands?
8	A. Had been every week, every ten days, if we weren't
9	elsewhere in the world, but it was a regular destination.
10	And why did you go to the island each time Mr. Epstein went Q.
11	to the Virgin Islands?
12	A. I also flew the helicopter. So when Mr. Epstein would
13	arrive at St. Thomas main airport, I would go get the
14	helicopter and then pick him up and the passengers and fly them
15	to Little St. James Island, as well as, you know, taking
16	luggage and also picking up luggage at the island. And also a
17	very large home theater was installed at that residence as
18	well.
19	Did you install large home theaters in all of Mr. Epstein's Q.
20	residences?
21	A. Yes, I did.
22	Other than helicopter, how else could you get to Little St. Q.
23	James?
24	A. The other option would be boat.
25	MS. COMEY: Ms. Drescher, can we please pull up
	SOUTHERN DISTRICT REPORTERS, P.C.

	155
	- direct LBUVMAX2
	Government Exhibit 346 for the witness, the Court, and the
	parties.
	Q. Mr. , do you recognize that?
4	A. Yes.
5	Q. What is it?
6	That is an aerial view of Little St. James Island. A.
7	And does that fairly and accurately depict Little St. James Q.
8	Island?
9	A. Yes, it does.
10	Your Honor, the government offers this in MS. COMEY:
11	evidence.
12	MR. EVERDELL: No objection.
13	THE COURT: Government 346 is admitted.
14	You may publish.
15	(Government's Exhibit 346 received in evidence)
16	MS. COMEY: Thank you, your Honor.
17	Thank you, Ms. Drescher. We can take that down.
18	I'd like to go now to Government Exhibit 308 for the
19	witness, the Court, and the parties please.
20	Q. Mr. , do you recognize this?
21	A. Yes, I do.
22	Q. What is it?
23	A. That is an aerial view of the main property on Little St.
24	James Island.
25	Is this a fair and accurate depiction of a portion of Q.
	SOUTHERN DISTRICT REPORTERS, P.C.

	156 - direct LBUVMAX2
	Mr. Epstein's private island?
	A. Yes, it is.

	Your Honor, the government offers this in MS. COMEY:
4	evidence.
5	MR. EVERDELL: No objection.
6	THE COURT: Government 308 is admitted.
7	You may publish.
8	(Government's Exhibit 308 received in evidence)
9	MS. COMEY: Thank you, your Honor.
10	And while Ms. Drescher puts that up for the jury, Q.
11	Mr. , could you tell us what we see in this photograph
12	please?
13	A. That is the main house which appears to be -- and it's
14	located on the north side of the island. But it's a photo of
15	the main house structure on the island.
16	MS. COMEY: I'd like now, please, to go to Government
17	Exhibit 326 for the witness, the Court, and the parties.
18	, do you recognize this? Q. Mr.
19	A. Yes, I do.
20	Q. What is it?
21	That is also an aerial view of Little St. James Island's A.
22	main property home site.
23	And is this a fair and accurate depiction of a portion of Q.
24	Jeffrey Epstein's private island?
25	A. Yes, it is.

	- direct LBUVMAX2
	Your Honor, the government offers this in MS. COMEY:
	evidence.
	No objection. MR. EVERDELL:
4	THE COURT: GX-326 is admitted. You may publish.
5	(Government's Exhibit 326 received in evidence)
6	MS. COMEY: Thank you, your Honor.
7	And while Ms. Drescher puts this up for the jury, Q.
8	Mr. , would you please tell us what we see in this
9	photograph.
10	A. As far as describing the home or the property?
11	Q. Could you tell us what we see in the top right-hand Yes.
12	corner first and then tell us what we're seeing on the
13	property.
14	A. Oh, gotcha.
15	The top right-hand corner was the boat dock, if you
16	were to arrive by boat. So that was the entrance for guests to
17	And then if you continued down the highway arrive by boat.
18	there, you can't see the helipad, the helipad is still south of
19	Once you were there, you could take -- you that structure.
20	would walk up to the main house up on the top of the hill.
21	Q. Thank you.
22	MS. COMEY: We can take that down.
23	And now, Ms. Drescher, can you please pull up
24	Government Exhibit 703 for the witness, the Court, and the
25	parties.
	SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

	- direct LBUVMAX2

	, do you recognize this? Q. Mr.
	A. Yes, I do.
	Q. What is it?
4	A. That is a photo of Little St. James Island.
5	Is this a fair and accurate depiction of an aerial view of Q.
6	the entirety of Little St. James Island?
7	Yes, it is. A.
8	Your Honor, the government offers this in MS. COMEY:
9	evidence.
10	MR. EVERDELL: No objection.
11	THE COURT: Government's 703 is admitted.
12	You may publish.
13	(Government's Exhibit 703 received in evidence)
14	MS. COMEY: Thank you, your Honor.
15	Q. While Ms. Drescher puts this up for the jury, Mr.
16	I want to ask you, did Mr. Epstein own this entire island that
17	we see here?
18	To my knowledge, yes. A.
19	And could you walk us through in a little more detail a Q.
20	description of the island and the property on it.
21	I guess I'll start at the top of the photo. A. Okay. There
22	was a building there that was a library. It used to have a
23	gold dome on it, but that was actually a library inside that
24	building. And then we come down to the right side of the
25	photo, you could see a small pool on the right side of the

LBUVMAX2 - direct¶

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 of his time working on the phone and computers.¶

And then we're coming down through the beach area. Right dead center of the island you'll see a little blue roof, that was the gym. And inside the gym had a tremendous audio system for working out. There was a large gym inside there. And then you come down further from -- further down -- or you're heading down back to the main house structure, to the left you see a wide open grass area, that was the helipad that if we -- if you arrived by helicopter.¶

Coming further down from that, there are several buildings to the left, you see a blue one, a white one. That housed all of the construction equipment, tractors, dump trucks and such, support equipment for the island. And then we're going to come down further from that to the right. We'll come all the way down to the main house structure which also has a large swimming pool.¶

The house was quite unique. It was pretty much a home that was exploded out, that each building was a room of a house; that guest bedrooms were their own bunaglows. So the kitchen was its own building, the living room was its own building, the master bedroom was its own building. So in order to walk from one to another, you actually walked outside. So¶

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	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?
4	We flew into the main airport in St. Thomas, U.S. Virgin A.
5	I believe it's called Charlotte Amalie. Islands.
6	MS. COMEY: We can take that down.
7	Thank you, Ms. Drescher.
8	Q. Mr. , what, if any, of Ms. Maxwell's residences did
9	you visit during your employment?
10	I think I've been to all of her residence. A.
11	Could you walk us through each of them chronologically, Q.
12	starting with the first, please.
13	A. Yes. The first time I met Ms. Maxwell, she was in a
14	smaller apartment. We're going back 30 years, so I don't
15	really remember the streets.
16	But then the second apartment I remember a little
17	more, a little more obviously better, which I believe was on
18	84th Street, which was a nice three-bedroom apartment. And she
19	was there for several years. I did set up a home theater in
20	that apartment as well.
21	And then eventually she purchased a brownstone
22	townhouse, I believe, which was on 65th Street.
23	About when do you remember Ms. Maxwell moving from the Q.
24	smaller apartment to the apartment around 84th Street?
25	I don't really have a good, Had to have been the mid '90s. A.

	- direct LBUVMAX2
	accurate estimation on that.
	And about when do you remember her moving into the Q.
	brownstone townhouse you mentioned?
4	A. I'd only be guessing if I said the 2000s, but I don't have
5	an exact era. It had to have been in the 2000s, I believe.
6	Q. In what borough were all three of those residences?
7	They were in Manhattan. A.
8	Why did you go to those residences? Q.
9	It was -- it was still luggage; we would actually go there A.
10	to pick up luggage for the flights. I would actually go there
11	And then also at sometimes to get an expense report signed.
12	the brownstone I did -- she had the sixth floor up there that
13	had a home theater that I installed with a flat screen TV, so I
14	would occasionally go there and support, you know, help tune
15	and adjust that.
16	Would you please describe the interior of Ms. Maxwell's Q.
17	brownstone townhouse.
18	I believe it was a five or six-story building or home. Yo. A.
19	entered the front door, it brought you into a courtyard or I
20	And then once you started -- you should say an entrance foyer.
21	walk up the first stairs to the first -- to the first level you
22	got to, that was kind of the living room and also had the
23	So in the front of the house of the brownstone was kitchen.
24	the living room, then there was a dining room, and then further
25	back of that was the kitchen. And then you went to the next

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 fifth floor where we installed a home theater for her. Q. Switching gears. Between 1991 and 2004, what planes did you fly for Mr. Epstein? A. From '91 to 2004? Q. Yes. A. The first aircraft was a Hawker Siddeley, what's called an HS125. Mr. Epstein purchased that. He had that aircraft from '91 till 1994. And then in 1994, he sold that aircraft and he purchased a Gulfstream, which is called the G2B. And he had the Gulfstream from 1994 up until 2000, when he added another aircraft, is when he bought the Boeing 727. And he continued to keep both of those aircraft. So we flew both aircraft, the Boeing and the Gulfstream, up until 2004, to the date you mentioned. MS. COMEY: Ms. Drescher, would you please pull up Government Exhibits 311 and 312 for the witness, the Court, and the parties. Q. Mr. , do you recognize these? A. Yes. Q. What are they? A. That is the first aircraft Mr. Epstein purchased, which is the Hawker Siddeley 125.¶

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	Are these both fair and accurate depictions of that Q.
	aircraft?
	A. Yes, they are.
4	MS. COMEY: Your Honor, the government offers both of
5	these exhibits in evidence.
6	MR. EVERDELL: No objection.
7	Without objection, Government 311, 312 are THE COURT:
8	admitted, and you may accomplish.
9	(Government's Exhibits 311, 312 received in evidence)
10	MS. COMEY: Thank you, your Honor.
11	Thank you, Ms. Drescher. You can take those down.
12	Q. Mr. , about how many helicopters do you remember
13	Mr. Epstein owning between 1994 and 2004?
14	During that time frame, up until 2004, it was probably the A.
15	first helicopter he purchased, one helicopter.
16	Q. And when did Mr. Epstein purchase that helicopter?
17	Give or take a year, probably the year 2000, '99 to 2000. A.
18	MS. COMEY: Ms. Drescher, would you please pull up
19	Government Exhibits 344 and 345 for the witness, the Court, and
20	the parties.
21	Mr. , do you recognize these? Q.
22	A. Yes, I do.
23	Q. What are they?
24	A. That is a photo of Mr. Epstein's first helicopter he
25	purchased.

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	Do both of these exhibits fairly and accurately depict that Q.
	helicopter?
	A. Yes, they do.
4	MS. COMEY: Your Honor, the government offers these in
5	evidence.
6	MR. EVERDELL: No objection.
7	THE COURT: 344 and 345 government exhibits are
8	admitted. You may publish.
9	(Government's Exhibits 344, 345 received in evidence)
10	MS. COMEY: Thank you, your Honor.
11	Q. And while Ms. Drescher puts those up, I'll ask you,
12	, what did Mr. Epstein use these -- this helicopter Mr.
13	for?
14	A. It was mainly to get from St. Thomas to Little St. James,
15	rather than taking the boat ride.
16	Who do you remember flying this helicopter? Q.
17	Myself, Ms. Maxwell flew the helicopter with me, and I also A.
18	had some contract pilots that were based in St. Thomas that
19	assisted flying the helicopter as well.
20	About how many times do you remember Ms. Maxwell flying Q.
21	this helicopter?
22	It would be hard to put a number on it. A. Many times. Any
23	time -- several -- many times. It's hard to put a number on
24	it.
25	MS. COMEY: We can take those down. Thank you.

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	Q. Between approximately 1994 and 2000, what plane did you fly
	most frequently for Mr. Epstein?
	From 1994 to 2000, that would be it would have been A.
4	all been the Gulfstream G2B.
5	MS. COMEY: Ms. Drescher, would you please pull up
6	Government Exhibits 336 and 315 for the witness, the Court, and
7	the parties.
8	Mr. Q. , do you recognize these?
9	A. Yes, I do.
10	Q. What are they?
11	The photo on the left is a photo of the Gulfstream G28 that A.
12	has the white stripe on it, the black aircraft. The white
13	aircraft in the photo is -- I don't -- nothing to do with
14	Mr. Epstein. And then the photo on the right is another photo
15	of the Gulfstream G2B with Mr. Epstein standing in front of it.
16	MS. COMEY: Your Honor, the government offers these in
17	evidence.
18	MR. EVERDELL: No objection.
19	THE COURT: 336 and 315 are admitted and you may
20	publish.
21	(Government's Exhibits 315, 336 received in evidence)
22	Q. While Ms. Drescher puts these up for the jury, would you
23	please describe what the interior of the G2B looked like,
24	please.
25	As you walk up the entrance stairs to the aircraft, A.

LBUVMAX2 - direct¶

11¶

14¶

4 5 6 7 8 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 compartment, there were four large captain's chairs. They were baseball glove leather in color. This aircraft had a burgundy carpet. Once you get past the four chairs, you're continuing walking to the rear of the aircraft. There was a conference table to the right that had two chairs as well.¶

9 10 12 13 15 And then further aft, as you continue walking to the back of the aircraft, there was a couch or a divan inside there. And then once you went past the couch divan, there was a galley or what you would call kitchen inside the aircraft. And as you went further past that was the bathroom for the aircraft. And then further back than that is the luggage compartment.¶

16 17 Q. What, if any, barrier was there on this aircraft between the pilots and the passengers?¶

18 19 A. Between the pilots and the passengers there was a door that could be shut.¶

20 21 Q. And when you flew this plane for Mr. Epstein, was that door open or shut during flight?¶

22 23 A. We always had the door closed. It's much quieter with the door closed as well.¶

24 25 Q. So were you able to observe what the passengers were doing when you flew this plane?¶

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	A. No, I could not.
	Between approximately 2001 and 2004, which of Mr. Epstein's Q.
	planes did you fly most frequently?
4	A. Between 2001 and 2004, it was a combination of both the
5	Boeing 727 and the G2B, depending upon his choice of what
6	aircraft he wanted to fly. But mostly during that time frame
7	we were flying the Boeing 727.
8	MS. COMEY: Ms. Drescher, would you please pull up
9	Government Exhibits 302 and 301 for the witness, the Court, and
10	the parties.
11	Q. Mr. , do you recognize these?
12	A. Yes, I do.
13	Q. What are they?
14	Those are two photos of the Boeing 727 that Mr. Epstein A.
15	owned.
16	MS. COMEY: Your Honor, the government offers these in
17	evidence.
18	MR. EVERDELL: No objection.
19	THE COURT: 302 and 301, government exhibits, are
20	admitted. You may publish.
21	(Government's Exhibits 301, 302 received in evidence)
22	MS. COMEY: Ms. Drescher, after you've shown both of
23	these, I'd ask just to put up Government Exhibit 301 for the
24	jury, please.
25	, would you please While she's doing that, Mr. Q.

LBUVMAX2 - direct¶

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.¶

You went in the front entrance door which is located at the forward part of the aircraft. You walked upstairs. And if you continued straight ahead, it went into the first bathroom, which we considered the crew bathroom; so there was a lavatory up in front. And then if you made a left turn, brought you into the cockpit.¶

Now we're still at the entrance and now we're going to walk to the back of the airplane. You went through -- as soon as you got to the first compartment, there was like a large living room that had one, two, three -- it had three couches or divans. And then it had several captain chairs inside there.¶

Once you went from that first compartment, you're continuing walking to the back of the aircraft, in the middle there was a galley or kitchen like you would find in a home. It was a full decked-out kitchen.¶

And then once you went further past the kitchen, there was what we call the round room. There was a couch or a divan in the middle of the aircraft that was actually round or circular. And once you went past that, there was what we called the red room, which had Mr. Epstein's office that also had a red couch or divan and his office desk.¶

LBUVMAX2		- direct
----------	--	----------	--

	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
4	you're still walking to the back of the aircraft, there was the
5	master -- the master lavatory or the bathroom in the rear of
6	the aircraft.
7	MS. COMEY: Ms. Drescher, would you please pull up
8	Government Exhibit 303 for the witness, the Court, and the
9	parties.
10	, do you recognize this? Q. Mr.
11	A. Yes.
12	Q. What is it?
13	That is actually the round room I described with the round A.
14	couch or divan inside it. And then further in the photo you
15	could see the red couch which was his office. And further
16	after that led into the bedroom.
17	Is this a fair and accurate depiction of a portion of the Q.
18	interior of Jeffrey Epstein's Boeing 727?
19	A. Yes, it is.
20	Your Honor, the government offers this in MS. COMEY:
21	evidence.
22	MR. EVERDELL: No objection.
23	THE COURT: Government 303 is admitted.
24	You may publish.
25	(Government's Exhibit 303 received in evidence)
	SOUTHERN DISTRICT REPORTERS, P.C.

LBUVMAX2 - direct¶

4 5 6 7 8 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 located. When you say describe it -- Q. What we're seeing in the foreground and the background, the jurors weren't able to see the photograph when you were describing it.¶

A. Oh, I'm sorry. Gotcha. I thought I just explained it. I'm going to repeat myself.¶

10 11 12 13 14 15 16 So this is the round couch, round divan that was in the middle of the aircraft. And then as you see in the photo, the red couch or divan, which was Mr. Epstein's office and which -- to the right side of that, which is not in the photo, there was a large desk. And then in the foreground, way in the back are the two captain's chairs that are actually across from the master bed in the back of the aircraft.¶

17¶

18¶

19¶

20¶

9¶

MS. COMEY: We can take that down.¶

Thank you, Ms. Drescher.¶

Q. What, if any, barrier was there between the pilots and the passengers on the Boeing 727?¶

21 22 23 A. On the Boeing, each compartment had its own doors, so you can seclude each compartment or even the cockpit from the passengers.¶

24 25 Q. During flight in the Boeing 727, was the cockpit door opened or closed?¶

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	A. It was always closed.
	So were you able to observe the passengers on the flights Q.
	you piloted on that plane?
4	A. No.
5	What records did you keep as a pilot for Mr. Epstein? Q.
6	We kept two documents, one was a flight log and the other A.
7	was a passenger manifest.
8	Q. And when you say "we," who do you mean?
9	I meant myself and the other pilot. A.
10	Q. And who was that?
11	A. David Rogers.
12	You mentioned a flight log and a passenger manifest. Q. Did
13	you complete one for each flight you piloted for Mr. Epstein?
14	A. Yes, I did.
15	What is contained in a flight log? Q.
16	A flight log is a document that is pretty much married to A.
17	the aircraft; it's the history of how many hours the aircraft
18	has on it, how many times the aircraft has landed, each engine
19	has its own total time that's recorded, as well as how many
20	times it was cycled, meaning turned on or off.
21	Q. Will that flight log have any information about the
22	passengers onboard for a particular flight?
23	A. No, it will not.
24	How about the passenger manifest, what information goes Q.
25	into a passenger manifest?

	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
4	also had a column for the name of the passengers that were on
5	the aircraft.
6	Who completed the passenger manifest for each flight that Q.
7	was piloted for Mr. Epstein?
8	A. Whoever was captain on the aircraft that day would complete
9	that form.
10	What does it mean to be captain? Q.
11	To be captain would be to fly in the left seat and be in A.
12	total control of the aircraft.
13	Q. How long after each flight did the captain complete the
14	passenger manifest?
15	It was done immediately after the aircraft, within an hour. A.
16	Between approximately 1994 and 2004, what did you do with Q.
17	the passenger manifests that you personally completed?
18	After about 30 days, I would take A. They would acquire them.
19	them to the main office in New York and then drop them off.
20	Q. Did you keep a copy for yourself?
21	A. No, I did not.
22	If you did not know the name of a particular passenger on a Q.
23	flight, how will you indicate the presence of that passenger in
24	a passenger manifest?
25	I tried to be as accurate as I could. If I didn't know a A.

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 name. We tried to be as accurate as we could. So if I didn't know a name, I put whether they were male or female. Q. And remind us why you wouldn't necessarily know the name of everyone on your plane? A. It wasn't my first priority. Most of the time Mr. Epstein would, you know, indicate or introduce us to the passengers, but it just wasn't -- it wasn't the first thing, you know, on anybody's mind. Occasionally he would introduce and sometimes he wouldn't. We would try to gather their name if we asked them, if we had the time to ask them. But we tried to do the best we could is to get everybody's name. Q. During your employment with Mr. Epstein, did you ever fly to the airport in Traverse City, Michigan? A. Yes, I did. Q. About what years do you remember making those trips to Michigan? A. Definitely in the '90s is the best I could come up with. It was in the '90s. Q. During what season do you remember taking those trips to Michigan? A. I don't remember it being cold, because I know it gets pretty cold up there. It had to have been summer or, you know,¶

	- direct LBUVMAX2
	maybe close to fall when cherry season was happening because _
	think that's the cherry capital.
	When traveling to Traverse City, Michigan, where, if Q.
4	anywhere, do you remember picking up Mr. Epstein's luggage?
5	I can only recall one time that Mr. Epstein had called or A.
6	somebody notified me to pick up the luggage in the lobby of the
7	Interlochen School of Music.
8	Q. About when was that?
9	A. I don't have an accurate date. I could only say the '90s.
10	And what is Interlochen? Q.
11	A. I believe it's a school for gifted children that are
12	talented musicians, singers, etc., world-renowned type of
13	school.
14	Q. How many, if any, female passengers who flew on
15	Mr. Epstein's plane do you remember who were singers?
16	I can recall one. A.
17	At this time, your Honor, I'd like to read MS. COMEY:
18	a stipulation into the record, if I may.
19	THE COURT: What is the identification number?
20	It's Government Exhibit 1004. MS. COMEY:
21	Mr. Everdell, without objection? THE COURT:
22	Go ahead.
23	MR. EVERDELL: No objection, your Honor.
24	You may read Government Exhibit THE COURT: Okay.
25	1004, the stipulation.

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 Department of State. Government Exhibit 11 accurately reflects the date of birth of the person named on the certificate. Government Exhibit 12 is a true and correct copy of a birth certificate reported to the Rhode Island Department of Health. Government Exhibit 12 accurately reflects the date of birth of the person named on the certificate. Government Exhibit 13 is a true and correct certified copy of a birth certificate reported to the Missouri Department of Health and Senior Services. Government Exhibit 13 accurately reflects the date of birth of the person named on the certificate. Government Exhibit 14 is a true and correct certified copy of a birth certificate reported to Sacramento County, California. Government Exhibit 14 accurately reflects the date of birth of the person named on the certificate. Government Exhibit 15 is a true and correct certified copy of a birth certificate reported to the Massachusetts Department of Public Health. Government Exhibit 15 accurately reflects the date of birth of the person named on the certificate. Government Exhibit 16 is a true and correct copy of SOUTHERN DISTRICT REPORTERS, P.C.¶

175¶

	- direct LBUVMAX2

	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
4	certificate.
5	It is further stipulated and agreed that this
6	stipulation, marked as Government Exhibit 1004, and Government
7	Exhibits 11, 12, 13, 14, 15, and 16 may be received in evidence
8	at trial.
9	At this time, your Honor, the government offers all of
10	the exhibits I just named.
11	THE COURT: Mr. Everdell.
12	MR. EVERDELL: No objection.
13	THE COURT: Without objection and on stipulation,
14	Government Exhibit 1004 is admitted, as are Government Exhibit
15	11, 12, 13, 14, 15, and 16.
16	(Government's Exhibits 11, 12, 13, 14, 15, 16, 1004
17	received in evidence)
18	MS. COMEY: Your Honor, I would note that the parties
19	have agreed that Government Exhibits 11 through 16 would be
20	submitted under seal. And I would ask for authorization to
21	have the jurors pick up their binders of sealed exhibits so
22	that we may look at one of those in a moment.
23	THE COURT: Okay. And the sealing is consistent with
24	my ruling that some of the witnesses are able to testify under
25	pseudonyms.

	177
	- direct LBUVMAX2
	Yes, your Honor. MS. COMEY:
	THE COURT: Okay. And the specific direction to the
	jury is to pick up the binder now or not yet?
4	MS. COMEY: Pick up the binder now, but don't turn
5	anywhere in the binder yet.
6	THE COURT: Okay. Mr. Everdell, without objection?
7	MR. EVERDELL: That's fine, your Honor.
8	THE COURT: Members of the jury, there's a binder
9	under your seat. Please just pick it up, but don't open it
10	until specifically directed. Thank you.
11	MR. EVERDELL: Your Honor, also they shouldn't pick up
12	the folder.
13	THE COURT: They should not. There's a folder there
14	as well, and you should not pick up the folder yet, just the
15	binder. Surprises under your seats.
16	Your Honor, I would also ask the witness MS. COMEY:
17	to please pick up the binder in front of him.
18	THE COURT: Okay. Please do, Mr.
19	MS. COMEY: At this time I'd like to ask for the jury
20	and the witness to just turn silently to Government Exhibit 12
21	and take a look at that.
22	THE COURT: We're not going to put these on the
23	screens.
24	That's correct, your Honor. All paper MS. COMEY:
25	copies.

	1
	- direct LBUVMAX2
	THE COURT: Thank you.
	MS. COMEY: And your Honor, we have a hard copy for
	the Court, if that would be useful.
4	THE COURT: That would help. Thank you.
5	MS. COMEY: May Ms. Drescher approach?
6	THE COURT: Please.
7	And you've asked, Ms. Comey, to turn to again?
8	MS. COMEY: Government Exhibit 12, your Honor.
9	THE COURT: Okay.
10	So please just turn to Government Exhibit 12.
11	Everybody there? Not yet.
12	I see a hand from a juror. MS. COMEY:
13	THE COURT: We're going to get You need glasses.
14	them. Hang on a second. will ask you where she Ms.
15	can find them for you. Just a moment.
16	Members of the jury, please don't turn to other
17	exhibits until expressly instructed, but you may look at
18	Government Exhibit 12 in the binder.
19	(Pause)
20	THE COURT: Thank you, Ms. GX-12.
21	MS. COMEY: Yes. Thank you, your Honor.
22	BY MS. COMEY:
23	Now, Mr. , without saying the name out loud, would Q.
24	you please look at the first and last name on this exhibit.
25	A. Yes.

	179
	- direct LBUVMAX2
	Is the first and last name on that document the name of the Q.
	female singer you remember being a passenger on Mr. Epstein's
	plane?
4	MR. EVERDELL: Objection. Leading.
5	THE COURT: I'll allow it. Go ahead.
6	You can answer or I'm happy to ask the question again if Q.
7	you need me to.
8	A. Yes.
9	To be clear, is that the first and last name of the female Q.
10	singer you remember being a passenger on Mr. Epstein's plane?
11	Yes, it is. A.
12	MS. COMEY: We can set that aside. Thank you.
13	And your Honor, we don't need those binders for the
14	jurors anymore for this witness.
15	THE COURT: All right. Members of the jury, you can
16	close the binder and put it back under your chair, please,
17	until given further instruction. Thank you so much.
18	Mr. , I'm going to refer to that person whose name Q.
19	, and I would ask you to do the same, we just looked at as
20	please.
21	A. Okay.
22	Do you remember meeting Q.
23	A. Approximately mid to late '90s.
24	Do you remember the exact year as you sit here today? Q.
25	A. No, I do not.

	180 - direct LBUVMAX2
	Q. Did anyone ever tell you how old was?
	A. No.
	was when you met her? Q. Do you know how old
4	A. No, I didn't.
5	Q. How did you meet
6	Mr. Epstein brought her to the cockpit and introduced her A.
7	to me.
8	Q. What, if anything, stands out in your mind about
9	demeanor when you met her that day?
10	Just a mature woman with some piercing powder blue eyes. A.
11	About how many times do you recall seeing Q. on
12	Mr. Epstein's plane?
13	At least one, the time that Mr. Epstein introduced. A.
14	Q. Do you remember where you were going that day?
15	A. I do not.
16	Q. Do you remember where you were coming from?
17	A. Yes.
18	Do you remember where you were coming from that day? Q.
19	Yes, we were departing West Palm Beach Airport. A.
20	Q. What, if any, passenger with the first name do you
21	remember flying on Mr. Epstein's plane?
22	I do remember at least one person named A.
23	And what was that person's full name? Q.
24	It was A.
25	Q. About when did you meet
	SOUTHERN DISTRICT REPORTERS, P.C.

	LBUVMAX2	- direct
	A.	Had to have been mid to late '90s.
	Q.	Do you remember the exact year?
	A.	I do not.
4	Q.	look like? What did
5	A.	A shorter woman with dirty blond hair.
6	Q.	Did anyone ever tell you how old was when you met
7	her?
8	A.	No.
9	Q.	Do you know how old she was when you met her?
10	A.	No, I did not.
11	Q.	About how many times do you remember seeing
12		as a passenger on Mr. Epstein's private planes?
13	A.	She was on the airplane a couple times. I couldn't guess
14		the quantity, but definitely more than once.
15		MS. COMEY: May I have a moment, your Honor?
16		THE COURT: You may.
17		(Counsel conferred)
18		MS. COMEY: Nothing further, your Honor.
19		THE COURT: Okay. Mr. Everdell, you may proceed with
20		the cross-examination.
21		MR. EVERDELL: Thank you, your Honor.
22		At this point, with the Court's permission, I would
23		put a binder up in the witness box.
24		THE COURT: Okay.
25		Your Honor, to be clear, I have not seen MS. COMEY:
		SOUTHERN DISTRICT REPORTERS, P.C.

	182
	- cross LBUVMAX2
	what's inside this binder.
	This is in case we need to refer the MR. EVERDELL:
	witness to something.
4	So you may bring it forward. Before the THE COURT:
5	witness is directed to look at any document, you'll show it to
6	the government.
7	MR. EVERDELL: Yes. If we're going to refer to
8	anything, we will refer what it is to the government so they
9	can see it before we have the witness open the binder.
10	THE COURT: Okay.
11	MS. COMEY: Thank you, your Honor.
12	THE COURT: Thank you.
13	MR. EVERDELL: May I approach, your Honor?
14	THE COURT: You may.
15	MR. EVERDELL: May I remove my mask, your Honor?
16	THE COURT: You may, Mr. Everdell.
17	CROSS-EXAMINATION
18	BY MR. EVERDELL:
19	Good morning Mr. Q.
20	Good morning, Mr. Everdell. A.
21	I'm going to ask you a few questions about what you just Q.
22	testified to on direct.
23	A. Okay.
24	Now, you testified that you started working as a pilot for Q.
25	Jeffrey Epstein in about 1991; is that right?
	SOUTHERN DISTRICT REPORTERS, P.C.

	183 - cross
	LBUVMAX2
	A. That is correct.
	And you were hired, along with your friend Q.
	that right?
4	A. That's correct.
5	Q. Now, when you started in 1991, was the chief
6	pilot and you were the co-captain?
7	A. That is correct.
8	Q. But that changed, I think, in about 2000; is that right?
9	A. That is correct, approximately.
10	At that point you became the chief pilot and Q.
11	became the co-captain?
12	A. That's correct.
13	And you continued to work for Epstein as his chief pilot Q.
14	until about 2019?
15	A. Correct.
16	So you were a pilot for Jeffrey Epstein for almost 30 years Q.
17	from 1991 to 2019; is that right?
18	A. That is correct.
19	Q. And in that time, I think you testified that you flew
20	several different planes for him; is that right?
21	A. That is correct.
22	If we could call up what is already in MR. EVERDELL:
23	evidence as Government's Exhibit 311.
24	THE COURT: 311 you said?
25	MR. EVERDELL: 311, your Honor.
	SOUTHERN DISTRICT REPORTERS, P.C.

	184
	- cross LBUVMAX2
	THE COURT: Okay. You may.
	MR. EVERDELL: And we can display that for the jurors.
	THE COURT: You may.
4	Do you see that, Mr. Q.
5	A. Yes, I do.
6	That's the Hawker Siddeley jet, right? We saw that before. Q.
7	A. Correct.
8	And that was used from about '91 -- 1991 to 1994; is that Q.
9	right?
10	A. That's correct.
11	MR. EVERDELL: Okay. We can take that down.
12	So you no longer flew the Hawker after about '94? Q.
13	A. No, the aircraft was sold after '94.
14	Q. And there was another aircraft you mentioned, the
15	Gulfstream, the G2B, right?
16	A. Correct.
17	MR. EVERDELL: If we can pull up what's already in
18	evidence as Government's Exhibit 315.
19	THE COURT: You may.
20	MR. EVERDELL: Display that for the jurors as well.
21	Do you see that, Mr. Q.
22	A. Yes.
23	Q. We saw that before, right, that is the Gulfstream jet with
24	Mr. Epstein in front of it; is that right?
25	A. Correct.
	SOUTHERN DISTRICT REPORTERS, P.C.

	185
	- cross LBUVMAX2
	And he got that, your recollection is, sometime Q. Okay.
	around 1994?
	A. Correct.
4	MR. EVERDELL: All right. We can take that down.
5	And you've also mentioned that he eventually got the Boeing Q.
6	727?
7	A. Correct, in 2000.
8	Q. That was roughly around 2000?
9	A. Correct.
10	MR. EVERDELL: If we can display what's already in
11	evidence as Government's Exhibit 301.
12	THE COURT: You may.
13	MR. EVERDELL: And show that to the jurors as well.
14	That was -- that is the Boeing 727; correct? Q.
15	A. That is correct.
16	MR. EVERDELL: Okay. You can take that down.
17	You occasionally flew other planes for him as well? Q.
18	A. Yes.
19	I think we saw in one of the photos, I won't call it up, Q.
20	but there was a small Cessna?
21	A. Yes.
22	But from about 1994, after Mr. Epstein sold the Hawker, Q.
23	till about 2001 or 2000, I think is your recollection, when he
24	bought the Boeing, you flew primarily the Gulfstream?
25	That is correct. A.

	186
	- cross LBUVMAX2
	And from 2000 onwards or till 2004 or five, you were flying Q.
	both the Gulfstream and the Boeing?
	A. That's correct.
4	Now, in the period from 1991, when you were first hired, to Q.
5	2005, you flew numerous flights for Epstein?
6	A. Correct.
7	Would it be accurate to say that you flew over 1,000 Q.
8	flights during that time period?
9	I'd have to look at my records, but it was probably close A.
10	to that, yes.
11	Q. Give or take?
12	A. Give or take, yes.
13	That's a lot of flights. Q.
14	A. We consider it more in hours than flights, but
15	Q. Understood.
16	And Epstein would frequently have other passengers on
17	these flights, right?
18	A. Yes.
19	Q. And many of these passengers were female; correct?
20	A. Correct.
21	Q. And sometimes you saw the passengers, right?
22	A. Yes.
23	Q. There were times when you, I think, stood at the entrance
24	of the plane near the cockpit when the passengers arrived and
25	you might have greeted them?

	187
	- cross LBUVMAX2
	A. Sometimes.
	Q. There were times when Epstein or Ghislaine introduced you
	to passengers?
4	A. Correct.
5	Q. There were times when the plane and the passengers had to
6	clear customs, right, and the pilots and the passengers would
7	have to get out of the plane and clear customs to do that?
8	A. Yes, that's correct.
9	Q. And you'd see the passengers then too?
10	A. Sure.
11	Q. Okay. And there were times when the passengers came up to
12	the cockpit before takeoff and you might have met some of them
13	then?
14	Occasionally that would happen, sure. A.
15	Q. Okay. Now, you testified that the cockpit doors for the
16	Gulfstream and the Boeing were always closed during the flights
17	while you were in the air; is that right?
18	A. Yes.
19	But you left the door open to the cockpit as you were Q.
20	getting the plane ready for takeoff before you took off, right?
21	A. Yes.
22	As you were in the cockpit, if you were looking back Q.
23	through the cockpit door, you could see the passengers in the
24	entranceway if you wanted to, right?
25	Most of them, yes. A. It wasn't a clear view to every seat in

	188
	- cross LBUVMAX2
	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?
4	Yeah, if I looked over my shoulder; correct, yes. A.
5	Q. Or those other ways we discussed?
6	At the entrance, yes. A.
7	Now, of the female passengers on these planes that you Q.
8	observed, you occasionally saw young girls who were traveling
9	with their family members, isn't that right?
10	A. There was some time when adults would bring their children
11	onboard, sure.
12	But you never saw a female you thought was under the age of Q.
13	18 who was not with her family, right?
14	A. Correct. No.
15	Q. And apart from those times when you saw young girls
16	traveling with their family members, you never saw any female
17	on the plane who looked to you to be under the age of 20, isn't
18	that right?
19	A. Well, that's correct, yeah, I didn't notice anybody of a
20	younger nature without an adult or, you know, a parent.
21	So in the roughly thousand or so, give or take, flights Q.
22	that you flew for Epstein from 1994 -- or 1991, I should say,
23	to 2005, you never once saw a female on any of the planes who
24	looked under the age of 20, apart from the ones who were
25	traveling with their family members?

	189 - cross LBUVMAX2

	I didn't know anybody's, you know, exact age or Correct. A.
	age at all really.
	But none of them appeared to you to be under 20? Q.
4	A. Correct.
5	Was that -- I didn't hear. Q.
6	Yes, that's correct, yes. A.
7	Now, that includes the woman that we have been referring to Q.
8	; correct? as
9	I didn't know her age. Correct. A.
10	Q. And she did not appear to you to be under the age of 20?
11	I didn't know her exact -- I didn't know her age at all. A.
12	But to my -- she looked like a woman.
13	She looked like a mature woman, I believe was your Q.
14	testimony before; is that right?
15	Sure. A. Yes.
16	And it also includes the woman you referred to as Okay. Q.
17
18	A. Yes.
19	She also did not look below the age of 20 to you? Q.
20	I didn't know her age, but she didn't -- she didn't look A.
21	I mean, wherever you decipher is the definition of young.
22	"young," but she -- she was a woman in my category.
23	(Continued on next page)
24
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	190
	- cross LBUCmax3
	BY MR. EVERDELL:
	Q. She was a woman?
	A. Yes.
4	Mr. Q. , in all these flights that you flew, the
5	several hundred to a thousand flights that you piloted for
6	Mr. Epstein in this time period, you also never saw any kind of
7	sexual activity occur on the planes; isn't that right?
8	A. I never saw any sexual activity, no.
9	Q. And you certainly never saw anyone engaging in sex acts
10	with underage girls on the plane?
11	A. Absolutely not.
12	In fact, you never saw anyone engaging in sex acts with any Q.
13	of the women on the flights period; right?
14	A. That is correct.
15	Q. Now, you testified, I think we already established this,
16	that when you were flying, in flight, the cockpit doors were
17	closed?
18	A. That is correct.
19	So if the cockpit doors were closed, you couldn't Q.
20	necessarily see what was going on in the cabin during the
21	flights; right?
22	A. Not at all, no.
23	But you were never instructed by Epstein or anyone else Q.
24	that you were not allowed to leave the cockpits during the
25	flights; is that correct?

	- cross LBUCmax3
	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.
4	So he invited you to come anywhere you wanted to, even Q.
5	including in the back of the aircraft to use the restroom if
6	you wanted to?
7	A. Yes, because there are times that if you have to Exactly.
8	use the restroom, like now.
9	We can take a break. Q.
10	I was hoping for a break in between. A. Am I the only one?
11	THE COURT: Jury, I think it's time for our midmorning
12	break. Why don't you finish the question and then we'll take a
13	break.
14	MR. EVERDELL: Yes, your Honor.
15	He invited you to use the Q. I'll just ask the question.
16	restroom at the back of the plane whenever you needed to?
17	Yes, he offered, if we needed to use the restroom, to feel A.
18	free to come into the back of the aircraft to use the restroom.
19	To do that, you had to Q. One last question before we break.
20	walk through the cabin to the back of the plane and go through
21	the rooms of the plane to get to the restroom; isn't that
22	right?
23	A. If we were in the Gulf Stream, yes. In the Boeing, we had
24	But in the Gulf Stream, like, our own lavatory up front.
25	you're talking about from '94 to 2000, we would walk down the

	192
	- cross LBUCmax3
	middle of the aircraft because the bathroom was at the absolute
	rear, correct.
	THE COURT: Members of the jury, we'll take our
4	midmorning break. See you in about 10 minutes. Thank you.
5	(Continued on next page)
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	193
	- cross LBUCmax3
	(Jury not present)
	Everyone may be seated, the witness may step down for
	the break.
4	(Witness not present)
5	Are there matters to take up before the break?
6	No, your Honor. MS. COMEY:
7	MR. EVERDELL: No, your Honor.
8	MS. STERNHEIM: Judge, may I just ask, it's very cold
9	in here, can the temperature be risen just a little?
10	THE COURT: I'm sweating.
11	MS. STERNHEIM: Sorry.
12	This is my light THE COURT: We'll get it raised.
13	weather robe. We'll get it raised.
14	MS. STERNHEIM: Thank you.
15	I apologize. THE COURT: We'll see you in about 10.
16	(Recess)
17	THE COURT: Matters to take up, counsel?
18	No, your Honor. MS. COMEY:
19	MR. EVERDELL: No, your Honor.
20	THE COURT: We can bring the witness back into the
21	box.
22	Mr. Everdell, do you have a time estimate? I won't
23	hold you to it.
24	MR. EVERDELL: Do you have an estimate for how long
25	I've been going so far? I could probably --

	- cross LBUCmax3
	20 minutes. THE COURT:
	I'd say maybe another hour or so. MR. EVERDELL:
	Ms. Sternheim, I have asked for Okay. THE COURT:
4	them to raise the temperature.
5	Feels better Thank you, Judge. MS. STERNHEIM:
6	already.
7	(Continued on next page)
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	195
	- cross LBUCmax3
	(Jury present)
	THE COURT: Please be seated. I hope you had a
	pleasant and timely break, members of the jury. Thank you for
4	your continued attention and diligence.
5	Mr. Everdell, you may continue with your cross
6	examination of Mr. And Mr. , I remind you that
7	you are under oath. You may proceed.
8	MR. EVERDELL: Thank you, your Honor.
9	BY MR. EVERDELL:
10	Q. Welcome back, Mr.
11	A. Thank you.
12	Q. Trust you're feeling more comfortable?
13	Oh, much better. A.
14	Do you recall when we left off, we were talking Q. Very good.
15	about going to the restroom on the airplanes?
16	A. Yes.
17	Q. And I think you said that you were allowed, you were
18	permitted and even invited to walk through the Gulf Stream to
19	the back of the plane to use the restroom there if you needed
20	to?
21	A. That's correct.
22	So Mr. Epstein never told you, for example, you have to Q.
23	stay in the cockpit during the flight?
24	A. Absolutely not.
25	Q. Now if he were engaging in sex acts with underage girls in

	196
	- cross LBUCmax3
	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.
4	THE COURT: Overruled. You may answer.
5	A. Can you repeat the question.
6	Sure. If Mr. Epstein were engaging in sex acts with Q.
7	underage girls on his planes and he didn't want you to see it,
8	he probably would have told you that you couldn't leave the
9	cockpit during the flight; isn't that right?
10	A. That's correct.
11	And he never told you that you could never mingle with the Q.
12	passengers; right?
13	A. No, not at all.
14	Q. In fact, you recounted how you did interact with the
15	passengers on occasion; right?
16	A. Absolutely on occasion, sure.
17	In fact, you were never given any rules about how you could Q.
18	or could not interact with the passengers; right?
19	No, I was never told what to do with the passengers or what A.
20	not to do.
21	Q. And you were never given any rules about how you could
22	interact with the other members of his staff or his assistants;
23	isn't that right?
24	That is correct, never. A.
25	Now, you did say that every once in a while you would leave Q.
	SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

	197
	- cross LBUCmax3
	the cockpit to use the restroom?
	A. Correct.
	And you did that both on the Gulf Stream and on the Boeing; Q.
4	is that correct?
5	A. Yes.
6	Q. The Gulf Stream bathroom, you said, was in the back of the
7	plane; right?
8	A. Yes.
9	Q. And the Boeing bathroom was near the cockpit but outside
10	the cockpit; is that right?
11	A. Exactly, yes.
12	So if you went to the bathroom in the Boeing, you could Q.
13	still see the cabin where the passengers were, at least the
14	first cabin?
15	If the door was open. A. Each section of the aircraft had a
16	door and typically the doors were open.
17	Q. Well, in any of those trips to the restroom, you never saw
18	any sexual activity on the plane?
19	A. No, I never did.
20	Q. And you had also, I think, occasion go to get coffee in the
21	galley kitchen; is that right?
22	I would go to the middle of the A. In the Boeing, yes.
23	aircraft to get a cup of coffee on occasion, sure.
24	And as you said in the Boeing, the galley kitchens is in Q.
25	the middle of the aircraft; is that right?

	198
	- cross LBUCmax3
	A. That's correct.
	So you would have to walk through at least that first cab':-: Q.
	of passengers?
4	A. That's correct.
5	Q. And on those trips you took to get coffee in the galley
6	kitchen, you never saw any sexual activity going on then, did
7	you?
8	A. No, never.
9	Q. Now, after the flight landed, I believe it was part of the
10	pilot's job to help clean up the cabin and straighten up a bit;
11	isn't that right?
12	A. Yes, it is.
13	And when you did that, you never saw anything like clothes Q.
14	strewn about the cabin; is that right?
15	A. No, never.
16	You never saw any sex toys left in the cabin? Q.
17	A. Never.
18	Q. You never saw anything like used condoms?
19	A. Absolutely not.
20	You never saw anything that gave you the impression that Q.
21	any kind of sexual activity was taking place on the plane with
22	anyone; is that right?
23	That is correct, I never, no. A.
24	So sitting here today, based on what you observed, you have Q.
25	no reason to believe that Epstein or anyone else was engaging

	199
	- cross LBUCmax3
	in sexual activity with underage girls on the flights you
	piloted; isn't that right?
	A. Correct.
4	, I want to ask you some questions about how the Mr. Q.
5	flights were scheduled and set up. Okay?
6	A. Sure.
7	Now, before a flight was scheduled, you and Q.
8	needed to be alerted ahead of time that Epstein needed to fly
9	somewhere; isn't that right?
10	A. Yes.
11	Q. I think you said typically you get about a day's notice;
12	isn't that right?
13	A. That's correct.
14	And several different people would call you to schedule Q.
15	these flights; is that right?
16	A. Yes.
17	Q. And in the 1990s, focusing on that time period, you would
18	occasionally get calls from Epstein himself to schedule
19	flights?
20	A. He would call on occasion, yes.
21	And every once in a while, you'd get a call from Ghislaine, Q.
22	as well?
23	A. Sure.
24	But during that time period, it was usually Epstein's Q.
25	secretary or one of his other assistants in New York who would
	SOUTHERN DISTRICT REPORTERS, P.C.

	200
	- cross LBUCmax3
	call you to schedule the flights; isn't that right?
	It would be a variety. A. Whoever got the message would pass
	it along to us, correct.
4	And I think you said that in the 1990s, you didn't Q. Right.
5	have cellphones; right?
6	It was a beeper, pager. A. Correct.
7	This was over 20 years ago at this point; right? Q. Beeper.
8	A. Coming in on 30, but yes, correct.
9	Coming in on 30. Q. That's before everybody owned a
10	cellphone; correct?
11	A. Yes.
12	But you did have the beepers? Q.
13	A. Yes.
14	Q. And you and would get a message on your beeper;
15	right?
16	A. Yes.
17	And you would call back Epstein's office, usually; right? Q.
18	A. Yes.
19	Because that's usually where the call came from, isn't it? Q.
20	A. That's correct. That was the number that would appear for
21	departure.
22	And you would talk to Epstein's secretary or assistant or Q.
23	whoever was going to schedule that flight?
24	A. Correct.
25	Now, occasionally, you said you talked to Ghislaine about Q.
	SOUTHERN DISTRICT REPORTERS, P.C.

	- cross LBUCmax3
	this, about scheduling?
	A. Occasionally Ghislaine would reach out. Several people
	Whoever Jeffrey told, hey, get the plane would reach out.
4	ready, that's the person that contacted me.
5	It was usually the case, if you spoke to Ghislaine about Q.
6	flight, she was going to be traveling on that flight?
7	A. Most of the time, sure.
8	Q. And in the 2000s now, fast forwarding to a later time
9	period, you spoke to different people about scheduling flights;
10	isn't that right?
11	A. Yeah, whoever would get the message, correct. It would be
12	different people.
13	Well, one person you spoke to in the 2000s was Q.
14	; isn't that right?
15	A. That's correct.
16	Q. And was Epstein's secretary?
17	A. That's correct.
18	Q. And she worked in Epstein's New York office?
19	A. That is correct.
20	Do you recall what number you used to call her on? Q.
21	A. Yes, the main office number.
22	Q. Do you remember what that number was?
23	A. Yes, I do.
24	Q. What was it?
25	A. 212-750-9895.

	202
	- cross LBUCmax3
	But the person I think you spoke most often to about Q.
	, it was scheduling flights in the 2000s was not
	; isn't that right?
4	She would also schedule flights, yes. A.
5	Q. , you said? You met
6	Yes, I have. A.
7	MR. EVERDELL: If we can pull up for the members of
8	the jury and everyone else Government Exhibit 327, which is
9	already admitted.
10	Q. That's isn't it?
11	A. That is , yes.
12	Now, you say you think you met her sometime in the early Q.
13	2000s; is that right?
14	Again, we're 20, 21 years A. It could have been late '90s.
15	ago, but yeah, it was late '90. It could have been 2000.
16	remember Ms. obviously flying on the Boeing, which would
17	have been 2000 and later. Yeah, it was late '90s. It's the
18	best I could do as far as recollection.
19	Q. Well, isn't it true that she first flew on one of Epstein's
20	planes in September of 2001?
21	I believe she -- well, she probably did because she was A.
22	around in '01 when the Boeing was there. I haven't gotten
23	any -- I don't have any documentation or -- but yes.
24	MR. EVERDELL: Let me see if there is something that
25	might refresh your recollection. I would like to pull up just

	203
	- cross LBUCmax3
	for the Court, the deputy, and for the witness 3527-07 at page
	I'll repeat for clarity that's 3527-007 at page 86. 86.
	Let me know when you're ready, Ms. Comey. THE COURT:
4	Thank you, your Honor. I'm there. MS. COMEY:
5	THE COURT: Thank you.
6	BY MR. EVERDELL:
7	, if I could direct your attention to the sixth Q. Mr.
8	entry down on that list you're looking at. If you could just
9	take a look at that. Just see if that refreshes your
10	flew. recollection about the first time
11	Is that the September 3rd date you're looking? A.
12	I'm asking, does that refresh your recollection? Q.
13	Well, it's a document of a regularly scheduled route. A.
14	It was normal -- there was a Obviously it's not my logbook.
15	typical routing that we would fly. It's the best I could say,
16	but it would appear to be the -- it doesn't refresh of any, you
17	know, certainty, but sure, that would be a date that we would
18	do a trip like that.
19	, to the best of So I'll just rephrase. Okay. Q.
20	your recollection, was flying on Epstein's planes in the early
21	2000s?
22	A. Correct. Yes.
23	MR. EVERDELL: You can take that down.
24	excuse me. Now, that is around the time when Epstein Q.
25	became Epstein's personal assistant; isn't When
	SOUTHERN DISTRICT REPORTERS, P.C.

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. Maxwell's assistant, just that she was there as an employee. Q. Your recollection is that she was an employee who worked with Epstein; is that fair to say? A. Yeah. Exactly, yes. Q. But you're a little unclear exactly what her role was? A. Correct. Q. But she certainly did some work for Epstein in the time she worked in his office? A. Exactly, yes. Q. Do you recall, she was married to right: A. Later in life, I believe she got married to Q. So you said that would call you to arrange the flight departures? A. Sometimes, sure, yes. Q. And by that point in the 2000s or the early 2000s, you had cellphones; right? A. Correct. Q. So, when she did call you, would call your cellphone to arrange a flight; is that right?¶

	205
	- cross LBUCmax3
	That is correct. A.
	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
4	right?
5	A. Most likely, yes.
6	Do you recall what phone number was? Q.
7	A. I do not.
8	MR. EVERDELL: Let me show you something, see if it
9	I want to call up 3527-001, we'll refreshes your recollection.
10	go to the third page. That is just for the Court, the deputy,
11	and the witness, please.
12	MR. EVERDELL: May I proceed, your Honor?
13	THE COURT: Yes.
14	MS. COMEY: Thank you.
15	, do you have that document in front of you? Q. Mr.
16	A. Yes, I do.
17	Do you see just sort of maybe a third of the way down from Q.
18	the top of the page, there is an entry there. Does that
19	phone number refresh your recollection on what
20	was?
21	Her number wasn't embranded in my mind as a memory, but the A.
22	number does come back to me as being cellphone
23	number.
24	So the number, was it Q.
25	A. That's correct, yes.
	SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

	206
	- cross LBUCmax3
	MR. EVERDELL: Thank you. You can take that down.
	So in the 2000s, that's the number you would speak to Q.
	on about arranging flights?
4	A. Correct.
5	Q. Now, regardless of who you spoke to about scheduling
6	flights, when you were told that Epstein needed to fly
7	somewhere, you would need to be given certain information about
8	the flight; correct?
9	A. Sure.
10	Q. Like, for example, you would need to be given the date of
11	when Epstein wanted to fly?
12	A. Correct.
13	You would need to be given roughly the time of departure: Q.
14	A. Yes.
15	And you would need to be given the destination where you're Q.
16	going to fly; right?
17	A. Yes. That would be helpful, yes.
18	You might want to follow a flight plan or something like Q.
19	that?
20	A. Yes.
21	Q. But you wouldn't necessarily be told who was going to be
22	going on the flight; right?
23	A. Not at all.
24	If you had someone who was particularly important that was Q.
25	going to be on the flight, you might be told ahead of time?

	207
	- cross LBUCmax3
	A. Exactly.
	So, for example, I believe former president Bill Clinton Q.
	flew on Epstein's planes a few times in the 2000s; isn't that
4	right?
5	A. Yes, he did.
6	So if he were going to be on the flight, you might be told Q.
7	that information in advance?
8	A. Yes.
9	Q. Because you might want to make sure the plane looked nice?
10	A. Exactly.
11	You might want to invite some special caterer? Q.
12	A. Sure.
13	But otherwise, you might not know who would be traveling on Q.
14	the flight at all; is that right?
15	A. Correct.
16	Q. And even when the passengers arrived at the airport, even
17	then, you wouldn't necessarily meet all the passengers; right?
18	A. No, not at all.
19	A lot of the time you didn't meet them? Q.
20	A. Correct.
21	Q. Sometimes you were just given their names?
22	A. Yes.
23	And you wouldn't always be given all of their names; right? Q.
24	A. Correct.
25	Sometimes you would just be given a first name? Q.

LBUCmax3 - cross¶

208¶

	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
4	people were on the plane; right?
5	A. That's correct.
6	Because as you mentioned before in testimony, pilots need Q.
7	to fill out a passenger manifest for each flight; right?
8	A. They don't have to on general aviation. It was more for
9	It was my understanding we kept passenger weight and balance.
10	information more for tax reasons on who flew on the aircraft in
11	Might not be the case at this point, but we the early days.
12	still tried to keep as accurate records, if we could, even if
13	it wasn't necessary.
14	Q. Fair enough. So but you did try to keep passenger
15	manifests for flights on Epstein's planes?
16	A. Absolutely, yes.
17	Q. And a manifest, I think you described, among other things,
18	contains the list of the passenger names if you have them; is
19	that right?
20	A. That's correct.
21	Q. And if you didn't know their names, you might put in
22	something like one female or one male or one passenger to note
23	a named passenger?
24	We tried to at least identify the sex rather than A. Exactly.
25	just put one passenger. So that's why we had put male or
	SOUTHERN DISTRICT REPORTERS, P.C.

(212) 805-0300¶

	209
	- cross LBUCmax3
	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
4	manifest?
5	A. Absolutely.
6	And you said that it was important to keep track of the Q.
7	head count, which is why you wanted to know how many people
8	were on the plane; right?
9	A. That is correct.
10	Now, you said weight was also a consideration; is that Q.
11	right?
12	It's a consideration on some aircraft, not the kind that A.
13	we're flying, but it's something that should take into account
14	But it is a consideration or as far as how heavy luggage is.
15	as a pilot to know how much something weighs as far as luggage
16	and/or passenger.
17	Q. And that's if you're flying a small plane, for example, you
18	need to know the weight of the passengers?
19	A. Exactly, yes.
20	But for the planes you were flying for Epstein, Q.
21	particularly the Gulf Stream and the Boeing, you didn't need to
22	know the weight for those planes; right?
23	It's, like I said, more of a It was not necessary, no. A.
24	head count, but yeah, it's not a factor in these type of
25	aircraft.

	- cross LBUCmax3

	Right, because the Boeing, as we saw it, it's huge; right? Q.
	A. Correct.
	And the Gulf Stream is not a little prop plane, it has a Q.
4	jet engine; right?
5	A. Correct. It's not power challenged, correct.
6	So it wasn't your practice to ask passengers their weight Q.
7	before they boarded?
8	A. No, absolutely not.
9	Q. Now, it was sometimes the case, wasn't it, that if one of
10	Epstein's friends or acquaintances or family members needed to
11	go to the same place he was flying, he would take them on his
12	plane; right?
13	A. I don't know for a fact, but sure, I'm sure on occasion.
14	if we were going to the same place, he may extend an invitation
15	for somebody to come along.
16	Q. He did have friends and family members and other people
17	traveling on his plane?
18	That is correct, yes. I see what you're saying. A.
19	Q. It's like offering a lift in your car, except it's a jet?
20	A. Correct, yes.
21	Q. You call these people tagalongs; right?
22	Yeah, there is several names, sure, but tagalongs or extra A.
23	guest.
24	Q. Now, in those cases, if the person or the tagalong was not
25	a regular traveler, you might not know their name?

210¶

	211
	- cross LBUCmax3
	A. That's correct.
	Or you might just be given their first name? Q.
	A. Correct.
4	Q. Not be given a name at all?
5	A. Correct.
6	So that's an example of where you might put one female, one Q.
7	male?
8	A. That is correct, yes.
9	Q. Now, the manifest, you testified that you kept the
10	manifest; right?
11	A. Yes.
12	And then eventually you gave them to the New York office? Q.
13	A. Correct.
14	Q. I think you sent them, if I recall, to someone named
15	in New York; is that right?
16	A. Yes.
17	You did not send them to Ghislaine, though; isn't that Q.
18	right?
19	A. No, they went to the main office, whether it be
20	haven't heard that name in a long time. That was a memory
21	refreshed. Thank you.
22	Q. My pleasure. So you have no reason to believe that
23	Ghislaine was reviewing these manifests; right?
24	A. No, Ms. Maxwell had nothing to do with the passenger
25	manifests.

	- cross LBUCmax3
	So from your perspective, you had no reason to believe that Q.
	Ghislaine would have known which passengers were on the flights
	that she didn't fly on herself?
4	A. Correct.
5	I want to talk to you about a few specific flights. Q. I
6	think you mentioned in your testimony a place called
7	Interlochen; is that right?
8	A. Yes.
9	Q. Interlochen is, I think you recall, an arts center; is that
10	right?
11	A. Yes, correct.
12	It hosts an arts camp in the summer for musicians and Q.
13	singers and actors and other types of artists; is that right?
14	A. That's correct.
15	Q. And generally, in this summer camp, these artists,
16	musicians, and singers are in high school; is that right?
17	I didn't know where they -- I knew it was just an upcoming A.
18	school for talented, I guess, children, because I would take it
19	they're more on the younger side than older.
20	Q. Understood. Are you aware that Epstein himself attended
21	the Interlochen Summer Arts Camp when he was a young man?
22	A. I did not.
23	Q. Interlochen is located in Michigan?
24	A. Correct.
25	And to get to Interlochen, you said you had to fly into Q.

		213
		- cross LBUCmax3
		Traverse City, Michigan?
	A.	That's correct.
	Q.	That's the closest airport?
4	A.	That is closest.
5	Q.	And in the 1990s, you flew into Traverse City at least once
6		a year or maybe twice a year in the summer months, you recall;
7		right?
8	A.	That's correct.
9	Q.	Do you recall any of the passengers on those flights?
10	A.	I do not.
11	Q.	Isn't it true that Itzhak Perlman flew on some of those
12		flights?
13	A.	As you said, it just dawned on me, yes, Itzhak Perlman did
14		fly on some of those flights, correct.
15	Q.	Itzhak Perlman is a world famous violinist?
16	A.	Yes.
17	Q.	It's fair to say that Epstein went to Interlochen almost
18		every summer in the 1990s; isn't that right?
19	A.	He went there often in the '90s, but like you, said we are
20		going back a ways. Yes, correct.
21	Q.	You recall this being in the summer months?
22	A.	Summer months, yes.
23	Q.	These flights typically took place in August, didn't they?
24	A.	I don't know the exact month, but it was warm.
25	Q.	Let me see if I can show you something to refresh your
		SOUTHERN DISTRICT REPORTERS, P.C.

	214
	- cross LBUCmax3
	If we could pull up 3527-007 at page 2 recollection again.
	just for the Court, the deputy, and the witness, please. We'11
	direct your attention, Mr. , from the bottom if you
4	count up six or seven lines, if you look at those entries right
5	there.
6	A. Yes.
7	And you can look to the left-hand side, as well, in Q. Okay.
8	terms of the date.
9	A. Yes.
10	Does that refresh your recollection about flying in the Q.
11	month of August to Interlochen?
12	A. Sure it does, yeah. This certainly would be a trip that we
13	So it would be in the would do. I recognize the identifiers.
14	trip that we would do during that timeframe, yes.
15	So, you recall, I believe, right, that Epstein eventually Q.
16	had a cabin at Interlochen; isn't that right?
17	A. That is correct.
18	So he would be going there at the end of the summers to Q.
19	stay in his cabin and see the performances at the end of the
20	Interlochen Summer Camp; isn't that right?
21	It was my understanding, which it could have been hearsay A.
22	information, that I thought the cabin was bought or built for
23	Itzhak Perlman, but that was just a rumor I heard, but I don't
24	know whether or not Mr. Epstein actually stayed in the cabin or
25	he donated it to the Interlochen School. I don't know a whole

	- cross LBUCmax3

	lot of facts on it, just sheer of what I know, what I remember.
	But on those trips, Ghislaine wasn't with him every time he Q.
	went, was she?
4	A. I don't remember whether she was or not. I know
5	Mr. Epstein was because he always traveled on the aircraft.
6	Let's take a look at that same document again to see if I Q.
7	can refresh your recollection. One moment.
8	A. Sure.
9	Q. I'll call up that same page if I could, 3527-007 at page 2,
10	just for the Court, the deputy, and the witness. We'll look at
11	the same entries as you did before, Mr.
12	A. Okay.
13	THE COURT: Describe those, please.
14	MR. EVERDELL: Sorry. It's the sixth and seventh
15	entries up from the bottom.
16	These are the ones we were looking at before; isn't that Q.
17	right, Mr.
18	A. That's correct.
19	Q. And if you look there, there is some indications of the
20	passengers?
21	A. Yes, I see that.
22	And does that refresh your recollection about whether or Q.
23	not there were flights to Interlochen that Ms. Maxwell did not
24	fly on?
25	I mean, it appears that way. A. Obviously this isn't my
	SOUTHERN DISTRICT REPORTERS, P.C.

	216
	- cross LBUCmax3
	document, but I don't see Ms. Maxwell's name on there. :t's
	just --
	MS. COMEY: Your Honor, objection.
4	THE COURT: Sustained. I'll have the jury disregarded
5	observations of the document that are not in evidence other
6	than to refresh his recollection, which we've moved beyond.
7	MR. EVERDELL: Understood, your Honor. That's fine.
8	Thank you, Mr. We can take that down.
9	BY MR. EVERDELL:
10	Mr. , I think you also flew Mr. Epstein a number of Q.
11	times to Columbus, Ohio; isn't that right?
12	A. That's correct.
13	Columbus, Ohio is where Les Wexner lives? Q.
14	A. That's correct.
15	Les Wexner is the billionaire owner of the Limited? Q.
16	A. That's correct.
17	Q. That's the clothing company?
18	A. Yes.
19	It owns Victoria's Secret and Abercrombie & Fitch, among Q.
20	other companies?
21	A. That's correct, yes.
22	Q. And Les Wexner was a friend of Jeffrey Epstein's?
23	I believe they were friends. A.
24	He was one of Epstein's clients, wasn't he? Q.
25	To my knowledge, Mr. Epstein would call him a client, yes. A.

		217 - cross LBUCmax3

	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.
4	Q.	So he had a few reasons to go to Columbus, Ohio?
5	A.	That's correct.
6	Q.	Now, you were asked a few questions by the government about
7		a woman we are referring to as
8	A.	Yes.
9	Q.	Do you recall that?
10	A.	Yes.
11	Q.	is not her real name; right? Just to be clear,
12	A.	Correct.
13	Q.	But you do know what her real name is?
14	A.	Yes.
15	Q.	It's been shown to you?
16	A.	That's correct.
17	Q.	on Epstein's plane on one Now, you recall seeing
18		occasion; is that right?
19	A.	One occasion for sure at the time that I had met her.
20	Q.	That's the only time you actually have a recollection?
21	A.	That I have a recollection of, correct.
22	Q.	And you recall this I think being in the 1990s; right?
23	A.	Yes.
24	Q.	Now you said, I believe, that you remember meeting her; is
25		that right?

	- cross LBUCmax3
	A. Yes.
	And that she was a singer; right? Q.
	A. Yes. That's the way Mr. Epstein introduced her as.
4	And you said that I think she had striking blue eyes; is Q.
5	that right?
6	A. Correct.
7	Q. You'll forgive the question, Mr. , but I think you
8	also remembered that at the time you saw her, you remembered
9	she had large breasts; isn't that right?
10	She was a mature woman, in my opinion. A.
11	Well, she looked to you like she was in her 20s, as we said Q.
12	before?
13	A. Sure, yes.
14	Now, you remember that this meeting took place I think you Q.
15	said in Palm Beach?
16	A. It was on the ramp in West Palm Beach, correct.
17	Now, it was sometimes the case that Epstein would invite Q.
18	people onto the plane before takeoff to show them the plane;
19	isn't that right?
20	A. Correct.
21	And sometimes Epstein brought them into the cockpit to meet Q.
22	the pilots?
23	A. That's correct, yes.
24	And these people didn't always fly on the planes; isn't Q.
25	that right?
	SOUTHERN DISTRICT REPORTERS, P.C.

EFTA00068680¶

	219
	- cross LBUCmax3
	He would bring passengers on just to show A. That's correct.
	them the interior and the cockpit, correct.
	Q. Sometimes he would show them around, they would look
4	around, maybe meet the pilots, and then leave before takeoff?
5	A. That's correct, yes.
6	Sitting here today, you don't know whether the woman you Q.
7	, actually flew on that flight that you recall meeting met,
8	her in the plane?
9	I wouldn't be able to swear that she actually flew on it. A.
10	I know I met her in the cockpit.
11	And you don't remember where that flight was going? Q.
12	A. No, I don't.
13	Q. And you don't remember anybody else who was on that flight?
14	A. I do not.
15	specifically, Q. And again, you don't recall seeing
16	seeing on the plane or any plane at any other time except
17	that one time in Palm Beach that you recall?
18	I can't visualize her sitting in the passenger compartment A.
19	like I would, say, president Clinton. It was so long ago, but
20	to answer your question, I can't visually see her sitting in
21	the -- I see her standing in between the two pilot seats.
22	That's my recollection of her.
23	On that one occasion? Q.
24	On that one occasion, yes, sir. A.
25	Now, you met, I believe, with the government on several Q.

	220
	- cross LBUCmax3
	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
4	document that I've been showing you just today to refresh your
5	recollection; isn't that right?
6	Was that reference to the logbook looking -- A.
7	Q. Yes.
8	A. Okay. I don't remember if I did see any from the
9	I'm going to go with government on that. I'm drawing a blank.
10	yes.
11	Well, do you recall them pointing out certain flights to Q.
12	you?
13	A. Yes.
14	To see if you recall them? Q.
15	A. Yes.
16	You do remember that? Q.
17	A. Yes, I do. Yes.
18	And in particular, they pointed out certain flights to you Q.
19	where a female passenger was listed with just her first name.
20	Do you remember that?
21	A. Yes.
22	Q. And that first name was the same as true first name;
23	is that right?
24	A. Correct.
25	And that did not list the passenger's last name, right, Q.
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	221
	- cross LBUCmax3
	just her true first name?
	A. Correct. Yes.
	And there were three of those flights; is that right? Q.
4	A. As far as that same first name?
5	Q. Yes.
6	A. I'm sure, yeah, there is at least three.
7	There was one in '96, one in '97, and one in '98 they Q.
8	showed you; is that right?
9	I don't remember the dates, Mr. Everdell. A.
10	Q. Do you remember those three flights they showed you?
11	A. Yes.
12	Well, when you met with the government and they showed you Q.
13	these three flights, you couldn't recall whether the woman we
14	are referring to as actually flew on those flights or
15	whether it was somebody else with her same first name?
16	There was a -- the first names were the same, but A. Correct.
17	there were no last names.
18	Now, sitting here today, you still don't know whether the Q.
19	flew on any of those flights; isn't women we're calling
20	that right?
21	I mean, it was just -- I couldn't A. Not to my knowledge.
22	tell one from the other with no last name and 20 -- like you
23	said, 20, 22 years ago.
24	Q. Sure. But there were other people in Epstein's world who
25	had that same true first name; isn't that right?

	222
	- cross LBUCmax3
	A. That is correct, yes.
	For example, Epstein had an assistant with that same first Q.
	name; isn't that right?
4	A. That is correct.
5	And it was spelled the same way, wasn't it? Q.
6	A. Yes.
7	Q. And you met that person, didn't you?
8	A. Yes, I did.
9	MR. EVERDELL: One moment, your Honor.
10	Your Honor, I apologize for the delay. We have a
11	slight choreography issue that we're dealing with here. I
12	wonder if it might be appropriate if we could take a brief
13	break to deal with it or I can try to do it without the issues
14	of the choreography.
15	Your Honor, I think a brief break would MS. COMEY:
16	help with the choreography. I apologize.
17	You mean to send the jury back to the jury THE COURT:
18	room?
19	MS. COMEY: I think that might be necessary, your
20	There is an exhibit that needs to be submitted under Honor.
21	seal instead of on the screens.
22	THE COURT: Okay. Is it possible to move past this
23	moment and then return to it later?
24	MR. EVERDELL: Your Honor, actually, we can do that.
25	If I'm permitted to fix the problem and then display it later,
	SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

	223
	- cross LBUCmax3
	we just have to return to this topic when we can figure this
	As long as I'm able to return to this topic and display out.
	things to the jury, that's fine.
4	MS. COMEY: That's fine with me, your Honor.
5	THE COURT: I don't usually tell lawyers what
6	topics -- you're not going to get an asked and answered
7	objection, if that's --
8	MR. EVERDELL: Yes. Understood, your Honor.
9	So we'll keep going for now. I presume THE COURT:
10	we'll hit the lunch break time and then you can do the
11	choreography.
12	MR. EVERDELL: That's fine, your Honor. We'll do
13	that. We're breaking for lunch when?
14	THE COURT: If you're We have jury lunches at 12:30.
15	otherwise done by then, we'll break early and do that.
16	MR. EVERDELL: Let me see if I can also fix it in the
17	meantime.
18	THE COURT: Mr. Everdell, my deputy reminds me, we
19	have a close room with bathrooms, we can just do a short break
20	for the jury.
21	MR. EVERDELL: Thank you, your Honor.
22	So we'll do a five-minute break, members THE COURT:
23	will take you just to that first of the jury. Ms.
24	room where the restrooms are. Thank you.
25	(Recess)

	- cross LBUCmax3
	(Jury not present)
	THE COURT: Are you set, Mr. Everdell?
	MR. EVERDELL: Your Honor, I have the copies. What I
4	need to do is insert them into the folders.
5	MS. COMEY: No objection, your Honor.
6	THE COURT: Go ahead, Mr. Everdell.
7	(Pause)
8	Are you ready, Mr. Everdell?
9	MR. EVERDELL: Yes.
10	THE COURT: The procedure will be you will direct the
11	jury to open the folder under the chair and turn to a
12	particular page?
13	MR. EVERDELL: Yes. This one will be done on paper,
14	your Honor. We'll have it on the screen for the Court, the
15	deputy, and the witness, but the jurors will just have it in
16	paper, as will the government, and it will not be displayed to
17	the public.
18	This is choreography to maintain the THE COURT:
19	anonymity of the witnesses who might be permitted to testify
20	under pseudonyms?
21	That's exactly right, your Honor. MS. COMEY: And for
22	that reason, we're going to ask that the two exhibits that the
23	defense is about to offer be offered under seal.
24	I am grateful to both counsel for working THE COURT:
25	Thank you. that through.

SOUTHERN DISTRICT REPORTERS, P.C.¶

22.1¶

		225
	- cross LBUCmax3
	MR. EVERDELL: Yes, your Honor.
	THE COURT: We'11 bring in the jury.
	(Continued on next page)
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	226
	- cross LBUCmax3
	(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.
4	So, we are ready to proceed, Mr. Everdell, whenever
5	you're ready.
6	MR. EVERDELL: Thank you, your Honor.
7	BY MR. EVERDELL:
8	Hi again, Mr. Q.
9	A. Hi.
10	So when we broke, we were talking about other people in Q.
11	Epstein's world who had that same first name as we were talking
12	about as ; right?
13	A. Yes.
14	Q. And you said that Epstein had an assistant with that same
15	first name?
16	A. Yes, there was another person with that same name.
17	Q. And spelled the same way?
18	A. Correct.
19	And you met that person? Q.
20	A. Yes.
21	MR. EVERDELL: Now, just for the Court, the deputy,
22	and for the witness, if you could please display LV3A and LV3B,
23	if you can display them together.
24	Q. Do you see those, Mr.
25	A. Yes, I do.

	227
	- cross LBUCmax3
	Those are two photographs; is that right? Q.
	A. That's two photographs.
	Q. Do you recognize the person in those photographs?
4	A. Yes, I do.
5	Is it the same person in both photographs? Q.
6	A. Yes.
7	Q. And you know that person's name?
8	A. Yes.
9	Q. Without telling us the name, is that the person we've been
10	referring to just now that has the same first name as
11	true first name?
12	A. That's correct, yes, it is.
13	And is that a fair and accurate depiction of that woman? Q.
14	A. Yes.
15	MR. EVERDELL: The defense offers LV3A and LV3B.
16	MS. COMEY: No objection so long as they are sealed,
17	your Honor.
18	MR. EVERDELL: We offer them under seal, your Honor.
19	THE COURT: LV3A and LV3B are admitted under seal
20	consistent with my ruling allowed certain witnesses to testify
21	under pseudonyms to protect their privacy.
22	(Defendant's Exhibits LV3A, LV3B received in evidence)
23	MR. EVERDELL: Thank you, your Honor. Now if I could,
24	with the Court's permission, members of the jury, you can take
25	out the manilla folders that are under your chairs, but please

LBUCmax3		- cross
----------	--	---------

	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
4	jury box, as you look at the photos, because they are under
5	seal, please do it in such a way that you do not display what
6	you're looking at to the members of the gallery. So keep that
7	manilla folder upright so no one could see, if you would.
8	Is that right all right, your Honor?
9	THE COURT: Yes.
10	Is it okay with the government? MR. EVERDELL:
11	Yes, your Honor. MS. COMEY:
12	MR. EVERDELL: If you would open the folders and
13	please look at what's been marked as LV3A and LV3B. When
14	you've had a chance to look, you can return the folders under
15	your chair. And you can take that down.
16	BY MR. EVERDELL:
17	, you spoke to this person in the photos on Now, Mr. Q.
18	a number of occasions; is that right?
19	A. That's correct.
20	In fact, you've spoke to her frequently enough that you Q.
21	even had her phone number in your cellphone; right?
22	A. That's correct.
23	And she traveled frequently with Mr. Epstein on his planes; Q.
24	isn't that right?
25	A. Yes.
	SOUTHERN DISTRICT REPORTERS, P.C.

	229
	- cross LBUCmax3
	, is she? But that woman is not Q.
	A. Correct.
	Q. And you testified earlier that you often didn't meet the
4	passengers on the flights, you were just given their names
5	sometimes before takeoff; right?
6	A. Correct.
7	So, for all you know, there may have been many other people Q.
8	with that same first name as first name who traveled on
9	Epstein's planes?
10	A. True.
11	But the bottom line is, you don't know whether was on Q.
12	any of those three flights where there is a passenger listed
13	true first name? with
14	Not the three flights you made reference to. Without the A.
15	last name, I didn't know which one you were referring to or who
16	it was.
17	I want to ask you just about a few more Q. Thank you.
18	flights.
19	A. Sure.
20	Q. Are you familiar with Prince Andrew, the Duke of York?
21	A. Yes, I am.
22	He is the son of Queen Elizabeth II of England, is he not? Q.
23	A. Yes.
24	Q. Did he ever fly on Epstein's planes?
25	A. Yes, he did.
	SOUTHERN DISTRICT REPORTERS, P.C.

	230 - cross
	LBUCmax3
	Do you recall the first time when he flew on the plane? Q.
	A. I do not.
	Do you recall someone named Q.
4	A. Yes.
5	She was one of Ghislaine's assistants, wasn't she? Q.
6	A. Yes, she was.
7	She started working for Ghislaine in around 1997 or so; Q.
8	isn't that right?
9	A. I don't know the exact date and I actually didn't remember
10	the name until you brought it up, but that's correct, that's a
11	name from the past.
12	Q. Well, did fly on Epstein's planes?
13	A. Yes, she did.
14	Do you recall the first time she flew? Q.
15	A. I do not.
16	Q. Are you familiar with the name Andy Farmer?
17	A. Yes.
18	Do you recall meeting or seeing anyone named Andy Farmer on Q.
19	any flights?
20	A. I don't remember. I know the name, but I think we're going
21	back a long way.
22	Well, to your knowledge, is there any record of anyone Q.
23	named Andy Farmer ever flying on
24	A. I don't know of any record.
25	MR. EVERDELL: Just one moment, your Honor.

	23_ - cross
	LBUCmax3
	I'll ask we put up for the Court, the deputy, and
	Mr. LV4 and LV5.
	, do you see those documents in front of you? Q. Mr.
4	A. Yes, I do.
5	Each of those documents has a name on it; isn't that right? Q.
6	A. Yes.
7	MR. EVERDELL: Without objection, I believe we will
8	offer these under seal as LV4 and LV5.
9	No objection, as long as they're under MS. COMEY:
10	seal, your Honor.
11	LV4 and LV5 are admitted to the extent of THE COURT:
12	my rulings that certain witnesses may testify pursuant to
13	pseudonyms in order to protect them.
14	(Defendant's Exhibits LV4, LV5 received in evidence)
15	MR. EVERDELL: At this point, I will ask the members
16	of the jury if the government is okay to pick up their folders
17	one more time.
18	MS. COMEY: No objection, your Honor.
19	THE COURT: Go ahead.
20	MR. EVERDELL: It's the same procedure as before. I'm
21	going to ask you to look at the documents that are underneath
22	the two photographs you've already looked at. Please do not
23	show any of them to the members of the gallery.
24	BY MR. EVERDELL:
25	Q. Mr. , I'm going to start with what's now in evidence
	SOUTHERN DISTRICT REPORTERS, P.C.

	- cross LBUCmax3
	as LV4; all right?
	A. Yes.
	I'm going to refer to the person there as Kate, okay? Q.
4	A. Okay.
5	Q. Now, LV4 has a true name on that exhibit; is that right?
6	A. Correct.
7	Q. Do you recognize true name, the one that's on the
8	paper of LV4?
9	A. Not really.
10	Do you recall meeting or seeing anyone with true Q.
11	name on any of the flights?
12	A. It's not jumping out at me at all. Not to my knowledge.
13	To your knowledge, there is no record with Q. true name
14	ever flying on any of Epstein's flights?
15	I don't recall any of them. A.
16	That has a full name on it, too, Q. Now please look at LV5.
17	doesn't it?
18	A. Yes.
19	And that person's first name is -; Q. correct?
20	A. Correct.
21	I'm going to refer to that person by her first name, Q.
22	, okay?
23	A. Okay.
24	Do you recognize full name that's on the paper, Q.
25	LV5?

	233
	- cross LBUCmax3
	A. I do not.
	Q. Do you recall meeting or seeing anyone with full
	name on any flights?
4	A. I do not.
5	And to your knowledge, there is no record of anyone with Q.
6	full name flying on any of Epstein's flights?
7	A. Not to my knowledge. I don't have any memory at all.
8	Mr. Q. , during your testimony so far, you've mentioned
9	the names of some pretty important people; isn't that fair to
10	say?
11	A. Yes.
12	You already said that former president Bill Clinton flew on Q.
13	some of the flights?
14	A. Yes, he did.
15	Q. And Prince Andrew on some of the flights?
16	A. Yes.
17	Q. Itzhak Perlman, the famous violinist, on some of the
18	flights?
19	A. Yes.
20	Q. Donald Trump, before he was president, also flew on
21	Epstein's flights; isn't that right?
22	A. Yes, he did.
23	Q. He flew on them a number of times; right?
24	A. There was more than once I believe, yes.
25	Sometimes he flew with his family members, too; right: Q.
	SOUTHERN DISTRICT REPORTERS, P.C.

	234 - cross LBUCmax3

	I don't know -- I don't remember that. A. I certainly
	remember President Trump, but not nearly the other people
	associated with him. Like I said, if it was something special
4	that would get embranded in my head, I certainly remember the
5	president.
6	Did Robert Kennedy Jr. also fly on his plane? Q.
7	A. I don't remember. I'm not remembering that one.
8	the former astronaut? Q. What about Senator John
9	I do remember Senator A. yes.
10	Former Senator George Mitchell also flew on his plane? Q.
11	I do remember. A.
12	The actors Kevin Spacey and Chris Tucker also flew on his Q.
13	plane?
14	A. I remember them, as well.
15	It's fair to say that these are all pretty high profile Q.
16	people; is that right?
17	A. Correct.
18	And these are people who the public at large would be Q.
19	interested in?
20	A. Sure.
21	And these are all people who are subject to a great deal of Q.
22	media attention and scrutiny; is that right?
23	A. I would assume so, yes.
24	And these are all people who might have legitimate privacy Q.
25	concerns about their goings on?

	235
	- cross LBUCmax3
	A. Correct. Yes.
	Mr. , I think you were asked as part of your Q.
	employment to sign a nondisclosure agreement?
4	A. That is correct.
5	Q. Now, when you were asked to sign a nondisclosure agreement,
6	you didn't think it was unusual, did you?
7	A. Not at all.
8	And you certainly didn't take it to mean that you needed to Q.
9	sign it so you wouldn't disclose some kind of illegal activity
10	that was happening on the plane, did you?
11	A. No, of course not.
12	You never saw anything that came close to that; right? Q.
13	A. Correct.
14	You just took it to mean you couldn't write a book about Q.
15	the stuff and the people you were interacting with; right?
16	That's correct. Several of my colleagues have signed the A.
17	same or similar documents in my profession. It's a fairly
18	normal request.
19	So for people who fly private jets, this is a fairly common Q.
20	occurrence?
21	A. That is correct, sure.
22	Q. You have a lot of people, high profile people we just
23	mentioned, who don't want necessarily all their business
24	written about in a book; right?
25	A. Exactly.

	- cross LBUCmax3
	I want to ask you a little bit about where you stayed when Q.
	you flew to Epstein's residences. All right?
	A. Okay.
4	Now, I believe your home is near Palm Beach; is that right? Q.
5	A. Yes, it was.
6	So when you flew to Palm Beach, you stayed in your home; Q.
7	right?
8	A. Correct.
9	Q. That's where you're based?
10	A. Correct.
11	When you flew to New York, where did you stay? Q.
12	The first part of my employment with Mr. Epstein, I stayed A.
13	in a hotel, but then later on, I was offered to stay at a
14	building he owned, an apartment building on East 62nd or 66th
15	So I had my own apartment. Street.
16	Q. Was that 301 East 66th Street?
17	A. That is correct.
18	Q. Is that where your partner, copilot Dave Rogers also
19	stayed?
20	A. That's correct.
21	Q. And that's an apartment building?
22	A. That is correct.
23	Q. These are basically corporate apartments?
24	A. Correct.
25	Do you know if Epstein owns that building or rents those Q.

	- cross LBUCmax3
	apartments?
	I don't know the actual business of it. It was to my A.
	knowledge that he owned the building.
4	But it's safe to say that you and Q. stayed there
5	on your trips to New York?
6	A. That is correct.
7	Do you know if any other Epstein employees stayed there? Q.
8	A. Yes.
9	So you saw some other employees in the building when you Q.
10	were there; right?
11	A. Correct.
12	Q. For example, you saw in the 66th Street
13	building; is that right?
14	A. That's correct.
15	Q. Do you remember any others you saw there?
16	A. The other person was the one we can't say the name.
17	Q. Okay. So you saw the person whose photographs we just
18	looked at, LV3A and LV3B; right?
19	A. That is correct, yes.
20	Q. You saw that woman in that apartment building?
21	A. That is correct, yes.
22	But you never saw the woman we're referring to as Q.
23	there, did you?
24	No, not -- no. A.
25	Q. All right. Now, for the ranch in New Mexico, your
	SOUTHERN DISTRICT REPORTERS, P.C.

	238
	- cross LBUCmax3
	recollection is that Epstein bought the ranch I think sometime
	in the mid 1990s; is that right?
	A. That's correct.
4	And when he first bought the property, that large main Q.
5	house that we saw pictures of hadn't been built yet right?
6	A. That's correct.
7	That house was under construction for several years; right? Q.
8	A. That's correct.
9	I think you said it was finished towards the end of the Q.
10	'90s, 2000?
11	A. Correct.
12	So you stayed when you went to the ranch in the mid to late Q.
13	'90s -- well, where did you stay?
14	A. In the early part of the mid '90s, I stayed at the Ranch
15	Central in the bunkhouse rooms, and then later on I built a
16	home on the ranch.
17	I'll ask you about that home in a bit. But for the first Q.
18	part, you stayed in Ranch Central; right?
19	A. Ranch Central, correct.
20	Q. And the ranch hands and the property manager stayed there,
21	as well?
22	A. They stayed in the other buildings associated with Ranch
23	Central, but mostly the Ranch Central lodge or bedrooms were
24	for guests that were on the aircraft. But everybody stayed,
25	really, at Ranch Central, like you said, employees or workers

	239
	- cross LBUCmax3
	on the ranch that lived there.
	And you said that Epstein, before the main house was built, Q.
	stayed in that triple-wide trailer you called the lodge; is
4	that right?
5	A. That's correct.
6	And you've described it already, I think from the Okay. Q.
7	outside, it had a deck; is that right?
8	A. That's correct.
9	And it sort of looks nicer than a trailer does from the Q.
10	outside, it was outfitted that way?
11	A. Correct, yes.
12	About how big was it? Q.
13	A. It was probably around two 2,000 square feet.
14	Q. You went inside it?
15	A. Yes.
16	How many times were you inside that triple-wide trailer? Q.
17	A. Many times.
18	And you described the interior before, but you mentioned a Q.
19	number of bedrooms. Can you just describe a little bit when
20	you walk in the front door where things are situated from the
21	front door entrance, the different rooms?
22	Sure. A. When you walked in the front door, there was
23	immediately to your left, there was a fireplace on the wall.
24	Across from the fireplace, there was a couch that faced the
25	fireplace. You went further in, you're in the middle of the

LBUCmax3		- cross
----------	--	---------

4¶

7¶

8¶

9¶

10¶

5 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. Were the guest bedrooms next to each other or how were they set up?¶

6 A. There was a bedroom with a bathroom in between. They weren't a Jack and Jill bathroom, but it was still a bedroom, a bathroom in between, and then the other bedroom, but they were on the right side of the trailer. The left side of the trailer was the master bedroom. So it was a split floor plan.¶

11 Q. But you didn't sleep there; right?¶

12 A. On occasion I have slept there.¶

13 14 15 16 17 Q. Where did you sleep, in one of the guestrooms? A. In one of the guestrooms, but this was a vacation where Mr. Epstein was on the ranch. It was before I built my home, so I was able to spend the time at the lodge. We're going really back far.¶

18 19 Q. But eventually, and I think maybe it was in the 2000s or so, Epstein gave you some land; is that right?¶

20 A. That's correct.¶

21 22 Q. Epstein gave you about 40 acres of land from his ranch so that you could build a house; isn't that right?¶

23 A. That's correct.¶

24 Q. And he didn't charge you for that land?¶

25 A. No, he did not.¶

	241
	- cross LBUCmax3
	Q. And you built a house there?
	A. I built the house there, yes.
	So from about 2000 onwards when you flew to the ranch, Q.
4	you'd stay at your home?
5	A. That is correct.
6	Let me ask you briefly about the trips to Epstein's island Q.
7	in the Virgin Islands. You said that's Little St. James
8	Island?
9	A. That's correct.
10	Q. When you flew to the Virgin Islands, you didn't fly
11	directly into little St. James, you said; right?
12	A. No.
13	It doesn't have an airstrip? Q.
14	A. That's correct.
15	You flew to St. Thomas, which is the bigger island right Q.
16	by?
17	A. That's correct.
18	You flew Epstein and his guests to Little St. James in a Q.
19	helicopter?
20	A. Correct.
21	Q. Because you're a trained helicopter pilot?
22	That is correct. A.
23	Where did you stay when you went on the trips to the Virgin Q.
24	Islands?
25	A. Typical hotel, Marriott Resorts that were there.
	SOUTHERN DISTRICT REPORTERS, P.C.

	242
	- cross LBUCmax3
	So you wouldn't stay in the island residence, you'd stay at Q.
	St. Thomas?
	A. I would bring the helicopter back and the crew would stay
4	on St. Thomas in a regular hotel.
5	Now, we saw a number of photographs of Little St. James Q.
6	Island when you were on your direct testimony.
7	Do you remember those?
8	A. Yes.
9	I'm not going to call them up, there were a number of them. Q.
10	But you recall that they had structures on the property in
11	those photographs; right?
12	A. Yes.
13	Q. They had the fully built houses on those photographs;
14	right?
15	A. Yes.
16	Q. Well, when Epstein first bought the property, those houses
17	weren't there; right?
18	Some of the buildings were not there. He added buildings, A.
19	yes.
20	So there was a fair amount of construction to make the Q.
21	island look the way it was in those photographs; right?
22	A. That is correct.
23	And was it about -- was it roughly '97 when he purchased Q.
24	the property?
25	It was the late '90s, correct. I don't know the exact A.
	SOUTHERN DISTRICT REPORTERS, P.C.

	243
	- cross LBUCmax3
	year, but you're correct that it was late '90s.
	Q. And that construction was going on for several years,
	wasn't it?
4	A. Yes.
5	Q. Including the helipad that was there?
6	The helipad moved a couple times, but yeah, it was -- A.
7	kind of easy to do a helipad compared to a building, but yes,
8	the helipad moved around.
9	Q. And Ghislaine supervised all that construction?
10	A. She was involved, absolutely.
11	. You are, I believe, Q. Separate question, Mr.
12	somewhat of a car guy; is that right?
13	A. That's correct.
14	Q. You like cars?
15	A. Yes, I do.
16	Q. You enjoy looking at the latest models?
17	A. I like the classics.
18	Well, Epstein shared that Q. You like the classics. Okay.
19	interest with you; is that right?
20	A. That is correct.
21	Q. He also liked cars?
22	A. Yes.
23	And you and he would discuss cars from time to time; isn't Q.
24	that right?
25	A. Yes.

		241
		- cross LBUCmax3
	Q.	So he knew about your shared interest, you talked about
		this a lot?
	A.	That is correct.
4	Q.	Now he, I believe, bought some cars that he registered in
5		your name; isn't that right?
6	A.	Yes.
7	Q.	There was a 2008 Land Rover?
8	A.	Yes.
9	Q.	There was a 2005 Mercedes Benz CLK?
10	A.	Yes.
11	Q.	There was a 2005 Jaguar X-Type?
12	A.	Yes.
13	Q.	These were all kept at his residence in Palm Beach?
14	A.	That's correct.
15	Q.	And you could use the cars if you wanted to; right?
16	A.	If I wanted to, sure.
17	Q.	But you didn't consider them your cars?
18	A.	No.
19	Q.	They were Epstein's cars; right?
20	A.	I'm sorry?
21	Q.	They were Epstein's cars; right?
22	A.	That's correct.
23	Q.	And other people at the Palm Beach residence could use
24		them, as well?
25	A.	That is correct.

		245
		- cross LBUCmax3
	Q.	I believe Epstein also bought a 34-foot JVC powerboat;
		right?
	A.	Yes.
4	Q.	That was registered to you, as well?
5	A.	Yes, it was.
6	Q.	And you could use it if you wanted to; right?
7	A.	That's correct.
8	Q.	But it wasn't -- you didn't consider it yours?
9	A.	No.
10	Q.	Are you also aware of a green Cobra sports car that Epstein
11	had?
12	A.	Yes.
13	Q.	That one was not registered in your name; right?
14	A.	No.
15	Q.	Do you know where Epstein got that from?
16	A.	Yes.
17	Q.	Where did he get it from?
18	A.	That came from Mr. Wexler in Columbus, Ohio.
19	Q.	Do you know approximately when he got that car?
20	A.	It had to been -- I know the car was built in '94,
21		Mr. Wexner held it for — I'm only guessing now — a year or two.
22		So I would think Mr. Epstein got it '96, '97.
23	Q.	Do you know when he got rid of it?
24	A.	When he got rid of the Cobra?
25	Q.	Yeah.


	LBUCmax3	- cross
	A. Yes.
	Q.	When was that?
	A.	That was probably -- it was in my possession for 20 years.
4		Probably around 2000.
5	Q.	Now, Mr. , in your testimony a little Thank you.
6		while ago, you said that Epstein gave you 40 acres of land on
7		his ranch in New Mexico so you could build a house; right?
8	A. Yes.
9	Q.	I think you would agree that was a pretty generous act on
10	his part; yes?
11	A. Yes.
12	Q.	Now, over the years, Epstein also gave you other gifts, as
13		well; isn't that right?
14	A.	He gave other -- yes, he gave gifts to me as well as other
15		employees, but yes.
16	Q.	Isn't it true that he paid for your children's tuition?
17	A. Yes.
18	Q.	You have two daughters; is that right?
19	A. Correct.
20	Q.	And he paid for both of their tuitions?
21	A. Correct.
22	Q.	So were these private school tuitions when they were in
23	high school?
24	A. Yes.
25	Q.	Did he also pay for their college tuitions, as well?

	- cross LBUCmax3
	A. Yes.
	Did you ever mention this to Ghislaine that Epstein was Q.
	paying for your daughters' tuitions?
4	A. Yes.
5	So she was aware of this fact, too? Q.
6	A. Absolutely.
7	Q. Did you ask Epstein to pay for your daughters' tuitions?
8	A. He offered it when I first got hired. He said that he
9	would take care of all employees' children's education. So we
10	knew it was pretty much a given.
11	So he offered to do this for all of the employees that Q.
12	you're aware of?
13	A. Yes, correct.
14	You didn't have to ask him for it? Q.
15	A. No.
16	So fair to say that Epstein took an interest in seeing your Q.
17	young daughter succeed; isn't that right?
18	A. That's correct. He believed in higher education.
19	Q. And this was when they were high school aged and college
20	aged; isn't that right?
21	A. Yes, and even younger, grade school.
22	Q. You didn't think there was anything inappropriate about
23	that; right?
24	A. No.
25	It was just a generous act on his part, wasn't it? Q.
	SOUTHERN DISTRICT REPORTERS, P.C.

EFTA00068709¶

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, did he? A. No. Q. Mr. , are you aware that Epstein had back problems? A. He complained about back problems, yes. Q. Are you aware he often used a heating pad on his back? A. Yes. Q. And are you aware that he often got massages on a regular basis for the same reason? A. Yes, he did. Yes. Q. Now, for example, when you flew to the ranch in New Mexico, the ranch manager would sometimes arrange massages for Epstein; isn't that right? A. It's what I heard from the ranch manager, yes. Q. When the masseuses showed up, they were from a professional saloon in Santa Fe? A. To my knowledge, yes. Q. That was called the Ten Thousand Waves; is that right? A. I know that salon existed and it was famous for massage service, yes. Q. And he received massages from both male and female masseuses; isn't that right? SOUTHERN DISTRICT REPORTERS, P.C.¶

(212) 805-0300¶

	249
	- cross LBUCmax3
	I didn't know their sexes, to be honest with you. A.
	Q. But to your knowledge, these were all adult professional
	masseuses?
4	A. Oh, absolutely.
5	, I want to ask you some questions about Now, Mr. Q.
6	where Epstein lived in New York and where Ghislaine lived in
7	New York in the 1990s and the 2000s.
8	A. Okay.
9	Q. Epstein, I think you testified, had two different
10	residences in New York from 1991 two 2005?
11	A. Correct.
12	Q. You visited both of these?
13	A. Yes.
14	One of the reasons you would have gone to his residence was Q.
15	to pick up his luggage or drop it off before or after a flight;
16	right?
17	A. That was typically the main reason, correct.
18	Q. Another reason you said you might have gone there was you
19	had a hobby of installing home video and audio equipment and
20	home theaters; is that right?
21	A. It was home theater. I had been using the word "video
22	equipment," but it was in the '90s when home theaters, the
23	Dolby came out, so everybody was on installing that. So he
24	got -- he was an audio/video person, too, as one on high
25	So we were doing home theaters in all the fidelity.

	250 - cross LBUCmax3
	residences.
	Q. This is something you know how to do well?
	Yeah, I had a knack for that, as well. A.
4	So your mechanics background helps with that? Q.
5	A. Yes, it did.
6	And he liked having sort of the latest audio/video Q.
7	equipment or home theater equipment in his homes?
8	A. Absolutely.
9	So you would occasionally go to all of his homes and Q.
10	install this for him?
11	A. Absolutely, yes.
12	Q. Did this in all his residences, not just New York?
13	A. All of them.
14	Q. Palm Beach, Zorro Ranch, the island?
15	A. That's correct.
16	I want to focus on his residences in New York. Your Q.
17	recollection is that when you first began working for him in
18	'91, he lived on a residence on 69th Street; isn't that right?
19	Yes, that was of the first residences I remember. A. I think
20	I only maybe went there one time. It was very early on
21	obviously, in '91.
22	Was that 34 East 69th Street? Q.
23	A. I know it was 69th Street. I don't remember the number.
24	But you are correct when you say 69th Street.
25	Q. And then sometime after that, maybe in the mid '90s, he

		251
	- cross LBUCmax3
	moved to a townhouse on 71st Street; right?
	A. That's correct.
	Q. That's the one we saw photographs of?
4	Correct, that's the 9 East 71st Street. A.
5	Q. That's right off Fifth Avenue and Central Park?
6	A. Correct.
7	And these are the only two New York residences you recall Q.
8	for Epstein; isn't that right?
9	A. That's correct.
10	That's where you go to pick up his luggage and install Q.
11	video equipment?
12	A. Yes.
13	Now, you also went to Ghislaine's residences during the Q.
14	same period, didn't you?
15	A. Yes.
16	Q. And you went for the same purposes; isn't that right?
17	Yes, it was exactly -- yes, for luggage and such. A.
18	Q. You'd go pick up her luggage from the residence, drop it
19	off there?
20	A. Yes.
21	Q. I think you also did the home theater work for her
22	residences, as well?
23	A. Exactly, yes.
24	Now, Ghislaine had several different residences in New York Q.
25	from 1991 to 2005; isn't that right?

		252
		LBUCmax3 - cross
	A.	Yes.
	Q.	And I believe you said you think you went to all of them:
	A.	Yes.
4	Q.	So when you first started working for Epstein in '91, she
5		lived in an apartment on -- you said a small apartment on the
6		east side of Manhattan; is that right?
7	A.	Yes.
8	Q.	Do you recall if that was 20 East 66th Street?
9	A.	I don't remember the -- I definitely don't remember the
10		66th Street because I would have remembered that was the
11		apartment building where we stayed, but I don't remember the
12		address of her very first place.
13	Q.	And then at some point in the mid '90s, she moved to a
14		different apartment on the east side on 84th Street?
15	A.	I do remember 84th Street, yes.
16	Q.	I think you described that before in your testimony?
17	A.	Yes.
18	Q.	Was that 114 East 84th Street?
19	A.	Yes, it was.
20	Q.	Do you recall her living for a few years in the late '90s
21		and early 2000s at an apartment on East 81st Street?
22	A.	I don't remember 81st Street. I just remember 84th Street.
23	Q.	But you do recall that, at some point, maybe in the early
24		2000s, she moved to a townhouse on East 65th Street?
25	A.	I do remember 65th Street, yes.

	253
	- cross LBUCmax3
	Q. And that was 301 East 65th Street; right?
	No, 301 -- well, 301 was the apartment. A. 66th Street, that
	address on 65th, which I want to say it was 116 or 114 East
4	65th Street --
5	MR. EVERDELL: One moment, your Honor.
6	Q. Sorry I'm going to correct myself. It was 116 East 65th
7	Street?
8	A. There you go. That's correct.
9	These are all the New York residences that you recall for Q.
10	Ghislaine; correct?
11	A. Yes, it is.
12	Q. These are all different residences than the residences that
13	Epstein had as we discussed; isn't that right?
14	A. That's correct.
15	Q. And that's where you'd pick up Ghislaine's luggage from;
16	right?
17	A. Yes.
18	Q. You wouldn't pick it up from one of Epstein's residences;
19	right?
20	A. No, not unless I was picking up Jeffrey's luggage, I went
21	to Mr. Epstein's residence.
22	So at all times from 1991 to the 2000s, Ghislaine Q.
23	maintained a separate residence in New York from Mr. Epstein's;
24	is that right?
25	A. Correct.

LBUCmax3 - cross¶

	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
4	residences; right?
5	A. Yes.
6	Q. And you installed it in his residence in Palm Beach, you
7	said; right?
8	A. Yes.
9	So that Palm Beach residence was 358 El Brillo Way in Palm Q.
10	Beach?
11	A. That's correct.
12	Do you recall a time when the El Brillo Way residence was Q.
13	being renovated and Epstein had to move to a rental residence
14	in Palm Beach?
15	I do remember that time. A.
16	And did you install the sort of home theater or any audio Q.
17	equipment in the rental residence?
18	A. I don't recall installing in the rental residence, no.
19	Q. Do you recall where the rental residence was located in
20	Palm Beach?
21	I know approximately where it I don't know the address. A.
22	was, but I don't remember the address.
23	Q. Do you recall when the renovation took place?
24	I do not. A. I'd only be guessing if I said the mid 1990s,
25	but I can't give you an accurate date. Nothing sticks out in

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300¶

	255
	- cross LBUCmax3
	my head on that.
	Best guess is sometime in the mid '90s? Q.
	A. Mid '90s, yes.
4	Do you recall how long the renovation lasted? Q.
5	It was a pretty serious renovation. A. I'd only be guessing
6	if I said six to eight months.
7	Q. Thank you.
8	MR. EVERDELL: Your Honor should I continue?
9	THE COURT: How much longer do you have?
10	MR. EVERDELL: I'm going to have probably about 20
11	more minutes.
12	I'll let you know. THE COURT: Keep going for now.
13	Keep going for now.
14	MR. EVERDELL: Understood.
15	Q. Mr. , I want to ask you some questions about your
16	Okay? sense of the relationship between Epstein and Ghislaine.
17	A. Okay.
18	Now, you said you flew on numerous flights both of them; Q.
19	right?
20	A. Yes.
21	And you interacted with them on a regular basis for several Q.
22	years from the 1990s and the 2000s; right?
23	A. Yes.
24	So I think you got a sense of what Ghislaine did for Q.
25	Mr. Epstein; right?

		256
		- cross LBUCmax3
	A.	Yes.
	Q.	And you testified that she was one of the assistants he had
		in his office; right?
4	A.	Yes.
5	Q.	He had lots of assistants; isn't that right?
6	A.	That's correct.
7	Q.	Now, in the mid '90s through the end of the 1990s,
8		Ghislaine was the assistant who took care of Epstein's
9		properties; isn't that right?
10	A.	That's correct.
11	Q.	She would make sure the cleaning people came; right?
12	A.	Yes.
13	Q.	Or the -- well, there were -- I should clarify. There were
14		staff at each one of these residences; right?
15	A.	Yes, she took -- yes.
16	Q.	And there were house managers at each one of these
17		residences?
18	A.	That's correct.
19	Q.	So they would take care of, sort of, the day-to-day of each
20		of these residences?
21	A.	Exactly. She was in charge of the house managers, making
22		sure that --
23	Q.	Right.
24	A.	-- it got taken care of.
25	Q.	She supervised the house managers who did the day-to-day?
		SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

	257
	- cross LBUCmax3
	A. Correct.
	If there was something wrong, ultimately it was her Q.
	responsibility if there was a problem?
4	It probably would have been the first phone call to A.
5	Ms. Maxwell to say we got a problem.
6	If there was a problem with a pool guy not coming and the Q.
7	house manager wasn't dealing with it, Ghislaine would deal with
8	it?
9	A. She would jump on it.
10	Q. Same thing, cleaning people didn't come on time and it
11	wasn't being addressed correctly, Ghislaine had to deal with
12	that?
13	A. Yes.
14	She would manage the household staff as a supervisory over Q.
15	the household manager?
16	A. Correct.
17	Q. She would also oversee repairs and renovations and
18	decorating?
19	A. Yes.
20	Q. Things like that?
21	A. Yes.
22	She was a shopper for Epstein; right? Q.
23	She liked to shop. A.
24	She bought furniture and things like that for the Q.
25	residences?

	258
	- cross LBUCmax3
	A. That is correct.
	Q. She bought household items?
	A. Yes.
4	She decorated the planes, too; right? Q.
5	She had a lot put into the airplanes, stocking the airplane A.
6	on what we carry as far as beverages.
7	Q. We saw photographs of the plane, right, this isn't a matter
8	of hanging a few curtains; right?
9	A. No.
10	This is a pretty big job to outfit one of these planes Q.
11	correctly for their flight?
12	A. Sure.
13	And we also saw these properties; right? They were -- Q.
14	That was a large let's talk about the ranch in particular.
15	piece of property; right?
16	A lot of square footage, yes. A.
17	You said 10,000 acres, roughly? Q.
18	A. Yes.
19	It's a pretty big job to manage those properties; right? Q.
20	A. Yes.
21	In particular, just to call out the ranch for a moment, Q.
22	there were animals on that property; right?
23	A. Yes.
24	Q. There were horses in the stables?
25	A. She loved her horses.

	259
	- cross LBUCmax3
	She took care of the horses; right? Q.
	A. Yes, she did.
	Q. She took care of the other animals on the property?
4	A. Yes.
5	This took a lot of Ghislaine's time and energy to do this Q.
6	job, didn't it?
7	A. Yes.
8	And she had to travel to the properties from time to time Q.
9	to do this work; right?
10	A. That's correct.
11	Q. Now, I think in your testimony, you called her Epstein's
12	number 2; right?
13	A. Yes.
14	Q. But from your perspective, she was dealing with the
15	aircraft and the properties; right?
16	A. Yes.
17	She wasn't dealing with Epstein's finances; right? Q.
18	No, not the business side. A. It was Jeffrey household
19	personal.
20	The reason why you call her number 2 is because she was Q.
21	generally overseeing the running of the households; right?
22	A. Correct.
23	But as we said, she wasn't on site at each of these Q.
24	properties every single day running the day-to-day of these
25	households?

	260
	- cross LBUCmax3
	A. No.
	Q. There were house managers that did that on a day-to-day
	basis?
4	A. That's correct.
5	Now, your recollection is that Ghislaine generally worked Q.
6	out of Epstein's offices in New York; isn't that right?
7	A. Yes.
8	Q. And you testified there was a room in Epstein's offices
9	that had about five desks in it that was sort of off to the
10	right of his office?
11	A. That's correct.
12	Q. And that's what you called the personal assistants' room;
13	right?
14	There was no official name for it, but it was my best A.
15	description of who was in that room.
16	And Ghislaine was one of the personal assistants who had a Q.
17	desk in that room?
18	A. That's correct.
19	Q. Now, when you first met Ghislaine in 1991, she seemed to
20	you to be just an employee of Epstein; isn't that right?
21	It might in the first introduction. A.
22	So at that point early on, I'm talking '91, '92 when you Q.
23	first started working, it didn't seem to you like she had a
24	personal relationship with Epstein; right?
25	A. No. I believe when Mr. Epstein introduced her, that he

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 business. And when you start buying homes and properties, he -- Q. I'm sorry to interrupt. A. He knew he was going to get busy. So Ghislaine was his go-to person to handle everything else that was not business-related with his company. Q. So I think you said at some point, though, in the mid '90s, it may have appeared to you that Ghislaine was involved in a personal relationship with Epstein; isn't that right? A. Yeah, I thought they were a couple in the mid '90s. It's just my own take on it. Q. And that was based on your observations of them together at the time and how they interacted with each other? A. Sure. Yes. Q. They made travel plans together, they talked to each other, things like that? A. Yes. Q. But I think you testified that it wasn't totally clear to you that Epstein and Ghislaine had a romantic relationship; right? A. Yeah, I don't know what the definition of a romantic relationship is as opposed to just relationship. To me,¶

	262
	- cross LBUCmax3
	romantic would mean a more involved relationship. I wasn'-
	aware of anything more than a couple.
	Q. You never saw them kiss you said; right?
4	A. No.
5	Q. You never saw them hold hands?
6	A. No.
7	Now, it's fair to say, isn't it, that a lot of women were Q.
8	flying on the plane with Epstein in the mid '90s; isn't that
9	right?
10	A. That's correct.
11	It's fair to say that there were plenty of times that Q.
12	Epstein was flying on the plane with these women without
13	Ghislaine?
14	A. There has been times, sure.
15	It appeared to you that these women were adult women? Q.
16	A. Oh, yes.
17	So from your vantage point, whether Ghislaine or any one of Q.
18	these other women was somebody romantically involved or
19	something else, is a little blurry; right?
20	A. Yes.
21	In fact, I think the only person you really considered to Q.
22	be a girlfriend of Epstein was III ; is that right?
23	That's the way she was introduced, as one of Mr. Epstein's A.
24	original first girlfriends, correct.
25	By the time you started, she was an ex-girlfriend; right? Q.


		- cross LBUCmax3
	A.	Exactly.
	Q.	She was with him in the 1980s?
	A.	Yes, before my time.
4	Q.	before she was married, went by ill Now,
5
6	A.	That's correct.
7	Q.	She was a former Ms. Sweden?
8	A.	That's what I heard.
9	Q.	—; is that right? She later married
10	A.	That's correct.
11	Q.	is that is a
12		right?
13	A.	From my understanding, yes.
14	Q.	He was one of Epstein's clients; isn't that right?
15	A.	I don't know if he was a client. I know he was a friend.
16	Q.	But during the period when Ghislaine and Epstein appeared
17		to you to have some sort of a personal relationship, she
18		continued to work for him as an employee; isn't that right?
19	A.	Who's that, Ms. Maxwell?
20	Q.	Ms. Maxwell, yes.
21	A.	Yes.
22	Q.	Ghislaine. I'm talking Ghislaine still took care of the
23		houses?
24	A.	Yes. Yes.
25	Q.	She still shopped for him?

		- cross LBUCmax3
	A.	Yes.
	Q.	And you talked to her about the work she did for Epstein,
		didn't you?
4	A.	Yes.
5	Q.	She would talk about all the work she was doing on these
6		houses, wouldn't she?
7	A.	Yeah, she would tell what's going on and the troubles of
8		decorating and house managers, et cetera, yes.
9	Q.	She'd talk about how demanding the job was; right?
10	A.	Yes.
11	Q.	Now, at some point, it appeared to you that whatever the
12	personal relationship was between Epstein and Ghislaine sort of
13		fizzled out; is that right?
14	A.	Yes.
15	Q.	And I think that was in about 2000, right, the best of your
16		recollection?
17	A.	It was the early 2000s, correct.
18	Q.	Now, Ghislaine was still traveling with Epstein in the
19		early 2000s; right?
20	A.	Yes.
21	Q.	She was still his friend?
22	A.	Yes.
23	Q.	But by that time, her role in Epstein's life was
24		decreasing, wasn't it?
25	A.	I don't know how the decreasing point did, but it just

	265
	- cross LBUCmax3
	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.
4	It was all business; right? Q.
5	It was all business. A.
6	And Epstein, at that time, brought in other people to help Q.
7	run his day-to-day business, didn't he?
8	A. Yes.
9	Q. You testified already that appeared around
10	that time in the early 2000s; isn't that right?
11	A. That's correct.
12	She was another one of Epstein's personal assistants? Q.
13	A. Yes.
14	Q. And she became the person or one of the people you spoke to
15	about arranging flights; right?
16	A. That's correct.
17	And do you recall the name Q.
18	Yes, I remember that name. A.
19	Q. She also became one of Epstein's assistants around that
20	same point in the 2000s; isn't that right?
21	A. Yes.
22	And you interacted with her? Q.
23	Yeah, not as much, but yeah, I did. A. It's not like I would
24	, but yes. with Ms.
25	Q. And there were, in fact, many other assistants who appeared
	SOUTHERN DISTRICT REPORTERS, P.C.

	266
	- cross LBUCmax3
	over the years in the 2000s, as well, weren't there?
	A. There was many, yes.
	Now, you testified that by 2004 or so, to the best of your Q.
4	recollection, Ghislaine was traveling much less frequently on
5	Epstein's planes; isn't that right?
6	A. Yes.
7	Q. She was moving on from Epstein, was she not?
8	A. That's correct.
9	Q. Isn't it true that by 2004, Ghislaine was in a committed
10	relationship with another man?
11	A. Yes.
12	Q. You're familiar with Ted Waitt?
13	Yes, I am. A.
14	Q. He's the cofounder of Gateway Incorporated, the computer
15	company, isn't he?
16	A. That's correct.
17	Q. And Ghislaine was in a relationship with Ted Waitt by 2004,
18	wasn't she?
19	I don't know if it was a relationship, but I know she was A.
20	spending a lot of time with Mr. Waitt, and I think he was
21	completing a boat that she was involved in decorating and
22	building a helipad on it. So it was a different transfer to
23	Mr. Weight.
24	Q. And, in fact, I think Ghislaine introduced you to Waitt's
25	pilots, you guys became friends?

	267
	- cross LBUCmax3
	A. Yes.
	Your Honor, this is a convenient MR. EVERDELL:
	stopping point.
4	THE COURT: We'll break here for lunch. Members of
5	the jury, we'll take about a 45-minute lunch break. Enjoy your
6	lunch. Thank you for your continued attention. Witness may
7	step down for the lunch break.
8	(Continued on next page)
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25

	LBUCmax3	- cross
		(Jury not present)
		(Witness not present)
		Matters to take up before the break.
4		No, your Honor. MS. COMEY:
5		MR. EVERDELL: Nothing, your Honor.
6		(Recess)
7		(Continued on next page)
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	269
	- cross LBUVMAX4
	AFTERNOON SESSION
	1:35 P.M.
	THE COURT: Matters to take up, counsel?
4	MS. COMEY: Very briefly, your Honor.
5	Some of the courtroom sketch artists have indicated
6	confusion about the order about who they are allowed to draw
7	And so I think we would propose that before we call a and not.
8	witness who cannot be sketched, that that be put on the record.
9	Okay. The only restriction is with THE COURT:
10	respect to the witnesses who I've permitted to testify
11	anonymously.
12	And any MS. COMEY: That's correct, your Honor.
13	sealed exhibits, if someone were to somehow glimpse a sealed
14	exhibit, though I think that's unlikely given the precautions
15	we're taking.
16	Okay. So let's just talk through the THE COURT:
17	protocol, also what the witness will be called using the
18	pseudonym.
19	Yes, your Honor. MS. COMEY:
20	THE COURT: And then I'll swear them in. I would
21	typically say, State your name for the record. I'll just say,
22	I've granted you permission to testify under the pseudonym,
23	fill in the blank. And then turn the witness over for
24	questioning.
25	MS. COMEY: Thank you, your Honor.
	SOUTHERN DISTRICT REPORTERS, P.C.

	- cross LBUVMAX4
	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.
4	MS. COMEY: Thank you, your Honor.
5	THE COURT: Okay. Thank you.
6	MS. COMEY: Nothing further.
7	THE COURT: Mr. Everdell?
8	MR. EVERDELL: Nothing from the defense, your Honor.
9	Okay. THE COURT: We can bring the witness back.
10	And Ms. , please bring in the jury.
11	(Jury present)
12	THE COURT: Members of the jury, I hope you had a
13	Thank you. pleasant lunch.
14	THE LAW CLERK: Judge, one second.
15	THE COURT: All right. Thank you.
16	Everyone, I hope you had a good lunch. Thank you for
17	your continued attention and diligence.
18	Mr. Everdell, you may continue with your
19	cross-examination of Mr.
20	Mr. , I remind you you are under oath.

21¶

22¶

23¶

24¶

25¶

BY MR. EVERDELL:¶

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300¶

MR. EVERDELL: Thank you, your Honor.¶

THE WITNESS: Yes, ma'am.¶

resumed.¶

THE COURT: Go ahead.¶

	- cross LBUVMAX4
	Good afternoon, Mr. Q.
	Good afternoon, Mr. Everdell. A.
	I just want to begin with a quick question about the ranch, Q.
4	all right?
5	A. Yes.
6	Q. You testified before that it had a lot of acreage?
7	A. Yes.
8	Q. I think you said roughly 10,000 acres or so?
9	A. 10,000, yes.
10	Q. And there was a lot of open space on that ranch, right?
11	A. That's correct.
12	And one of the things that guests, I think, typically like Q.
13	to do when they were there was to go hiking, right?
14	A. Correct. Yes.
15	Lots of places they could go hiking on the ranch? Q.
16	A. Sure they could, yes.
17	But it's true, isn't it, that the property had a lot of Q.
18	rattlesnakes on it, isn't it?
19	A. Yes, there are several rattlesnakes, yes.
20	And it was wild country out there. Q. Okay.
21	A. Yes.
22	And so if you were going to hike on this property, Q. Okay.
23	you needed proper footwear to go hiking, right?
24	A. Yes.
25	So people would typically wear boots to go Q. All right.

	272 - cross
	LBUVMAX4
	hiking?
	A. That would be a first choice, yes.
	Q. And that would be recommended for any guest who wanted to
4	go hiking, right?
5	A. Yes. Correct.
6	Okay. Q. Thank you.
7	And I'll just say, I was reminded by the court
8	reporter that we shouldn't talk over each other, so I'll try
9	not to do it and we'll do the same, okay?
10	A. Yes.
11	Q. Thank you.
12	I want to talk to you a bit about your All right.
13	enter actions with Ghislaine.
14	A. Okay.
15	Q. You testified that you first met Ghislaine in about 1991,
16	when you started to work for Mr. Epstein, right?
17	A. That's correct.
18	Q. And Ghislaine would have been about 29 or 30 years or so
19	when you first met her?
20	A. Yes.
21	And Epstein would have been about 37 or 38 at the time; is Q.
22	that right?
23	A. That is right.
24	Q. And you said that Ghislaine flew on numerous flights with
25	you in the 1990s and 2000s, right?

	273 - cross LBUVMAX4

	A. That is correct.
	And so you knew her and you interacted with her for, it Q.
	would be, about 15 years, from the early 1990s to the mid
4	2000s; is that right?
5	A. That is correct.
6	Q. Now, in that whole time period, Ghislaine never appeared to
7	you to be pregnant, did she?
8	A. No, not at all.
9	No one ever told you she was pregnant? Q.
10	A. No, never said that.
11	And you never saw any pictures of her pregnant at any of Q.
12	the residences?
13	A. No, I did not.
14	Now, you had some regular interactions with Ghislaine about Q.
15	your job, right?
16	A. Correct.
17	Q. For example, I believe Ghislaine reviewed your expense
18	reports?
19	A. Yes, that was one detail, yes.
20	So you said you took your expense reports to the New York Q.
21	office maybe about once a week?
22	Yeah, whenever I was in New York; correct. A.
23	And it was Ghislaine's job to review them and approve them, Q.
24	right?
25	A. It was one of her duties, yes.
	SOUTHERN DISTRICT REPORTERS, P.C.

	- cross LBUVMAX4
	And you also talked to her about scheduling maintenance Q.
	visits for the planes, right?
	A. That's correct.
4	And you talked to her about scheduling your own vacations, Q.
5	right?
6	A. Yes.
7	So generally speaking, these were the main interactions you Q.
8	had with Ghislaine regarding employment issues and your job?
9	Yes, that was a good description of a lot of the A.
10	interaction that I had with Ms. Maxwell; correct.
11	Q. But now when Ghislaine had time when she wasn't working,
12	she spent time on other pursuits, right?
13	A. Yes.
14	Q. She became a trained emergency medical technician, didn't
15	she?
16	A. I know she had some medical training, yes.
17	Q. EMT?
18	A. EMT, yes.
19	Q. And she also became a trained helicopter pilot, too?
20	A. Yes, she did.
21	You, yourself, are a trained helicopter pilot, right? Q.
22	Yes, I am. A.
23	And you traveled with Ghislaine when she went to school to Q.
24	become a trained helicopter pilot, right?
25	A. Yes, we traveled frequently together.

	275
	- cross LBUVMAX4
	Q. Now, Epstein bought his first helicopter, your recollection
	was, sometime around 1990, 2000; is that right?
	Yeah, '99 to 2000; correct. A. Yes.
4	So sometime, I believe, in the early 2000s, Ghislaine went Q.
5	to school to become a trained helicopter pilot; is that right?
6	A. Yes, she did.
7	Q. That school was in Pompano Beach, Florida?
8	A. That's correct.
9	Pompano Beach is about an hour or so drive south of Palm Q.
10	Beach, right?
11	A. Yeah, give or take traffic. It could be longer some days;
12	but, yes, it's approximately an hour from Palm Beach to
13	Pompano.
14	Q. And the training sessions that she was taking were about
15	one to three times per week, right?
16	A. That's correct.
17	Q. Each training session lasted about three to four hours,
18	isn't that right?
19	Because there's a lot of preparation A. Yes, if not longer.
20	before you fly, and you're flying for an hour and a half, and
21	then you're still talking about it afterwards, you know, with
22	So it could be a your instructor, and then your drive home.
23	long duration.
24	So each training session was basically a full-day Q. Right.
25	event, wasn't it?

	276
	- cross LBUVMAX4
	A. Sure, it was.
	You had to drive, take the course, talk to the instructor, Q.
	drive back, all that took about a day, right?
4	A. Yes.
5	So it's fair to say she was away from the Palm Beach Q.
6	residence for the whole day when she was taking these courses,
7	right?
8	A. Yes, good chance, yes.
9	Q. And that helicopter course that she took took about eight
10	months to a year to complete, isn't that right?
11	A. Yes.
12	That course took a fair amount of time, didn't it? Q.
13	Took a lot of time, yes. A.
14	And it goes without saying that at the time, the time that Q.
15	Ghislaine spent at those training sessions in Pompano Beach,
16	she was not at Epstein's residence in Palm Beach, isn't that
17	right?
18	A. That's a correct assumption.
19	Now, you also accompanied Ghislaine to a different Q.
20	helicopter training school in Dallas, Texas; is that right?
21	A. That's correct.
22	Q. Do you remember when that was?
23	A. It was definitely once a year, because we were required to
24	go back for recurrent training. But I don't know the dates,
25	but it was definitely once a year we would go to Dallas for

LBUVMAX4 - cross¶

277¶

	training together.
	And do you remember how long that training lasted on those Q.
	trips?
4	A. That class, it was typically, I believe, four days; two
5	days of ground school, and two or three days of flight. It
6	could be four to five days, if memory serves.
7	And those training sessions that you're referring to in Q.
8	Dallas, you said, took place every year you recall, right?
9	A. Every year is a requirement for us as pilots.
10	Q. Do you remember when in the year those took place?
11	I do not. I remember it being warm, not extremely cold, so A.
12	I would have to do the summer months; but, you know, the dates
13	escape me without any documentation of when we took the
14	courses.
15	You guys had fun on those trips, right? Q. Okay.
16	The training was hard, but we tried to make the best of it. A.
17	I mean, you occasionally went out to a steak dinner while Q.
18	you were there together?
19	A. Yes, we did.
20	Q. Those were fun events, right?
21	A. Yes.
22	Q. Now, once Ghislaine had her pilot's license, her helicopter
23	pilot's license --
24	A. Yes.
25	-- she flew Epstein's helicopter; is that right? Q.

	278
	- cross LBUVMAX4
	A. Yes, she did fly the helicopter.
	You accompanied her on those flights as the more Q.
	experienced pilot?
4	Yeah, I was going to go in that direction, but yes, I A.
5	accompanied her as a safety pilot. We flew together.
6	Q. And to your knowledge, that was Epstein's helicopter, not
7	Ghislaine's helicopter, right?
8	A. That's correct.
9	So Ghislaine couldn't call you up and say, I want to fly Q.
10	the helicopter. Have it ready for me. Right?
11	A. She might have; but, no, that wasn't the normal situation.
12	We always had a mission to go on, and it was probably
13	But to my knowledge, it was Mr. Epstein's Mr. Epstein driven.
14	helicopter, yes.
15	To your knowledge, it was Mr. Epstein who controlled Q.
16	whether or not the helicopter was flown or not?
17	A. Correct. Yes.
18	Now, you said that when Ghislaine did fly the Q. Okay.
19	helicopter, you would fly with her as the more experienced
20	pilot?
21	A. Yes.
22	And you got to know her a little bit from that too, from Q.
23	your shared enjoyment of piloting helicopters, right?
24	Yes, we talked a lot about aviation. A.
25	And you remember her as a nice person, right? Q.

	279
	- cross LBUVMAX4
	A. Yes.
	Q. And you felt comfortable around her?
	A. Yes, I did.
4	You never saw Ghislaine do anything or say anything that Q.
5	would lead you to believe she was helping Epstein or anyone
6	else sexually abuse underage girls?
7	A. No, not at all.
8	, you testified before that you have two Now, Mr. Q.
9	girls of your own.
10	A. That is correct.
11	When you started working for Epstein in 1991, how old were Q.
12	your daughters?
13	When I started working, well, one was one year old and one A.
14	was not born yet.
15	Q. And in the mid 1990s, how old would they have been then?
16	So if you're going to use 1995, so one would be A. Mid 1990s.
17	five years old and one would be one year old.
18	Q. Okay. And by the time you get to the mid 2000s, let's call
19	it 2004, just to pick a date, how old would they have been
20	then?
21	A. Okay. It's a math quiz. Let's see.
22	Sorry. Q.
23	A. We're '94. So we're talking 14 11 and 14.
24	So I said 2004; is that right? Q.
25	2004; correct. So one would be 14. One was born in '90, A.

	280
	- cross LBUVMAX4
	So, yeah, 14 and 11-ish. and the other, '94.
	So one was a teenager and one was a preteen? Q.
	A. That's correct.
4	Now, your daughters occasionally spent time with Ghislaine Q.
5	on the ranch in New Mexico, especially after you built your
6	house there; isn't that right?
7	A. Yes.
8	Q. They loved the animals, I believe, right?
9	A. Yes.
10	Q. Especially the horses?
11	A. Yeah, they are horse lovers.
12	Q. And sometimes Ghislaine would take them riding on the
13	horses at the ranch; isn't that right?
14	Yes, my daughters did ride at the ranch on the horses, yes. A.
15	Q. They did that a fair amount?
16	A. Yes.
17	And you trusted Ghislaine enough that you felt comfortable Q.
18	letting your two young daughters spent time with her; isn't
19	that right?
20	A. That is correct.
21	If you had any inkling whatsoever that Ghislaine was Q.
22	involved in helping Epstein sexually abuse young girls, you
23	wouldn't have let that happen, would you?
24	A. Absolutely not.
25	Q. And if you had any inkling whatsoever that Ghislaine or

	- redirect LBUVMAX4	281

	Epstein were involved in inappropriate sexual activity with
	underage girls, what would you have done?
	A. They would have never seen my daughters.
4	Q. And you would have quit your job?
5	A. Reported it, yes.
6	Q. And you would have quit your job?
7	I would have quit my job, that's correct. A.
8	But you didn't do that, did you? Q.
9	A. No, I didn't.
10	Because nothing you saw or heard in the roughly 30 years Q.
11	you worked for Epstein ever gave you even the slightest hint
12	that anything like that was going on?
13	This is absolutely correct. A.
14	MR. EVERDELL: One moment, your Honor.
15	THE COURT: Okay.
16	(Counsel conferred)
17	MR. EVERDELL: Nothing further, your Honor.
18	THE COURT: All right. Thank you.
19	Ms. Comey.
20	MS. COMEY: Thank you, your Honor.
21	THE COURT: You may redirect.
22	REDIRECT EXAMINATION
23	BY MS. COMEY:
24	Q. Good afternoon.
25	A. Good afternoon, Ms. Comey.

	- redirect LBUVMAX4
	Q. Do you recall being asked questions about your daughters on
	cross-examination, Mr.
	A. Yes, I do.
4	Q. When your daughters were 14 years old, did you let them
5	give Mr. Epstein a massage?
6	A. No, I didn't.
7	Do you recall being asked about Q. and another person who
8	has the same first name as
9	A. Yes.
10	or the person who is Q. Who did you meet first,
11	identified in Defense Exhibits LV3A and LV3B?
12	The only way to kind of refresh my memory, Ms. Comey, to A.
13	narrow down that, I could only -- like when I -- when I
14	explained that I first met it was in between the two
15	So I know that was one of Mr. Epstein's smaller pilot seats.
16	aircraft; it wasn't the Boeing.
17	So visually, I can picture the second You have
18	Not the one -- not the first to help me out which one it was.
19	, but the other I could visualize in the Boeing which
20	would have been sometime 2000 and later.
21	So to the best of your recollection, did you meet the Q.
22	person we're calling in the 1990s?
23	A. I would go with that one, yes, only because with that
24	document of the airplane with, you know, that time frame, I
25	remember the other was in the Boeing, the bigger plane.

	283
	- redirect LBUVMAX4
	I just want to make this clear because I know we're dealing Q.
	with some pseudonym issues, so just listen to the question
	please.
4	A. Okay.
5	The person we're calling Q.
6	A. Yes.
7	Q. -- did you meet her in the 1990s, to the best of your
8	recollection?
9	A. Yes.
10	And the person who is depicted in Defense Exhibits LV3A and Q.
11	LV3B, did you meet her in the 2000s, to the best of your
12	recollection?
13	A. Yes. To the best of my recollection, that's a perfect
14	example of how I could remember; so that is correct, yes,
15	Ms. Comey.
16	And do you have that memory because the person depicted in Q.
17	Defense Exhibits LV3A and 3B you remember on the Boeing?
18	A. That's correct. That was my synopsis.
19	THE COURT: Sorry. Just a moment.
20	MR. EVERDELL: Objection. Leading.
21	THE COURT: Overruled.
22	You may finish. You may finish your answer.
23	THE WITNESS: Oh, I'm sorry.
24	It was a way of correlating a A. That is correct, Ms. Comey.
25	name to a date or a person to a date.

	284 - redirect LBUVMAX4
	Do you remember being asked on cross-examination about how Q.
	old you thought may have been?
	I remember that question, yes. A.
4	Q. Did you ever meet at summer camp when she was a
5	camper?
6	A. I did not, no.
7	Q. Did you ever pick up at high school?
8	A. No, I did not, ma'am.
9	Did you ever talk with about camp? Q.
10	A. No, I did not.
11	Q. Did you ever talk with about high school?
12	A. No, ma'am.
13	Q. Did you ever meet mother?
14	A. No, I did not.
15	Q. Did you meet other family members?
16	A. I did not.
17	Q. And finally, Mr. do you recall being asked about a
18	Cobra vehicle?
19	A. Yes, ma'am.
20	Q. Do you remember exactly when Mr. Epstein gave you that
21	vehicle?
22	Also to clarify, it's a replica Cobra. Probably in the A.
23	2000s, 2000; it's been around 20 years since I've had it. I
24	would say 2000, give or take. I don't have an exact date.
25	As you sit here today, do you remember the exact date or is Q.
	SOUTHERN DISTRICT REPORTERS, P.C.

	285
	- redirect LBUVMAX4
	that an approximation?
	I do not know the exact date. A. It's just an approximation.
	MS. COMEY: May I have a moment, your Honor?
4	THE COURT: You may.
5	(Counsel conferred)
6	MS. COMEY: Nothing further.
7	THE COURT: Okay.
8	MR. EVERDELL: Nothing from the defense.
9	THE COURT: All right. Thank you, Mr.
10	You may step down. You are excused.
11	THE WITNESS: Thank you very much, your Honor.
12	THE COURT: Thank you.
13	(Witness excused)
14	THE COURT: Do you have a matter to take up?
15	MR. EVERDELL: Yes, your Honor. You may want to
16	collect the binders and folders before the next witness or at
17	least the defense folders.
18	THE COURT: Okay. Or we leave them there?
19	MR. EVERDELL: There may be another -- it's fine, your
20	Honor.
21	THE COURT: Okay. Jurors, you know this, but don't
22	look at anything unless I direct you to, please. And there may
23	be instances in which I direct you to, but wait for that
24	direction.
25	Ms. Comey, the government may call its next witness.

	286
	- direct LBUVMAX4
	MS. MOE: Thank you, your Honor.
	The government calls
	THE COURT: The witness testifying under the pseudonym
4	may come forward.
5
6	called as a witness by the Government,
7	having been duly sworn, testified as follows:
8	THE COURT: Please be seated.
9	This witness will be testifying under the pseudonym
10
11	Ms. Moe, you may proceed.
12	MS. MOE: Thank you, your Honor.
13	And with respect to the Court's order regarding sketch
14	artists, is that now in effect?
15	It is in effect. THE COURT: I've asked the sketch
16	artist not to sketch the exact likeness -- ordered the sketch
17	artist not to depict the exact likeness.
18	And I will ask the witness to please remove your mask.
19	You are in the Plexiglas box with the HEPA filter. Thank you.
20	MS. MOE: Thank you, your Honor.
21	DIRECT EXAMINATION
22	BY MS. MOE:
23	Good afternoon. Q.
24	A. Good afternoon.
25	Just to be clear, are you testifying under the name Q.
	SOUTHERN DISTRICT REPORTERS, P.C.

	287 - direct LBUVMAX4
	today?
	A. Yes.
	Q. Leading up to this trial, did you ask to testify under a
4	pseudonym to protect your privacy?
5	A. Yes.
6	I'd ask you to please take a look in the binder in front of Q.
7	you on the witness stand. If you could please turn to what's
8	marked for identification as Government Exhibit 12. Just let
9	me know when you are there please.
10	A. Here.
11	Do you recognize that? Q.
12	A. Yes, I do.
13	I just want to make sure that defense has THE COURT:
14	what they need.
15	MS. MENNINGER: I do. Thank you.
16	THE COURT: Okay. Thank you. Go ahead.
17	What is Government Exhibit 12? Q.
18	My birth certificate. A.
19	MS. MOE: At this time, your Honor, Government Exhibit
20	12 is in evidence under seal. I'd ask the jurors be permitted
21	to remove their juror binders and turn to Tab 12.
22	THE COURT: Without objection, Ms. Menninger?
23	MS. MENNINGER: No objection.
24	Okay. Jurors, you may open the binder and THE COURT:
25	look at what's been admitted as GX-12, please.

	- direct LBUVMAX4	288

	MS. MOE: Thank you, your Honor.
	BY MS. MOE:
	Directing your attention to the top left corner of Q.
4	Government Exhibit 12, where it says "child's name." Do you
5	see that?
6	A. Yes.
7	Without saying that out loud, is that your true name? Q.
8	A. Yes.
9	Q. Is that your date of birth?
10	Yes, it is. A.
11	Q. Thank you. You can close the binder.
12	Now, I want to ask you, did there come a time in
13	your life when you met someone named Jeffrey Epstein?
14	A. Yes.
15	Q. What year was that?
16	A. 1994.
17	Q. Did there come a time in your life when you had sexual
18	contact with Jeffrey Epstein?
19	A. Yes.
20	Q. How old were you when that first happened?
21	A. Fourteen years old.
22	Q. Did that happen once or more than once when you were 14
23	years old?
24	A. More than once.
25	Was there ever anyone else in the room with you when you Q.
	SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

	- direct LBUVMAX4
	had sexual contact with Jeffrey Epstein when you were 14 years
	old?
	A. Yes.
4	Q. Who was most frequently in the room when you had sexual
5	contact with Jeffrey Epstein when you were 14 years old?
6	A. Ghislaine Maxwell.
7	I'd like to ask you to take a moment to look around the Q.
8	courtroom, and you can stand up if you need to if you can't
9	Do you see Ghislaine Maxwell in the courtroom today? see.
10	A. Yes.
11	Q. Can you please point to where she's sitting and indicate an
12	article of clothing that she's wearing.
13	sort of a beige Right there in the corner wearing a A.
14	turtleneck.
15	Your Honor, may the record reflect that the MS. MOE:
16	witness has identified the defendant?
17	THE COURT: It may so reflect.
18	Now, I want to ask you more about that in a few moments, Q.
19	but first I want to take a step back.
20	Directing your attention to 1993, where were you
21	living that year?
22	A. Palm Beach, Florida.
23	How old were you in 1993? Q.
24	A. Twelve, going on 13.
25	I'd ask you to take a look at the binder in front of you. Q.

	290 - direct LBUVMAX4

	If you could please turn to what's been marked for
	identification only as Government Exhibit 106.
	Do you recognize that?
4	A. Yes.
5	What is Government Exhibit 106? Q.
6	A. That is a picture of myself.
7	Q. Approximately how old were you when that photograph was
8	taken?
9	A. Thirteen years old.
10	Your Honor, the government offers Government MS. MOE:
11	Exhibit 106 under seal.
12	MS. MENNINGER: No objection.
13	THE COURT: Government Exhibit 106 is admitted under
14	seal, consistent with my ruling, to protect the anonymity of
15	this testifying witness.
16	(Government's Exhibit 106 received in evidence)
17	MS. MOE: Thank you, your Honor.
18	May the jurors turn to Government Exhibit 106, please.
19	THE COURT: Jurors, you may pick up the binder and
20	please turn to GX-106.
21	BY MS. MOE:
22	Who was living with you in your household in 1993 when you Q.
23	were approximately 13 years old?
24	My mother and two of my brothers. A.
25	What type of work did your father do? Q.
	SOUTHERN DISTRICT REPORTERS, P.C.

	291
	- direct LBUVMAX4
	A. He was a conductor and composer.
	Directing your attention to the fall of 1993, what happened Q.
	in your family at that time?
4	A. My father died of leukemia.
5	Q. What was your home life like after your father passed away?
6	A. It was not great. My father's employer had canceled his
7	health insurance without him knowing, and ended up in the
8	And basically, my family went hospital and died very suddenly.
9	into complete bankruptcy and lost everything, and we had to
10	move out of our home.
11	Q. You testified that before he passed away, your father was a
12	composer. Were you involved in the arts growing up?
13	A. Yes.
14	Q. Were your brothers involved in the arts?
15	A. Yes.
16	Q. Did you continue being involved in the arts after your
17	father passed away?
18	A. Yes.
19	Directing your attention to the summer of 1994, what did Q.
20	you do that summer?
21	Me and my two brothers, we went to camp for the first time, A.
22	Interlochen Arts Camp.
23	What is Interlochen Arts Camp? Q.
24	It's a camp for children with all kinds of artistic A.
25	abilities: Music, musical theater, theater, orchestra.

	292
	- direct LBUVMAX4
	Basically, what we used to joke about being band camp.
	Q. And where is that located?
	A. In Interlochen, Michigan, which is northern Michigan.
4	Q. Did anyone else go to camp with you that summer?
5	My two brothers. A.
6	Given your family's financial circumstances at the time, Q.
7	how were you and your brothers able to attend summer camp?
8	A. That first summer, my oldest sister and her husband and her
9	husband's family all pitched in to send us to camp.
10	Q. What grade in school had you just finished when you started
11	at summer camp that year?
12	A. Seventh grade.
13	Q. And when you arrived at camp that summer, how long had it
14	been since your father passed away?
15	So the end of October '93, so what is that, nine months? A.
16	Q. Did there come a time that summer at Interlochen Arts Camp
17	when you met a man and a woman?
18	A. Yes.
19	Q. Where were you when that happened?
20	A. I was in the main campus area where all the students hung
21	out during a break and where all the little cafes were and sort
22	of the gift shop. And I was on a park bench or a picnic bench
23	with my friends from camp. And we were eating ice cream.
24	What do you remember happening next? Q.
25	A. Well, we were sitting around and socializing. And we see

	- direct LBUVMAX4
	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.
4	Q. What happened then?
5	We started chitchatting, petted the dog. And the rest of A.
6	my classmates had to go to class. And probably about a minute
7	later, another man came and joined her.
8	Q. Once the man joined her, what happened next?
9	A. We continued chitchat, sort of talked to us. And the rest
10	of my friends, my classmates, left, and I was there by myself.
11	And I sat on the bench still eating my ice cream, and the man
12	sat across from me.
13	Q. Did you have a conversation with that man and that woman?
14	He seemed very interested to know what I A. Yes, I did.
15	thought about the camp, what my favorite classes were, what my
16	least favorite classes, teachers, whatnot, what the experience
17	was like. And proceeded to say that they were big benefactors
18	of this camp; and that they went there every summer; and that
19	they gave different kids scholarships. And so they wanted to
20	really know what a student attending the camp, what their
21	perspective was on it.
22	What, if anything, else did you discuss with them? Q.
23	A. Well, they asked me where I was from. And I said I lived
24	in Palm Beach, Florida. And the man said, What a coincidence,
25	we live there too. What are your parents' names?

	- direct LBUVMAX4
	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
4	smaller town. We definitely know her.
5	And I said, You know, my parents were sort of out on
6	the scene, and my father was a musician, and so that would make
7	sense.
8	And he had a newspaper under his arm. And then he put
9	the newspaper on the picnic table and said, Well, what's your
10	mom's name?
11	Gave my mom's name.
12	And he said, Well, what's her phone number?
13	And I just kind of went, Okay. He's asking me for a
14	number, so I gave it to him. And so I gave my mom's, which,
15	you know, at the time was just a landline.
16	How did that conversation end? Q.
17	It just sort of ended like, It was, you know, so nice to A.
18	meet you and I'm going to call your mom. That was it.
19	Q. That man and that woman that you had this conversation
20	with, who were they?
21	Jeffrey Epstein and Ghislaine Maxwell. A.
22	What was your impression of them at that point? Q.
23	A. They seemed very friendly. I thought they were a married
24	And it made sense, I guess, couple. They seemed inquisitive.
25	if they spent time there, that they wanted to know what the

		295 - direct LBUVMAX4
		what the classes were like and what the campus was like.
	Q.	Did you return home to Palm Beach when summer camp was
	over?
4	A.	Yes.
5	Q.	Where were you living at that point?
6	A.	We were living in a pool house in one of my parents'
7		friend's backyards.
8	Q.	Why were you living in a pool house?
9		THE COURT: I'm sorry, Ms. Moe, can you come a little
10		closer to the mic?
11		MS. MOE: Thank you, your Honor.
12	Q.	Why were you living in a pool house at the time?
13	A.	Because we lost our house and we were homeless.
14	Q.	When you were staying there, did you have your own bedroom?
15	A.	No.
16	Q.	Where did you sleep?
17	A.	I slept in a bed with my mom.
18	Q.	After you returned home from summer camp in 1994, did you
19	ever hear from those two people that you met at camp?
20	A.	Yes.
21	Q.	When was the first time you heard from them?
22	A.	Well, it was a few days after I had started school again.
23	Q.	What grade were you in at that point?
24	A.	Eighth grade.
25	Q.	What school were you attending?

	- direct LBUVMAX4
	A.
	Is that a middle school or a high school? Q.
	A. Middle school.
4	So what happened when you heard from them? Q. What do you
5	remember about that?
6	A. I just remember coming home from school one day, and my mom
7	said, Someone you met at summer camp, someone from their office
8	called me.
9	And I said, Oh, well, I don't -- oh, that's right.
10	I -- I barely remember, because it seemed so long ago. It was
11	maybe four or five or six weeks, but, you know, being that
12	young, it seemed like an eternity. And I said, Yeah, I met
13	and they said that they know you.
14	And my mom said, Well, we've been invited to his house
15	for some tea some afternoon.
16	Q. Did you end up going to his house for tea?
17	A. Yes.
18	What do you recall about going over to the house for tea? Q.
19	He sent somebody to come pick us up, like a chauffeur. A. And
20	we were driven to his house.
21	What was your impression of the house when you first Q.
22	arrived?
23	A. Well, it was enormous. It was not a pool house in the back
24	It was this giant, like, beach-looking of someone's yard.
25	And these giant gates house with a big white fence around it.

	- direct LBUVMAX4
	And it was just this, you opened up, and the car pulled in.
	know, big beautiful house.
	Who, if anyone, went with you when you went over for this Q.
4	tea?
5	A. My mother.
6	Q. What happened after you and your mother arrived at the
7	house?
8	Well, somebody opened the door for us and let us in the A.
9	house and escorted us through the house and to Jeffrey's
10	office, which was sort of like an open space.
11	Q. And after you got to the office, what happened next?
12	He was on the phone. A. He got off the phone, stood up, and
13	introduced himself to me and my mother, and then sort of let us
14	outside to the back patio, which had this great big dining
15	table. And there was a big spread of, like, pastries and
16	sandwiches and tea.
17	Q. What happened during the tea with you and your mother and
18	Jeffrey Epstein?
19	A. Well, he was very inquisitive and asked me questions about
20	what I was doing in school, what my interests were, what I
21	wanted to do with my life, and was asking us about our family,
22	asking my mother. It didn't last very long, I would say maybe
23	30 minutes in total.
24	But he proceeded to say, Well, I like to mentor young
25	And I love music, and I love dance, students who are artists.

	298
	- direct LBUVMAX4
	and I gave all kinds of scholarships.
	Q. How did that tea end?
	It ended with him saying, Well, I am I'm very impressed A.
4	with your daughter and, you know, would love to see her sing
5	next time.
6	Q. After the day that you had this tea, did you ever see
7	Jeffrey Epstein again?
8	A. Yes.
9	Q. In the months after that tea, how frequently did you begin
10	seeing Jeffrey Epstein?
11	A. On average, once or once every week or two.
12	We've been talking about a time period when you were 14 and Q.
13	living in Palm Beach. How old were you when you moved away
14	from Palm Beach?
15	A. When I moved away? 17.
16	I want to focus now first on the first few months that you Q.
17	spent time with Jeffrey Epstein when you were 14. During those
18	first few months, when you spent time with Jeffrey Epstein in
19	Palm Beach, who was typically there with you?
20	A. At Jeffrey's house?
21	Q. Yes.
22	I was there by myself. A.
23	And when you would spend time with Jeffrey Epstein at his Q.
24	house in those first few months, who, if anyone, was there?
25	A. Ghislaine Maxwell.

LBUVMAX4 - direct¶

	Q. What was your understanding at the time of what the
	relationship was between Ghislaine Maxwell and Jeffrey Epstein?
	I didn't really understand. A. They never really shared that
4	information. I just assumed that they were married. And then
5	at a certain point I thought maybe they're best friends. And
6	then I thought, Well, maybe she works for him because he would
7	ask her to do things, make phone calls and things for him. So
8	I guess I was just confused.
9	When you would see Epstein or Maxwell, how were those Q.
10	meetings typically arranged?
11	A. It would be Ghislaine calling the house or Jeffrey's office
12	calling the house, like an assistant or something.
13	Q. Now, you mentioned earlier that you would go to these
14	Just to be clear, did your mother go with you meetings alone.
15	for these meetings?
16	A. No.
17	Q. Why not?
18	A. She wasn't invited.
19	Q. How would you typically get over to the house?
20	A. Jeffrey would send his chauffeur for me.
21	Did you have your driver's license at the time? Q.
22	A. No.
23	Q. Do you recall the driver who would pick you up?
24	A. I don't remember his name, but he was a sweet Yes.
25	Latin-American man. And I know his wife worked at the house as

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300¶

	well.
	When you began spending time with Maxwell and Epstein, what Q.
	was your impression at the time of how old they were?
4	I thought approximately the same age as my parents, my mom. A.
5	And again, just to be very clear, how old were you when you Q.
6	first started spending time with Maxwell and Epstein?
7	14. A.
8	What kind of activities would you typically do when you Q.
9	spent time with Maxwell and Epstein during those first few
10	months?
11	We would spend time at the house and sort of chitchat A.
12	and -- or eat in the kitchen or hang out by the pool, sometimes
13	going to the movies. Casual stuff.
14	Q. What, if anything, do you remember about spending time at
15	the pool during those first few months?
16	A. Well, I remember maybe the first time I went to the
17	And there was at least four poolside. And I walked out there.
18	women and Ghislaine all topless, and some of them were naked.
19	Q. What was your reaction to that?
20	Well, I was just shocked because I hadn't seen that before. A.
21	In those first few months when you spent time at the house Q.
22	in Palm Beach, did you have conversations with Maxwell?
23	A. Yes.
24	Q. What kinds of things would she talk about with you?
25	A. Well, we would chitchat, talk about school. She would ask

	- direct LBUVMAX4
	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
4	her, how did Maxwell come across to you?
5	A. She seemed a little bit odd and quirky; but, you know, she
6	would kind of like tease me at times and -- but she was nice.
7	How would you describe your relationship with Maxwell those Q.
8	first few months when you started spending time with her?
9	A. In the first few months, I felt like I think she might have
10	said, I'm sort of like an older sister. Because I at least
11	thought that she was the same age difference maybe as my oldest
12	sister, but I wasn't sure.
13	And at that time, approximately how old was your oldest Q.
14	sister?
15	A. Twenty-seven. I'm not great at math. Sorry.
16	Q. Did there ever come a time when Epstein ever gave you any
17	gifts or money?
18	A. Yes.
19	Approximately when did that first happen? Q.
20	It happened probably a few visits in. A.
21	What do you remember about the first time that that Q.
22	happened?
23	A. I just remember that he said good-bye to me and was going
24	to lead me to the front door. And he put cash in my hand. And
25	I was a polite kid who didn't want to look. And I said, No,

	302 - direct LBUVMAX4

	it's okay.
	This is for your And he said, No, no, no. It's okay.
	I know she's having a hard time, so it's not a big mother.
4	deal.
5	Q. After that happened, did he ever give you any money again?
6	A. Yes.
7	Q. How often would that happen?
8	Almost every visit. A.
9	Did there come a point where he began paying for things for Q.
10	you?
11	A. Yes.
12	Q. What kinds of things did he help pay for?
13	A. He helped pay for some voice lessons, he bought me some
14	clothes, things for school.
15	In your conversations with Maxwell, in that first few Q.
16	months that you were spending time with her and with Epstein,
17	did you ever have any conversations with her about boyfriends?
18	A. Yes.
19	What do you remember her telling you? Q.
20	I just remember her telling me at one point when I said, A.
21	No, I don't have a boyfriend, she said, Well, remember when you
22	do, that once you fuck them, you can always fuck them again
23	because they're grandfathered in.
24	Q. What was your reaction to that when she told you that?
25	A. Well, I giggled because I didn't understand what

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	- direct LBUVMAX4
	"grandfathered" meant, first and foremost.
	Did there ever come a time when you went shopping with Q.
	Maxwell and Epstein?
4	A. Yes.
5	Q. Approximately when was that?
6	A. Sometime at the end of 1994 or
7	Q. Did they buy you anything?
8	A. Yes.
9	Q. What did they buy you?
10	They bought me some -- some pants and some shoes, like, A.
11	I remember some shirts, like, sort of a sort of loafers.
12	preppy button-up shirt, like a cashmere sweater.
13	During that trip, did you go shopping for anything else Q.
14	with them?
15	A. Yes, we went to a Victoria's Secret and bought some
16	underwear.
17	What kind of underwear did they buy you? Q.
18	It was sort of those, like, white cotton briefs; like, the A.
19	very sort of, I would say, basic-looking ones that you would,
20	sort of, wear when you're -- when you're younger.
21	Q. During this time in the first few months when you were
22	spending time with Maxwell and Epstein, did they ever tell you
23	anything about their social circle?
24	A. I mean, from the very beginning there was a lot of Yes.
25	bragging about how they were friends with essentially everyone,

	304
	- direct LBUVMAX4
	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
4	just, you know, say that they were very well-connected and
5	affluent.
6	Q. How did that make you feel at the time?
7	I mean, I guess it made me feel slightly intimidated, but A.
8	And also I just -- I didn't know how I it was overwhelming.
9	was supposed to feel about it.
10	What names do you recall them mentioning to you when they Q.
11	would tell you about their social circle?
12	A. Donald Trump, Bill Clinton, Mike Wallace, people at some
13	that I didn't know.
14	I want to ask you now about the house in Palm Beach where Q.
15	you were spending time with Maxwell and Epstein.
16	Could you please describe for the jury how that house
17	in Palm Beach was decorated.
18	It was -- I mean, it was a giant house, and so it had lots A.
19	of furniture, or at least in my opinion it was lots of
20	furniture, and lots of artwork and sculptures. And there was a
21	lot of, like, memorabilia and pictures, and pictures with
22	famous people and presidents and things like that.
23	What do you remember about the pictures and artwork inside Q.
24	the house in Palm Beach?
25	A. Well, not knowing much about art, I thought some of it was

	305 - direct LBUVMAX4
	You know, there were some paintings maybe a little bit odd.
	of, like, naked women or half-naked women and, like, lots of
	kind of -- or animals, like creepy looking animals.
4	Q. How did you feel when you were spending time inside that
5	house?
6	A. "Intimidated" I guess is the first word I think of.
7	You testified earlier that there came a time when you had Q.
8	sexual contact with Jeffrey Epstein. Again, approximately when
9	was that, the first time?
10	A. In 1994.
11	Q. And again, how old were you?
12	A. Fourteen.
13	Q. Where were you when that happened for the first time?
14	A. In Jeffrey's Palm Beach house.
15	Q. Can you describe for the jury what happened that day.
16	A. Well, Jeffrey was asking me, you know, You really need to
17	focus on what you want to do; you can't be broad. You know, do
18	you want to be an Do you want to do theater? Do
19	you want to be an actress or model?
20	We just sort of discussed that.
21	He said, Well, you know, I know everybody. I know all
22	I know all the photographers. I know, you know, the agents.
23	the owner of Victoria's Secret. So I can make things happen,
24	but you just have to be ready for it.
25	Q. After he said that, what's the next thing that happened?

The conversation just sort of ended abruptly. A. It was in

his office. And he just took my hand and he said, Follow me.
Q. Where did he take you?
He took me outside in the backyard past the pool to the A.
pool house.
Q. Could you please describe for the jury what happened when
he took you inside the pool house.
He took me in the pool house. And on the right-hand side A.
And he just proceeded to was this couch, futon-looking thing.
pull me over. And he sat in the corner and he didn't say a
And he just pulled his pants down. He was wearing word.
sweatpants. And he pulled me on top of himself and he
And then he just -- he got up proceeded to masturbate on me.
and he went into the bathroom and, like, cleaned himself up,
and then acted like nothing happened.
What was your reaction when he did that to you? Q.
A. Well, I was frozen in fear. I'd never seen a penis before,
let alone not seen anything like this.
Did you tell anyone that day about what happened to you? Q.
A. No.
Q. Why not?
A. Because I was terrified and felt gross and I felt ashamed.
Q. After the incident that you just described, did you
continue spending time with Maxwell and Epstein in Palm Beach?
A. Yes.

	- direct LBUVMAX4
	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.
4	Q. Approximately when was that?
5	A. Shortly after the first incident.
6	Q. Could you please describe for the jury what happened that
7	day.
8	The three of us were just spending time together hanging A.
9	out and talking. And then all of a sudden, in that same
10	manner, just abruptly said, you know, Follow me. And we went
11	I followed them up this -- felt like a winding upstairs.
12	staircase, up into Jeffrey's bedroom.
13	Q. Once you got to the bedroom with Epstein and Maxwell that
14	day, could you please describe for the jury what happened next.
15	They moved me over to the bed and took their clothes off A.
16	and started to like sort of, like, fondle each other and sort
17	of, like, kind of casually giggling about it. And I was just
18	standing there.
19	And he asked me to take my top off. And then, you
20	know, sort of just there were hands everywhere. And Jeffrey
21	And Ghislaine was like rubbing proceeded to masturbate again.
22	on him and kissing on him and, you know, fondling. And then
23	that was it.
24	Q. After the incident that you just described, did your visits
25	to Epstein's house in Palm Beach include sexual contact?

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 the first time? A. Fourteen. Q. After that day, did your visits to Epstein's house in Palm Beach include sexual contact? A. Yes. Q. I'll ask you now about what happened during those incidents. Were there times when you were alone with Epstein and Maxwell when you were 14? A. Yes. Q. What kinds of things would happen when you were alone with Epstein and Maxwell when you were 14? A. I'm sorry, in what context? Q. When you were 14 years old and there were times where you were alone with Maxwell and Epstein, what kinds of sexual contact would occur during those incidents? A. It would be them leading me to a massage table and showing me how Jeffrey likes to be massaged. Q. Who would tell you how Jeffrey likes to be massaged? A. Ghislaine and Jeffrey. Q. How did he like to be massaged? A. Like, he -- he liked -- like, very hard, like like,¶

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300¶

	309
	- direct LBUVMAX4
	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
4	happen?
5	In a massage room that was off, like, the master bedroom. A.
6	Q. Did anyone ever give you instructions during incidents like
7	this in the massage room?
8	A. Yes.
9	Q. Who would give you instructions?
10	A. Ghislaine and Jeffrey.
11	What kind of instructions would they give you? Q.
12	Just showing me, you know, what he likes, what -- you know, A.
13	what men like, what women like, you know, sort of touching on
14	breasts and touching his penis.
15	Q. What was Maxwell's demeanor like during these incidents?
16	I would say that it seemed very casual, like it was -- like A.
17	it was very normal, like it was not a big deal.
18	Q. And when she behaved like that, how did that make you feel?
19	A. Well, it made me feel confused because that did not feel
20	normal to me; I'd never seen anything like this or felt any of
21	this, and it was very embarrassing. You know, it's all these
22	mixed emotions. When you're 14, you have no idea what's going
23	on.
24	Q. During these incidents that we've been discussing, did
25	Epstein touch your body?

	310 - direct LBUVMAX4
	A. Yes.
	Q. Where did Epstein touch your body?
	A. He would touch he would touch
4	Q. During these incidents we've been discussing when you were
5	14, did you touch Epstein's body?
6	A. Yes.
7	Q. Where did you touch his body?
8	A. Everywhere.
9	Q. When you were alone with Maxwell and Epstein when you were
10	14, did anyone ever use a sex toy?
11	A. Yes.
12	I'm sorry to ask you this, but could you please describe Q.
13	for the jury what would happen during those incidents.
14	A. He liked to, like, use, like, vibrators that were different
15	sizes; and even, like, those -- like -- like the back massagers
16	that were, like, really, you know, painful.
17	Q. During those incidents, what did Epstein do with that back
18	massager?
19	He would -- he would put it ven if I said A.
20	that it hurt.
21	During these incidents, did Maxwell ever touch your body? Q.
22	A. Yes.
23	Q. Where would she touch you?
24	A. I would say mainly
25	Q. Earlier, I believe you said that during these incidents,

	311
	- direct LBUVMAX4
	Can you explain for the jury you touched Epstein everywhere.
	what you meant by that.
	I meant he -- he wanted to be massaged really from head to A.
4	toe. He liked his head rubbed, his shoulders, he liked his
5	nipples squeezed, his feet and his penis.
6	Approximately how often did incidents like this occur when Q.
7	you were 14 years old?
8	A. Approximately every visit to his house.
9	Were there ever sexual interactions with Maxwell and Q.
10	Epstein when other people were present as well?
11	A. Yes.
12	Q. Approximately how old were you when that happened for the
13	first time?
14	A. Fourteen or 15.
15	Q. Where would those incidents typically take place?
16	In one of Jeffrey's houses. A.
17	Q. Were there times where you traveled to other houses that
18	Epstein owned?
19	A. Yes.
20	I want to talk with you about that in a few minutes. The Q.
21	incidents you've been describing where other people were
22	present, how would they typically start?
23	I'm sorry, can you -- A.
24	Of course. Q.
25	When there were incidents between you and Maxwell when

	- direct LBUVMAX4
	other people were present, how did incidents like that
	typically start?
	A. It would be other people spending time at the house, sort
4	of hanging out, seemingly casually. And then it was, once
5	again, sort of, it seemed just abruptly everything would stop.
6	And someone, Ghislaine or Jeffrey, would sort of summon
7	everyone to, you know, follow to a room.
8	Q. Where would everyone go?
9	To either Jeffrey's bedroom or mainly the massage room. A.
10	During these incidents where other people were present, Q.
11	what would Maxwell typically do?
12	A. Well, she, along with others, would just start taking their
13	clothes off. And Jeffrey would get on the massage table, and
14	it would just, you know, sort of turn into this orgy.
15	Q. What, if anything -- what, if any, clothing did you wear
16	during these sessions?
17	My underwear. A.
18	Q. During incidents like this where other people were present,
19	what kinds of sex acts would occur?
20	A. Kissing, oral sex on each other, oral sex on Jeffrey,
21	full-on intercourse.
22	Q. How often was Maxwell present in the first year that that
23	happened to you?
24	A. I can't give an exact number.
25	Were there times where there were incidents like this where Q.
	SOUTHERN DISTRICT REPORTERS, P.C.

	313
	- direct LBUVMAX4
	she was not present?
	A. Yes.
	Approximately how often would she be present during these Q.
4	incidents?
5	A. I'm sorry, can you explain that?
6	Q. If there were times when she was present and times when she
7	wasn't present, approximately how often would she be present
8	for group sessions like this?
9	A. I don't know.
10	Q. During these incidents where other people were present,
11	were there ever sex toys that were used?
12	A. Yes.
13	What do you remember about that? Q.
14	I mean, it was pretty much the same thing: A. Using vibrators
15	on girls' vaginas.
16	Q. The other people who were in the room during incidents like
17	this, what was their gender?
18	A. Female.
19	Q. Approximately how old were they?
20	A. Older than myself, but I don't know.
21	Q. During these incidents when other people were present, were
22	there any -- were there any particular acts that Epstein
23	particularly liked or requested?
24	A. Sorry. When other people were present?
25	Q. Yes.

		314 - direct LBUVMAX4
	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
4		this typically happen?
5	A.	The massage room.
6	Q.	Could you please describe that room for the jury.
7	A.	In which house?
8	Q.	In the Palm Beach house.
	A.
9		Oh.
10	Q.	Sorry.
11	A.	It was -- it looked like maybe it was light, because it was
12		off the master bathroom, which was sort of -- it had like a
13		beachy feel.
14	Q.	What was in the room?
15	A.	I don't think I saw anything past the massage table.
16	Q.	Did anyone ever call the incidents that you've just
17		described a massage?
18	A.	Yes.
19	Q.	Who would call it that?
20	A.	Jeffrey.
21	Q.	Did incidents like this continue when you were 16?
22	A.	Yes.
23	Q.	How frequently did these incidents occur between when you
24		were 14 and when you were 16?
25	A.	The number or --
		SOUTHERN DISTRICT REPORTERS, P.C.

	315
	- direct LBUVMAX4
	Q. How often would it happen during those years?
	It would happen almost every visit with him, which would A.
	have been every two weeks.
4	MS. MOE: Your Honor, if I could just have one moment.
5	THE COURT: Yes.
6	(Counsel conferred)
7	MS. MOE: Thank you, your Honor.
8	BY MS. MOE:
9	Q. Earlier, you were describing an incident when Maxwell was
10	in the room when you were 14. Just to be clear, during the
11	incidents you've been describing to the jury when you were 14,
12	was Maxwell in the room?
13	A. Yes.
14	And when these incidents would occur when you were 14, was Q.
15	Maxwell in the room?
16	At times. A.
17	And when you were 16, were there times when Maxwell was in Q.
18	the room?
19	A. Yes.
20	Q. Did there ever come a time when you traveled with Jeffrey
21	Epstein or Ghislaine Maxwell?
22	A. Yes.
23	Q. Approximately when did you begin traveling with them?
24	A. At 14 years old.
25	About when did you last travel with them? Q.
	SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

	- direct LBUVMAX4
	A. In March of 2001.
	Q. I want to focus now on the years when you were 14, 15, and
	About how many times did you travel with them during those 16.
4	years?
5	A. Maybe ten times.
6	Where did you travel with them when you were 14, 15, and Q.
7	16?
8	From Palm Beach to New York City, and also Santa Fe, New A.
9	Mexico.
10	Q. When you traveled with them to those locations, how did you
11	get there?
12	A. Mainly on Jeffrey's private plane.
13	Q. Did you ever get there another way?
14	A. Yes.
15	Q. And how was that?
16	A. Commercial flights.
17	When you flew in the private jet, did Maxwell ever go with Q.
18	you?
19	A. Yes.
20	Q. How would these trips typically be arranged?
21	A. They would be arranged by Jeffrey's office.
22	Q. Where did you typically stay when you traveled with Maxwell
23	and Epstein?
24	A. At Epstein's house.
25	Q. Did Maxwell ever assist you in making travel arrangements?
	SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

	317 - direct LBUVMAX4
	A. Yes.
	I want to talk about some of the locations that you just Q.
	Did some of those trips include travel to New York? mentioned.
4	A. Yes.
5	Where did you stay when you traveled with Maxwell and Q.
6	Epstein to New York?
7	A. Epstein's house.
8	Q. Where was that house located?
9	A. New York City.
10	Q. In what borough?
11	A. Do you need the exact address?
12	No, it's okay. Q.
13	Approximately where was it within the city?
14	A. Upper East Side.
15	Q. Thank you.
16	Could you please describe for the jury what the house
17	on the Upper East Side looked like.
18	A. Well, it looked more like a building than a house. It was
19	eight stories, his massive eight-story house building where you
20	walk through these giant doors and then there was, like,
21	another security door to go in. And it had an elevator and it
22	was eight stories.
23	How was the house decorated on the inside? Q.
24	It was -- it was very dark, I felt. A. You know, very,
25	very -- like an old building. Lots of stone, you know, old
	SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

	318
	- direct LBUVMAX4
	wood, and lots of, like, fabric wallpaper, like red curtains,
	lots of artwork, statues, paintings.
	When you spent time in the house, what, if anything, did Q.
4	you notice about the artwork, the statues, and the paintings?
5	I thought some of it was a little creepy personally. There A.
6	was, you know, like, animals and giant, like, paintings that
7	looked kind of -- I don't know how you would -- how I would
8	describe it, but just felt uncomfortable.
9	Q. What made you feel uncomfortable about the paintings and
10	the artwork in the house?
11	It all sort of seemed like to have a dark theme, like it A.
12	was kind of, you know, intimidating and dark and, like, animal
13	heads and strange things.
14	Q. Did any of the artwork inside the house in New York contain
15	nudity?
16	A. Yeah.
17	Q. What did you notice about that?
18	Paintings of naked women and orgies and things like that. A.
19	It didn't seem very unusual at this point.
20	Q. When you would spend time inside that house in New York,
21	how did you feel when you were inside the house?
22	A. Intimidated. It wasn't a very warm place; you didn't feel
23	I kind of felt like -- you always kind of very, maybe, safe.
24	felt like someone is watching you. You didn't feel free to
25	roam around exactly.

	- direct LBUVMAX4
	What rooms in the house did you spend time in when you Q.
	would stay in the house in New York?
	A. What rooms would I spend time in? The room that I was
4	given, which was the guest room on the eighth floor, or
5	Jeffrey's bedroom, his bathroom, the massage room, or his
6	office or the kitchen.
7	Earlier, you described having sexual contact with Epstein Q.
8	and Maxwell in Palm Beach. Did that ever happen when you
9	traveled with them?
10	A. Yes.
11	Q. Can you describe for the jury what kinds of sexual acts
12	would happen when you traveled to New York when you were 14,
13	15, and 16?
14	It was a lot of the same. If it wasn't an orgy in the A.
15	massage room, it was in Jeffrey's bedroom, and that would be
16	mostly me alone with him.
17	What would happen when you were alone with him in the New Q.
18	York house when you were 14, 15, and 16?
19	A. Well, he would get naked and get on his bed. And he would
20	pull me on top of him and ask me to take my clothes off.
21	Do you want me to describe in detail?
22	I'm sorry to ask, but if you could explain for the jury Q.
23	what would happen during these incidents.
24	So he would show me what he likes. A. And basically, he
25	would -- he would use vibrators on me, he would put his fingers

LBUVMAX4		- direct
----------	--	----------

	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.
4	Q. Did all of the things that you just described happen on
5	trips to New York when you were 14, 15, and 16?
6	A. Yes.
7	Q. You testified that you were mostly alone with him when
8	these incidents occurred in the New York house when you were
9	Just to be clear, were there times when 14, 15, and 16.
10	Maxwell was present during those years?
11	A. Yes.
12	Where would these incidents in New York typically happen Q.
13	within the house?
14	In the massage room. A.
15	Can you please describe for the jury what the massage room Q.
16	in the New York house looked like.
17	A. Well, it was off the master bathroom, and it looked like it
18	was maybe supposed to be a giant walk-in closet. And it was
19	very dark. There was a built-in bookcase on the right-hand
20	side, and there was a stereo system. And there was, like,
21	And I don't know if it was painted dark, but music playing.
22	or maybe that was the lighting, but it sort of had this, like,
23	red mood. And then there was just a giant black massage table
24	in the middle of it.
25	Q. Was there anything along the walls in the massage room?

	321
	- direct LBUVMAX4
	My eyes didn't even look at the walls, mostly the floor, if A.
	not what was going on.
	Q. Was there any other furniture inside the massage room aside
4	from the massage table?
5	I don't know. A.
6	Q. Earlier you testified that you recall traveling to New
7	Mexico; is that correct?
8	A. Yes.
9	Q. Approximately when did you travel to New Mexico?
10	A. The year?
11	Approximately how old were you when you traveled to New Q.
12	Mexico?
13	Oh, 15 or 16. A.
14	Q. Who went with you on that trip?
15	A. Jeffrey and Ghislaine.
16	Q. Where did you spend most of your time on the trip to New
17	Mexico with Maxwell and Epstein?
18	At Epstein's house, which was a ranch. A.
19	What do you remember about the ranch that you visited on Q.
20	that trip?
21	I just remember that it was this giant ranch sort of in the A.
22	And it seemed very empty on the interior, middle of nowhere.
23	meaning there wasn't really any other people around.
24	Q. When you were at the ranch in New Mexico, where did you
25	spend most of your time?

		- direct LBUVMAX4

	A.	In the guest bedroom that was assigned to me.
	Q.	Were you by yourself in the bedroom?
	A.	Yes.
4	Q.	And did you spend most of your time alone in that bedroom
5		when you were in New Mexico?
6	A.	Yes.
7		(Continued on next page)
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	323
	- direct LBUCmax5
	On that trip in New Mexico, was there ever a time when Q.
	someone came into your room?
	A. Yes.
4	Can you describe to the jury what you remember about that? Q.
5	I just remember someone, at one point, just came into the A.
6	room and said Jeffrey wants to see you and then escorted me to
7	see him.
8	When that person came into your room and told you that he Q.
9	wanted to see you, how did you feel?
10	I just, as usual, felt, like, my heart sink into my A.
11	stomach, you know.
12	Q. And why was your heart sinking into your stomach?
13	A. Because I did not want to go see him.
14	Q. What's the next thing you remember about that?
15	I just remember being led to his bedroom and, you know, the A.
16	same thing would happen.
17	Q. Who was the person who came into your room to tell you that
18	Epstein wanted to see you?
19	I don't know. A.
20	During that trip to New Mexico, was your bedroom in the Q.
21	same building as Epstein and Maxwell's bedrooms?
22	A. Yes.
23	When you traveled with Epstein and Maxwell, was there ever Q.
24	a time when you had trouble getting on a flight?
25	A. Yes.
	SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

LBUCmax5 - direct¶

	Can you describe to the jury what happened. Q.
	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
4	them on a private jet. Then, to get back, I was taking a
5	commercial flight, but I was only 15, so I didn't have a
6	driver's license or any ID, I didn't have a learner's permit
7	So I had no ID to get on the airplane. yet.
8	What happened next after you couldn't get on the airplane? Q.
9	A. I remember calling and freaking out, saying how am I going
10	And Ghislaine made it happen for me. to get on this plane.
11	She sort of called somebody and helped me get on that flight.
12	Q. Approximately how old were you when that happened?
13	I was 15. A.
14	Q. Earlier, you testified that Maxwell assisted with your
15	travel arrangements on these trips when you were 14, 15, and
16	Could you explain to the jury how Maxwell assisted with 16.
17	your travel during these trips?
18	Well, sometimes it would be -- Jeffrey would ask her, hey, A.
19	can you get -- not you know, tickets and the times and
20	whatnot and make the arrangements to be picked up.
21	Q. You testified that this began when you were 14. Can you
22	explain to the jury how old you were when you moved away from
23	Palm Beach?
24	17. A.
25	Q. Can you describe for the jury what you looked like when you

	325
	- direct LBUCmax5
	were ages 14, 15, 16, and 17.
	A. What I looked like?
	Can you describe what your physical appearance was like. Q.
4	Oh, I was -- I was kind of short. I was very thin. A. I was
5	flat-chested until I was almost 16.
6	If you could please take a look at the binder in front of Q.
7	I'd ask you to just turn to what's you on the witness stand.
8	been marked for identification as Government Exhibit 107.
9	Do you recognize that?
10	A. Yes.
11	Q. What is Government Exhibit 107?
12	That is a picture of myself at 15 years old when I thought A.
13	it was a really good idea to bleach my own hair at home, which
14	was not a good idea.
15	Your Honor, the government offers Government MS. MOE:
16	Exhibit 107 under seal.
17	THE COURT: Government Exhibit 107 is admitted under
18	seal consistent with my ruling allowing this witness to testify
19	under a pseudonym to protect her privacy.
20	(Government's Exhibit 107 received in evidence)
21	MS. MOE: Thank you, your Honor.
22	Q. if you could please take a look at the binder in
23	front of you and turn to what's been marked for identification
24	as Government Exhibit 108.
25	Do you recognize that?
	SOUTHERN DISTRICT REPORTERS, P.C.

	326
	- direct LBUCmax5
	A. Yes.
	What is Government Exhibit 108? Q.
	A. That's a picture of me.
4	Q. Approximately, how old were you when that picture was
5	taken?
6	17. A.
7	Your Honor, the government offers Government MS. MOE:
8	Exhibit 108 under seal.
9	MS. MENNINGER: No objection.
10	THE COURT: Thank you. Government Exhibit 108 is
11	admitted under seal consistent with my ruling, allowing this
12	witness to testify using a pseudonym.
13	(Government's Exhibit 108 received in evidence)
14	MS. MOE: Thank you, your Honor. May the jurors turn
15	to Government Exhibits 107 and 108 in their binders.
16	THE COURT: Pick up your binders and Yes, please.
17	look at GX107 and GX108.
18	MS. MOE: Just give the jurors a moment to Thank you.
19	turn to that.
20	BY MS. MOE:
21	So again, just to be clear, now that we're all looking at Q.
22	Government Exhibit 107, approximately how old were you when
23	that photograph was taken?
24	A. 15.
25	Turning to Government Exhibit 108, approximately how old Q.
	SOUTHERN DISTRICT REPORTERS, P.C.

LBUCmax5 - direct¶

327¶

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 in Florida, can you describe for the jury what your home life was like during those years? A. Well, it was it was not great. My father had just passed away, sort of suddenly, and we found ourselves losing our home and moving into a pool house and not being allowed to grieve the loss of my father and having a very depressed mom at home. Q. I think you mentioned that you felt like you weren't allowed to grieve your father. Can you explain to the jury what you meant by that? MS. MENNINGER: Objection, your Honor. Relevance. THE COURT: Overruled. You may answer. A. Well, I grew up with a mother who didn't allow us to talk about our feelings because that was a sign of weakness. So grieving would be a part of that because she was very concerned about appearance and what we would look like and that you always sort of put a pretty face on. So we really didn't discuss those kinds of things at home and weren't allowed to discuss it with anyone else. So, being a kid and losing your dad and not being allowed to talk about it, not having anyone to talk to about it, it was really difficult.¶

	328
	- direct LBUCmax5
	Q. During the years that we've been talking about, did your
	mother know that you were spending time with Epstein and
	Maxwell?
4	A. Yes.
5	Q. Would you ever talk with her about that?
6	Not in detail, but, you know, my mom was so enamored with A.
7	the idea that these wealthy affluent people took an interest in
8	me.
9	MS. MENNINGER: Objection. Hearsay, your Honor.
10	We've strayed into hearsay.
11	THE COURT: Just one moment, please. Overruled with
12	respect to the answer that's been given, but is that the end of
13	the question line, Ms. Moe?
14	MS. MOE: Your Honor, this testimony is offered for
15	the effect on the listener. We ask that the witness be able to
16	explain what is going on during this time period and how that
17	affected her.
18	THE COURT: You may ask that question.
19	MS. MOE: Thank you, your Honor.
20	BY MS. MOE:
21	During the time period that we've been talking about when Q.
22	you were 14, 15, and 16, did your mother ever talk to you about
23	Jeffrey Epstein and Ghislaine Maxwell?
24	The most that she would talk to me about was saying that _ A.
25	need to be --

	329
	- direct LBUCmax5
	MS. MENNINGER: Objection. Hearsay, your Honor. ThRt
	was a different question.
	THE COURT: I'll sustain. If you reframe the question
4	to elicit the information you indicated as opposed to asking
5	what her mother said, you may proceed.
6	MS. MOE: Your Honor, if I could just have one moment?
7	THE COURT: You may.
8	MS. MOE: Your Honor, could we briefly approach?
9	THE COURT: Why don't we take our midafternoon break,
10	because the jurors' snacks are here and it's time for that. So
11	we'll take an approximately 10-minute break, members of the
12	Thank you. See you in about 10 minutes. jury.
13	(Continued on next page)
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(Jury not present)¶

(Witness excused)¶

THE COURT: Everyone may be seated. Go ahead, Ms. Moe.¶

MS. MOE: Thank you, your Honor, I'd like to ask the witness about her conversations with her mother during this time period about Epstein and Maxwell. As I think the witness began explaining during this time period, her mother would tell her about how great they were, how enamored she was with them, and that I expect she would say that that had an effect on her. None of that is offered for the truth, but for the effect on the listener.¶

I think the defense has put at issue in this case why the victims continued seeing the defendant and Epstein and why they didn't tell about what happened to them later, and the circumstances under which all of this was happening, including her home life, the effect of her own mother and how her mother would talk about Maxwell and Epstein are all part of that and it's directly responsive to that issue.¶

THE COURT: The initial questions that you're asking, you expect the witness to say what exactly was communicated to the witness by her mother?¶

MS. MOE: Yes, your Honor. I expect the witness to testify that her mother encouraged the relationship and would often talk about them favorably and tell them she should be¶

	331 - direct LBUCmax5

	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
4	the witness?
5	MS. MOE: Yes, your Honor.
6	So you'll accept a limiting instruction? THE COURT:
7	MS. MOE: Of course, your Honor.
8	THE COURT: Ms. Menninger.
9	MS. MENNINGER: Your Honor, I think the simple way to
10	ask the question is, how did you feel, and if it was based on
11	something your mother said to you, without getting into the
12	content of what the mother had communicated to her. I think
13	it's a real issue that may come up later with things that the
14	mother has said to any number of people, and I feel like this
15	opens the door to many other conversations that relate to the
16	mother.
17	So I'm not sure that just asking -- giving a bunch of
18	hearsay from the mom, saying we're asking it for the effect on
19	the listener and precluding cross examination about other
20	conversations with the mom would be appropriate.
21	So I don't know what you have in mind THE COURT:
22	coming down the road. I think it's proffered by the government
23	I think there might be a way to at this point anyway.
24	streamline it. Ms. Moe, maybe you could think about that.
25	But as proffered by the government, it's not being

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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 the witness's testimony regarding what her mother said is not being offered for the truth of those statements, but for the impact or effect that it had on the witness. We'll keep it limited, Ms. Moe, as to eliciting statements for an out-of-court witness, but with that caveat.¶

And then tell me, Ms. Menninger, what your concern down the road was so I have it in my head.¶

MS. MENNINGER: Your Honor, if you're admitting it with that limiting instruction, I think we'll take up the issues with other statements by the mom when they come up.¶

THE COURT: Okay.¶

17 19 20 22 23 MS. MOE: Thank you, your Honor. Just to preview in order to streamline things because we're on the subject, I expect the next few questions to be about the issue of disclosure. In particular, I expect to ask the witness whether there was ever a time when she talked to a guidance counselor when she was a kid and whether she came to learn that her mother had found out that she talked to the guidance counselor, and I want to talk to her about how her mother reacted to that and told her that she should never talk about what goes on in their house.¶

24 25 We're offering that, again, not for the truth of anything, it's certainly not our position that she shouldn't¶

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LBUCmax5 - direct¶

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 going on with her.¶

THE COURT: But in particular, you want the witness to testify that her mother told her not to report what happened, not to tell anyone what happened. Did I get that right?¶

8 9 10 11 12 13 14 MS. MOE: Yes, your Honor. I expect that she'll testify that she spoke with a guidance counselor after her father passed away, that her mother found out that she had spoken with a guidance counselor and had a very strong negative reaction to that, and told her that she shouldn't be talking about personal family matters and shouldn't be talking about what happens in their household.¶

THE COURT: Ms. Menninger.¶

MS. MENNINGER: I have no objection to that, your Honor.¶

18 19 20 21 22 23 24 25 MS. MOE: Thank you, your Honor. THE COURT: Thank you for previewing it. Anything else to take up? MS. MOE: Not from the government, your Honor. THE COURT: Ms. Menninger? MS. MENNINGER: No, your Honor. Not now. THE COURT: We'll take a short break. Thank you. (Recess)¶

	LBUCmax5	- direct	334
		Nothing to take up; correct? THE COURT:
		MS. MOE: Correct, your Honor.
		MS. MENNINGER: Correct, your Honor.
4		THE COURT: We'11 bring in the jury.
5		(Continued on next page)
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	- direct LBUCmax5
	(Jury present)
	THE COURT: Thank you, everyone. Ms. Moe, you may
	continue with your direct examination of the witness.
4	MS. MOE: Thank you, your Honor.
5	BY MS. MOE:
6	Q. Before the break, we were talking about your interactions
7	with you

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