EFTA00008631

Extracted Text #

2
3   UNITED STATES GRAND JURY
4   SOUTHERN DISTRICT OF NEW YORK
5x
UNITED STATES OF AMERICA           •
6
-V-                      : November 19, 2019 Additional
7
Ghislaine Maxwell
8    (2018R01618)
-x
9
10                                           United States Courthouse
300 Quaroppas Street
11                                           White Plains, New York
12                                           June 29, 2020
10:04 a.m.
13
14   APPEARANCE             S:
15
Assistant United States Attorney
16
17                                  Assistant United States Attorney
18
19
20
21
22
23
Acting Grand Jury Reporter
24
25
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000131
EFTA00008631
06/29/20
(Colloquy Precedes)
2             (Witness Enters Room)
3             (Time Noted:     10:16 a.m.)
4                called as a witness, having been duly sworn by
5             the Foreperson of the Grand Jury, was examined and
6              testified as follows:
7   BY MS.
8        Q.    Good morning.
9        A.    Morning.
10       Q.    Can you please state your full name for the
11   record?
12       A.
13       Q.    So I recognize that you are wearing a mask anc
14   behind Plexiglas.     There's a microphone in front of you, it
15   you could just make an effort to speak into the mic and keep
16   your voice up that would be great.
17        A.   No problem.
18       Q.    Where do you currently work?
19        A.   The Federal Bureau of Investigation.
20       Q.    What is your title?
21        A.   Special agent.
22       Q.    How long have you worked as a special agent?
23        A.   About three years, three years now.
24       Q.    Where are you currently assigned?
25        A.   I work for the -- on the Violent Crimes against
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_OOOOO132
EFTA00008632
06/29/20
1   Children squad.
2           Q.   What are your duties and responsibilities as a
3   special agent on that squad?
4          A.   We investigate crimes that have to do with child
5   sexual abuse material, sextortion, exploitation, and
6    enticement of minors, sex trafficking.
7               GRAND JUROR.    Maybe if she could take the mask
8    off.   I'm having -- is anybody having difficulty
9    understanding her?
10               MS.          Thanks for letting me know.       Would that
11   be okay with you if the witness took her mask off?
12               GRAND JUROR.      We're okay with the Plexiglas,
13   right?
14               GRAND JUROR.      Yeah.
15               MS.          Thanks very much.     Thank you.
16               BY MS.
17          Q.    All right.    So I'm just going to go back and ask
18   a few of those questions again just to make sure that
19   everyone can hear.      You testified earlier that you're a
20   special agent with the FBI.       Is that correct?
21          A.   Yes.
22          Q.   Where are you currently assigned?
23          A.   I work on the Violent Crimes against Children
24   squad.
25          Q.   And what are your duties and responsibilities as a
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000133
EFTA00008633
06/29/20
1   special agent on that squad?
2         A.   We investigate crimes that involve child sexual
3   abuse material, sextortion, enticement, and exploitation of
4   minors, sex trafficking, international parental kidnappings.
5             MS.           Let me just pause here.       Can everyone
6    hear the witness?
7             GRAND JUROR.       Yes.
8              MS.          Okay.   Thank you.    And Special Agent
9           if you could just try to keep your voice up, I really
10   appreciate it.   It's a little difficult under the
11   circumstances.
12             BY MS.
13        Q.   Have you participated in an investigation of
14   Ghislaine Maxwell?
15        A.   Yes, I have.
16        Q.   Have you spoken to other people, including other
17   law enforcement officers, about this investigation?
18        A.   Yes.
19       4•    Have you reviewed reports and documents prepared
20   by others regarding this case?
21        A.   Yes.
22        Q.   Is your testimony today based in part on those
23   conversations with other law enforcement officers and
24   documents that you have reviewed?
25        A.   Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000134
EFTA00008634
06/29/20
MS.          Ladies and gentlemen, let me just give
2    you a brief instruction.       Some of the testimony that you'll
3   hear today will include what's called hearsay.           As you know,
4   that means that the witness will not be testifying solely
5   from her own observations, but that she'll also be reporting
6    to you what others have told her and what she's read in
7   reports and documents prepared by other people.
8                Hearsay evidence is admissible in these grand jury
9    proceedings, and you're free to rely on it in determining
10   whether there's probable cause to indict the proposed
11   defendant.
12               If, however, you would like to hear the testimony
13   of any other witness, you have the right to request it and
14   we will make reasonable efforts to bring that witness before
15   you.
16               BY MS.
17          Q.   Special Agent            we placed on the desk in
18   front of you a PowerPoint that is Grand Jury Exhibit 2,
19   which we're entering into the record.         Do you recognize
20   this?
21          A.   Yes.
22          Q.   What is it?
23          A.   It's a PowerPoint presentation to assist in
24   testifying today.
25          Q.    Did you participate in preparing this exhibit in
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000135
EFTA00008635
06/29/20   6
connection with your testimony today?
2        A.   Yes, I did.
3        Q.   If you could please turn to the first slide.           Who
4   are the individuals depicted in these photographs?
5        A.   The picture on the left is Ghislaine Maxwell, and
6    the picture on the right is Jeffrey Epstein with
7   Ghislaine Maxwell.
8         Q.   Based on your participation in this investigation
9    and your review of public source materials, have Maxwell and
10   Epstein been photographed together many times over
11   years?
12        A.   Yes.
13        Q.   Based on your participation in this investigation
14   and your review of public materials, where is Maxwell from?
15        A.   Maxwell was born in France.      She grew up in the
16   United Kingdom, was educated in Oxford, and is from a
17   wealthy family.
18        Q.   Is she a citizen of France, the United Kingdom,
19   and the United States?
20        A.   Yes.
21        Q.   How old is she currently?
22        A.   58.
23        Q.   Has the FBI investigated Maxwell and Epstein's
24   conduct with minors during the 1990's?
25        A.   Yes
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000136
EFTA00008636
06/29/20
Q.      Generally speaking, what have you learned about
2   the relationship between Maxwell and Epstein during the
3   1990's?
4       A.     Epstein and Maxwell had a romantic relationship,
5   and she also worked for him; managing his homes, hiring and
6    firing individuals.
7       4•     During that time period, was she one of his
8    closest associates?
9         A.     Yes.
10       4.     During the course of this investigation, have you
11   learned where Epstein maintained properties in the 1990's?
12        A.     Yes.
13       Q.      Where did he maintain properties?
14       A.      New York, Palm Beach, and New Mexico.
15       Q.      Turning to the next slide, did he maintain an
16   address in Manhattan located at 9 East 71st Street?
17       A.      Yes.
18       Q.     Does this slide fairly and accurately depict the
19   residence?
20       A.      Yes.
21       Q.      Can you please describe that property for the
22   grand jury?
23       A.      It's a seven story home; it's located near Central
24   Park.    It's reportedly the largest residence in Manhattan.
25       Q.     Based on your participation in this investigation,
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000137
EFTA00008637
06/29/20   6
did that house include a room that was used a massage room?
2          A.   Yes, it did.
3          Q.   All right.   We'll talk more about that later, but
4   for now, moving on to the other properties.         Did he maintain
5   an address in Palm Beach, Florida, located at 358 El Brillo
6    Way?
7          A.   Yes.
8           Q.   Turning to the next slide.     Does this slide fairly
9    and accurately depict that residence?
10          A.   Yes, it does.
11          Q.   Could you please describe that property for the
12   grand jury?
13          A.   It's a waterfront estate.     It has an in ground
14   pool and a detached dwelling or pool house on the property
15   as well.
16          Q.   And from your participation in this investigation
17   and your review of other materials, did that house include a
18   room that was used as a massage room?
19          A.   Yes.
20          Q.   Turning to the next property.     Did Epstein also
21   own a ranch in New Mexico?
22          A.   Yes, he did.
23          Q.   And turning to the next slide.     Was that property
24   located at 49 Zorro Ranch Road in Stanley, New Mexico?
25          A.   Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000138
EFTA00008638
06/29/20   9
Q.    Looking at the photograph on this slide, does this
2   accurately depict that property?
3       A.    Yes, it does.
4       Q.   And we've been talking about the properties that
5   Epstein owned during this time period.       Did he also own a
6    private jet?
7       A.    Yes.
8        Q.    Is it fair to say that he was a multimillionaire
9    during this time period?
10       A.    Yes.
11       Q.    During the 1990's did Epstein have an employee
12               who ran his house in Palm Beach?
13       A.    Yes, he did.
14       Q.    What was his job?
15       A.    His job was making sure that everything in the
16   house ran smoothly.    He referred -- he described that
17   Epstein liked to have his house run live a five-star hotel;
18   that everything had to be in its proper place.         So he was
19   responsible for managing that.
20       Q.    Have you interviewed
21       A.    Yes.
22       Q.    How many times?
23       A.    Twice.
24       Q.   And is the information you're about to provide
25   based on your interviews with
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000139
EFTA00008639
06/29/20    1D
A.    Yes.
2   Q.   Did          begin working for Epstein in the early 3
1990's?
4        A.    Yes, he did.
5        Q.    And at the time           came to work for Epstein in
6    Palm Beach, was Epstein dating Ghislaine Maxwell at that
7   point?
8         A.    Not at that time.
9         4.    Was it a few years before Epstein began dating
10   Maxwell after          started working there?
11        A.    Yes.
12        Q.    From what                told you, how did
13   work change once Maxwell arrived on the scene?
14        A.            described Epstein as being more pleasant to
15   work with prior to Maxwell coming into the picture.           Once
16   she came into the picture, he said things became more
17   secretive.   He wasn't allowed to be in the room with guests,
18   wasn't allowed to talk with them, associate with them.              It
19   became a different environment.
20        Q.    You talked about some of the rules that were
21   placed changing.    Were there any rule changes about eye
22   contact once Maxwell began staying in the Palm Beach house.
23        A.    Yes.           wasn't allowed to make eye contact
24   with Epstein and others.
25        Q.    In general, how did he describe what it was like
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GUDNYJODOOPM
EFTA00008640
06/29/20    11
1   to work for Maxwell?
2         A.     He said she was very demanding; she was on top of
3   him all the time.      He described her as a "bitch."
4        Q.     Is that the word that he used?
5        A.     That is the word he used.
6         Q.    Shifting gears.      I want to talk to you about
7   someone else that you've interviewed during this
8    investigation.      During the course of this investigation,
9    have you participated in interviews with an individual named
10
11        A.     Yes.
12        Q.    So for these purposes I'm just going to refer to
13   her as             Is that okay?
14        A.     Yes.
15        Q.     How many times have you interviewed
16        A.     Approximately five times.
17        Q.     If you could please just page through the next two
18   slides in front of you.       Are these photographs of
19        A.     Yes.
20        Q.     Is it your understanding that these photographs
21   depict         from approximately ages 13 to approximately 17?
22        A.     Yes, it does.
23        Q.    Okay.     Let's take a look at some of those
24   photographs.    I'm going to publish the next slide.            Is
25             date of birth
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000141
EFTA00008641
06/29/20   12
A.   Yes.
2        Q.   And are these two photographs of
3        A.   Yes, they are.
4        Q.   If you could turn to the second slide of
5   photographs.    Are these also photographs of
6         A.   Yes.
7        Q.   Based on your participation in this investigation
8    and your interviews with            where was she living when
9    she was approximately 14?
10        A.   She was living in Palm Beach, Florida.
11        Q.   Who was she living with when she was 14?
12        A.   Her mother and her siblings.
13        Q.   What was her whole life like at that time?
14        A.   At that time, her father had passed away the year
15   prior, so the family was struggling financially and having
16   some difficulties.
17        Q.   What did            father do before he passed away?
18   What was his profession?
19        A.   He was involved in
21        Q.   Was         involved in
22        A.   Yes, she was.
23        Q.   Were her siblings?
24        A.   Yes.
25        Q.   What kinds of         were they involved in?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_OOOOO142
EFTA00008642
06/29/20
A.     Singing, she was a singer.
2        Q.     Like what kind of singer?
3        A.     Opera.
4        Q.     In the summer of 1994, how old was
5        A.     She was 13 going on 14.
6         Q.     You testified earlier that her birthday is in
7        , so did she turn 14 in                    of 1994?
8         A.     Yes.
9        Q.     What did she do that summer?
10        A.     She attended an arts camp at Interlochen Certer
11   for the Arts.
12        Q.     And is Interlochen Summer Arts Program located in.
13   Michigan?
14        A.     Yes.
15        Q.     Did         meet Jeffrey Epstein and
16   Ghislaine Maxwell that summer?
17        A.     Yes, she did.
18        Q.     Did she meet them at summer camp?
19        A.     Yes.
20        Q.     What did she tell you about that?
21        A.     She said that she was sitting at a picnic table
22   with friends when Epstein and Maxwell walked by.            They
23   stopped to talk to her, engaged her in conversation, asked
24   her if she liked her classes, her teachers.            During that
25   conversation, they found out that she was also from Palm
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_OOOOO143
EFTA00008643
06/29/20   14
Beach and that he said that he gives scholarships to
2   students.
3        Q.     How did they leave the conversation?          Was there
4   any contact information exchanged?
5        A.     They asked for             phone number.
6         Q.     As part of your investigation, have you attempted
7   to gather records to corroborate that                  Maxwell, and
8    Epstein were all at that summer camp that summer?
9         A.     Yes.
10        Q.     If you could turn to the next slide, please.             na
11   you obtained records from Interlochen for the summer of
12   1994?
13        A.     Yes.
14        Q.     And what are we looking at on this slide?
15        A.     This shows who -- some of the individuals that
16   were there -- were present for that camp in '94.           On here is
17                                           and
18        Q.     And have you investigated whether Maxwell and
19   Epstein were also at Interlochen that summer of 1994 as
20           described?
21        A.     Yes.
22        Q.     Based on your review of records from Interlochen,
23   what is your understanding of Epstein's relationship with
24   Interlochen?
25        A.     My understanding was that he was a donor to the
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000144
EFTA00008644
06/29/20
school.
2        Q.   Did he make any substantial donations?
3        A.   He did.
4   Q.   Did he donate a lodge to the camp in the summer of 5
1994?
6         A.   Yes, he did.
7        Q.   Did he have a long standing relationship as a
8    donor to Interlochen?
9         A.   Yes.
10        Q.   Turning to the next slide.        Is this an excerpt o:
11   a letter from Interlochen to Epstein?
12        A.   Yes, it is.
13        Q.   And does this letter thank Epstein for donating a
14   scholarship lodge?
15        A.   Yes.
16        Q.   Does it invite Epstein to visit in August of 1994?
17        A.   Yes.
18        Q.   In 1994, did Epstein have a private jet?
19        A.   Yes, he did.
20        Q.   Have you obtained the flight logs for that jet
21        A.   Yes.
22        Q.   Do those logs include passenger lists and the
23   airport code for the airports that the plane flew into and
24   out of?
25        A.   Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_OOOOO145
EFTA00008645
06/29/20   16
4.    Turning to the next slide.      Is this a page of the
2   flight logs that you've reviewed?
3          A.    Yes.
4          Q.    And on this excerpt of the flight logs where the
5   red arrow is, is that a log entry showing an August 18, 1994
6    flight to an airport with the airport code TVC?
7          A.    Yes.
8           Q.    Is TVC the airport code for Cherry Capital Airpor -
9    in Traverse City, Michigan?
10          A.    Yes, it is.
11          Q.    About how far is that airport from Interlochen by
12   car?
13          A.    It's about 25 minutes give or take.
14          Q.    And who were the listed passengers on this flight?
15          A.    Jeffrey Epstein,                   (ph.), and
(ph.).
17          Q.    Turning to the next slide.      Is this the same
18   excerpt but just with a different arrow?
19          A.    Yes.
20          Q.    Okay.   So a few lines down is there a flight out
21   of Traverse City just two days later on August 20th, 1994?
22          A.    Yes.
23          Q.    And do the passengers listed in the flight out of
24   Traverse City include the initials G.M.?
25          A.    Yes, they do.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000146
EFTA00008646
06/29/20      i
Q.     Are those Ghislaine Maxwell's initials?
2        A.     Yes.
3        Q.     Have you obtained any records from Interlochen to
4   indicate that Maxwell was at Interlochen in 1994?
5        A.     Yes.
6         4.     If we could turn to the next slide.         Can you
7   please explain for the grand jury what we're looking at on
8    this slide?
9         A.     This was a letter from Interlochen explaining
10   addressed to Maxwell telling her that they had found an
11   envelope in the lodge that they had been staying in.
12        Q.     All right.       We were talking a few moments ago
13   about how          described meeting Maxwell and Epstein at
14   summer camp, and you testified that she provided them with
15   her phone number.      Did         explain to you whether or not
16   she had any contact with Epstein or Maxwell after she
17   returned home to Palm Beach?
18        A.     Yes.
19        Q.     When was the next time that happened?
20        A.     Shortly thereafter.
21        Q.     And how did that occur?
22        A.     She was invited to his house.      So her and her
23   mother went to Epstein's house to visit.
24        Q.     What did             tell you about that visit to
25   Epstein's house with her mother?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000147
EFTA00008647
06/29/20   18
A.   She said it was        wait, can you rephrase that?
2        Q.   Of course.     Did           go to the house by herself
3   or with her mother?
4        A.   With her mother.
5        Q.   Okay.   And when they went to the house, what did
6    they do there?
7        A.   They had tea.
8         Q.   Who was there when they had tea at the house?
9         A.   Epstein and Maxwell.
10        Q.   What did they discuss as they had tea?
11        A.   They just talked about her life and, you know,
12   what she wanted to do.
13        Q.   Did Epstein make any offers?
14        A.   He said that he gives scholarships.           He likes to
15   mentor people.
16        Q.   How did               mother react when Epstein said
17   this?
18        A.   She was happy for her daughter and oftentimes
19   referred to Epstein as             Godfather.
20        Q.   After that occasion when they went over to the
21   house, thereafter did             subsequently begin regularly
22   spending time with Maxwell and Epstein at Epstein's house in
23   Palm Beach?
24        A.   Yes.
25        Q.   And did that start when she was approximately age
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000148
EFTA00008648
06/29/20   19
14?
2         A.    Yes.
3         Q.    Did it continue until she was about age 17?
4         A.    Yes, it did.
5         Q.    And during those years, did she regularly go over
6   to Epstein's house in Palm Beach and spend time with Maxwell
7   and Epstein?
8          A.    Yes.
9          Q.    What happened in the summer of 1997 when
10   was 17 and about to turn 18?
11         A.    She moved to New York City.
12         Q.    Why did she move to New York City?
13         A.    She wanted to pursue a career in acting and
14   modeling.
15         Q.    We'll talk about that in a moment, but for now I
16   want to focus on the years you talked about in Palm Beach
17   from ages 14 to 17 when          would regularly go to
18   Epstein's house.    In the beginning, in the first few months
19   when she went there, what kinds of things did she do when
20   she would visit the house when Maxwell and Epstein were
21   there?
22         A.    They'd hang out by the pool, he -- they would take
23   her to the movies, take her shopping.       She described the
24   behavior as grooming.
25         Q.    When you say grooming, did she explain what sh,
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000149
EFTA00008649
06/29/20    20
1   meant by that?
2         A.     She meant that they were building a relationship
3   with her, giving her things, taking her places.            And then
4   usually when the grooming happens, an offender will -- once
5   they gain that trust, they will make the relationship turn
6    sexual.
7        Q.     Now, you testified just a moment ago that
8    described to you that she felt at this time period that they
9    were grooming her.      Is that right?
10        A.     Yes.
11        Q.     Is that something that she realized at the time
12   when she was 14, or is that something that she's described
13   to you now?
14        A.     Something she's described now.       She didn't realize
15   that at the time.
16        Q.     So we'll talk a little bit more about grooming in
17   a moment, but just to give context are you familiar with the
18   term grooming based on your experience investigating crimes
19   involving a sexual exploitation of minors?
20        A.     Yes.
21        Q.     Generally speaking, -- you were touching on this a
22   moment ago, but if you just could explain in full.              What is
23   grooming?
24        A.     Grooming is when someone builds a relationship
25   with a child.      They find a vulnerability or a need and then.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000150
EFTA00008650
06/29/20      21
1   they work on gaining a child's trust, and then oftentime
2    gaining a parent's trust.    Once they have that trust, they
3   show that in ways that they care about them by giving them
4   gifts and promises.   And then once that's established, they
5   then turn the relationship sexual, oftentimes making sexual
6    comments and normalizing the behavior.
7       4.    Now, during these visits that you've been
8    describing that        told you about, did                say whether
9    Epstein ever gave her anything?
10        A.   Yes, she did.
11        Q.   What did he give her?
12        A.   He gave her cash.    Sometimes he'd tell her to give
13   the cash to her mom because he knew that they needed it.             He
14   paid for her voice lessons as well.
15        Q.   Now, you were describing how              has
16   characterized these visits now.     But based on your
17   conversations with her, at the time did she feel that these
18   visits were strange at all?
19        A.   She thought they were strange, but Maxwell
20   normalized it for her.    She was like a cool older sister and
21   made comments like this is what grownups do.
22        Q.   You used the phrase cool older sister.            Is that a
23   phrase that       used to describe how she felt about
24   Maxwell at the time and what Maxwell was like?
25        A.   Yes, those are her words.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_0000015 I
EFTA00008651
06/29/20   22
Q.    Did there come a time -- these visits when
2   saw Maxwell topless by the pool?
3        A.   Yes.
4       Q.    What did she tell you about that?
5       A.    She was a little taken back, but Maxwell just
6    acted normal.
7       Q.    Did          tell you about an incident several
8    months into this arrangement when she was alone with Epstein
9    in the pool house?
10       A.    Yes.
11       Q.    And when they were alone together, did Epstein ask
12         what she wanted to do with her life?
13       A.    He did.
14       Q.    What did she say?
15       A.    She said she wanted to be an actress and a model.
16       Q.    How did Epstein respond?
17       A.    He told her that he was best friends with the
18   owner of Victoria Secret.      Told her that she would have to
19   have photographs taken and that she got to be comfortable in
20   her underwear, and not to be a prude.        When she asked what
21   that meant, he pulled her to his lap and masturbated.
22       Q.    What was her reaction?
23        A.   She felt paralyzed.       She froze.
24       Q.    After this incident, did                   encounters with
25   Epstein begin to include sexual contact?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_OOOOO152
EFTA00008652
06/29/20   23
A.    Yes.
2        Q.    Over time, did the sexual abuse escalate?
3        A.    It did.
4        Q.    From what she's described to you, did the abuse
5   include Epstein digitally penetrating
6         A.    Yes.
7        Q.    Did it include Epstein using a vibrator on her?
8         A.    Yes.
9         Q.    Did she describe to you that there were times when
10   Epstein would direct            to massage him while he
11   masturbated?
12        A.    Yes.
13        Q.    Did          explain to you what her memories are
14   like of the abuse?
15        A.    Yes.
16        Q.    What did she say about that?
17        A.    She said that it happened so often that it all
18   kinds -- it all runs together for her.         That it's hard to
19   separate out some of the different instances of abuse.
20        Q.    You were describing how             explained to you
21   that the abuse began.      Did that occur based on what
22   told you within the first year that she met Epstein and
23   Maxwell?
24        A.    Yes.
25        Q.    Now, did           also describe to you that once this
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000153
EFTA00008653
06/29/20   24
abuse started, Epstein would also bring her into his massatl
2   room in the house?
3        A.   Yes.
4        Q.   And were there times where he did this where there
5   are other women present including Maxwell?
6         A.   Yes.
7        Q.   Was        abused during those episodes?
8         A.   Yes, she was.
9         Q.   During these group encounters what were                and
10   the adult women wearing?
11        A.   They were usually just in their underwear.
12        Q.   Once they were all in the massage room, how wou..a
13   these episodes generally start?
14        A.   They would generally start with one of the girls
15   massaging Epstein.         was usually massaging his fee-.
16   Maxwell was kind of teasing the girls; she'd grab the girls'
17   breasts and she would direct the girls on what to do.
18        Q.   When these episodes would start, in general was
19   Epstein generally lying face down on the massage table?
20        A.   Yes.
21        Q.   What would happen as things progressed generally
22   speaking from what she described to you?
23        A.   When Epstein would decide he was kind of done with
24   the regular massage, he would turn over to his back and he'd
25   grab whichever girl he wanted to either touch him or
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000154
EFTA00008654
06/29/20    95
1   whatever girl he wanted to touch.
2        Q.       Did these episodes include sex acts that over time
3   in various instances included Epstein masturbating, Epstein
4   receiving oral sex, and Epstein engaging in intercourse?
5        A.     Yes.
6        Q.      You were describing for a moment what              to_
7   you about Maxwell's role during these group encounters.
8    Would Maxwell sometimes guide the women and give
9    instructions about what to do?
10        A.     Yes, she would.
11       Q.      What would           typically do during these
12   episodes?
13        A.     She would try to not look at Maxwell because she
14   gave off that sister vibe so it felt weird for her.            She
15   would try to be invisible in that room so they would ignore
16   her as much as possible.
17       Q.      In the beginning when             was approximately 14
18   or 15, would she generally begin by just massaging Epstein's
19   feet?
20        A.     Yes.
21       Q.      Is that something she was told to do?
22        A.     Yes.
23       Q.       Did she -- you mentioned that she tried to be
24   invisible.    Was -- I believe that was your testimony?
25        A.     Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000155
EFTA00008655
06/29/20   26
Q.     And over time -- has she described to you that
2   over time she believes she became more involved in the
3   sexual activity which varied in each encounter?
4        A.     Yes.
5        Q.     Were there times -- let me rephrase that.            How did
6       you touched on this for a moment, but just to be clear,
7   how did           describe Maxwell's attitude during these
8    incidents?
9         A.     It was very casual.       She acted like this was
10   normal.   She gave off that vibe to her and -- yeah.
11        Q.     Did that make her feel more comfortable with what
12   was happening?
13        A.     It did.
14        Q.     Was          sometimes fully nude during these
15   episodes?
16        A.     Yes.
17        Q.     And during these episodes, did the abuse include
18   Epstein touching               breast?
19        A.     Yes.
20        Q.     Did it include directing             to touch Epstein's
21   genitals?
22        A.     Yes.
23        Q.     Beginning when               was approximately 14, does
24   she begin to travel with Epstein and Maxwell to New York
25   City on occasion?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000156
EFTA00008656
06/29/20        27
A.    Yes, she did.
2       Q.     Was that to the property you testified about
3   earlier?   The townhouse on the Upper East Side?
4        A.    Yes.
5       Q.     When         traveled to New York City, did she stay
6    at Epstein's townhouse in New York City?
7       A.     Yes, she did.
8        Q.       Did she recall that Maxwell and Epstein took her
9    shopping on one of her early trips to New York City?
10       A.     Yes.
11       Q.       Did she remember them buying her anything?
12       A.     She recalled them buying her white cotton
13   underwear.    Her description was that they were, like, little
14   girls underwear.
15       Q.     From ages 14 to 17, did Epstein ask                 to
16   periodically fly to New York for weekends at that townhouse
17   in New York?
18       A.     I'm sorry, say it again?
19       Q.     You testified that she began traveling to New York
20   City at age 14.    Did she then periodically travel to New
21   York City in a similar manner from ages 14 to 17?
22       A.     Yes.
23        4•    Were there times when she traveled on those trips
24   when she flew on Epstein's private jet?
25       A.     Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000157
EFTA00008657
06/29/20   99
Q.     Did she also sometimes fly commercially?
2        A.     Yes, she did.
3        Q.     Was Maxwell sometimes present on the trips to New
1   York?
5        A.     Yes.
6        Q.     You testified earlier that             was sexually
7   abused in Palm Beach.    Did she describe to you that she was
8    also sexually abused on these trips to New York?
9         A.     Yes, she did.
10        Q.     Did Maxwell encourage          to go on these trips?
11        A.     Yes.
12        Q.     What does        -- what did            tell you about
13   her memory of how these trips were arranged?
14        A.     She recalled that Maxwell was usually the one that
15   would schedule her flights.     If she was flying commercially,
16   she would schedule the flights, sometimes calling her mother
17   to schedule.
18        Q.     Was that her general impression of how they were
19   arranged?
20        A.     Yes.
21        Q.     In addition to the trips to New York City that you
22   just described, did          also remember traveling at least
23   once to Epstein's ranch in New Mexico?
24        A.     Yes, she did.
25        Q.     Did she remember whether or not she was sexually
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000158
EFTA00008658
06/29/20   29
abused in New Mexico?
2        A.   She couldn't recall.      She couldn't remember.
3        Q.   In general, how would            get to the airport in.
4   Florida when she would fly on Epstein's jet?          What did she
5   describe to you?
6         A.   Usually a driver       one of Epstein's drivers would
7   pick her up from her house and take her to the airport.
8         Q.   Now, you testified earlier that you reviewed
9    flight records for Epstein's private jet.          Is that correct?
10        A.    Yes.
11        Q.   And have you reviewed records from the 1990's
12   see if that there -- whether there's a person named
13   listed on the records?
14        A.    Yes.
15        Q.   Turning to the next slide.       Is this an excerpt
16   from those records?
17        A.    Yes, it is.
18        Q.   And does the red arrow point to -- just one
19   moment.   Does the red arrow point to a November 11th, 1996
20   flight?
21        A.    Yes, it does.
22        Q.   And is this a -- does this flight log reflect that
23   it was a flight from Palm Beach, Florida to Teterboro, New
24   Jersey?
25        A.    Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000159
EFTA00008659
06/29/20   30
Q.   Is there a private airfield in Teterboro, New
2   Jersey?
3        A.   Yes, there is.
4        Q.   What's it called?
5        A.   Teterboro Airport.
6         Q.   Are the passengers listed on this entry J.E.?
7        A.   Yes.
8         Q.   Are the -- do the entries also include              olu
9    friend,              (ph.), family, III (ph.) child,
10   (ph.), and
11        A.   Yes.
12        Q.   Was         -- based on your awareness of
13   date of birth and the date of this flight, was              16 on
14   the date of this flight?
15        A.   Yes, she was.
16        Q.   Turning to the next slide.     You testified earlier
17   about Teterboro Airport.   What are we looking at on this
18   slide?
19        A.   This is directions from Teterboro Airport to
20   Epstein's residence here in Manhattan.
21        Q.   So based on your review of this map, if someone
22   were to fly into Teterboro Airport and travel to New York
23   City, would they -- would the most natural root be to travel
24   from Teterboro Airport and crossing into New York through
25   Manhattan?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000160
EFTA00008660
06/29/20   31
A.   Yes.
2        Q.   Turning to the next slide.     Is this also an
3   excerpt from the flight records that you've reviewed?
4        A.   Yes, it is.
5        Q.   And does this show a May 9, 1997 flight from
6
Teterboro, New Jersey to Santa Fe, New Mexico?
7        A.   Yes, it does.
8         Q.   And are the passengers listed on this log J.E.,
9    G.M.,
10        A.   Yes.
11        Q.   Based on your knowledge of               birthdate and
12   the date of this flight, would            have been 16 on the
13   date of this flight?
14        A.   Yes, she would've been.
15        Q.   Turning to the next slide.     Is this also an
16   excerpt from the flight records?
17        A.   Yes.
18   Q.   And does the red arrow point to a flight entry on 19
May 3rd, 1998?
20        A.   Yes, it does.
21        Q.   Based on the airport codes, does this reflect that
22   there is a flight on that date from Palm Beach, Florida to
23   Teterboro, New Jersey?
24        A.   Yes.
25        Q.   And are the passengers listed on this log J.E.,
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000161
EFTA00008661
06/29/20     32
G.M., E.T.,           Glen (ph.),                   (ph.),
2   (ph.), Manny (ph.),                     (ph.)?
3        A.    Yes.
4        Q.   Based on your knowledge of                  birthdate and
5   the date of this flight, would               have been 17 on this
6    date?
7        A.    Yes.
8         Q.   Am I correct that you testified earlier that in
9    addition to sometimes flying on Epstein's private jet, she
10   also traveled on commercial airlines, is that correct?
11        A.    Yes,   it is.
12        Q.   Based on your review of these flight logs, does
13   every flight entry list the name of every single passenger,
14   or are there times when a passenger is noted female?
15        A.    There's time where a passenger is just noted
16   female.
17        Q.    I'm going to talk to you about two examples of
18   that.   Turning ahead two slides.      Looking at slide 18, does
19   this reflect a January 3rd, 1995 flight where the flight log
20   says J.E., two females?
21        A.    Yes, it does.
22        Q.   And do the two entries below also just list fema_ ,
23   next to the initials J.E.?
24        A.    Yes, they do.
25        Q.    Turning to the next slide, slide 19.          Is this
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000162
EFTA00008662
06/29/20   33
another example of an entry like that?      Focusing on the
2   entry on February 12th, 1995?
3        A.    Yes.
4       Q.     Does that entry also say female?
5        A.    Yes, it does.
6        Q.     Now, you testified that          sometimes flew on
7   commercial airlines and that arrangements for her travel
8    were made for her to fly commercially for these trips.
9    that right?
10        A.    Yes.
11       Q.     Have you been able to obtain commercial flight
12   records?
13        A.    We tried.   We were not able to obtain those
14   records.
15       Q.     Why is that?
16        A.    Airlines do not keep records past a certain year.
17       Q.     Does        recall group sexualized massages
18   involving Epstein and Maxwell in both the New York and
19   Florida residences during the time period we've been talking
20   about?
21        A.    Yes.
22       Q.     You testified earlier about the time that Epstein
23   and Maxwell would spend together and the activities that
24   they were involved in.     During this time period, did
25   have occasions to talk with Maxwell?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000163
EFTA00008663
06/29/20   34
A.    She -- I'm sorry, can you ask the question again?
2          Q.    During the -- beginning when she was 14 when she
3   began spending time with Epstein and Maxwell and through the
4   years, did         often have conversations with Maxwell about
her life?
6          A.    Yes.
7         Q.    Did they talk about that often?
8          A.    They did.
9          Q.    Did Maxwell ask            about her family, her
10   classes, and other aspects of her life?
11         A.    Yes, she did.
12         Q.    You testified earlier that just before she turned
13   18,         moved to New York City.       Is that right?
14         A.    Yes.
15         Q.    Did she go to school there in New York City for
16   her senior year?
17         A.    Yes, she did.
18         Q.    What school did she go to?
19         A.    She went to
20         Q.    What is
21         A.    They cater to individuals who want to pursue
22   careers in the arts.
23         Q.    Have you reviewed records from
24
25         A.    Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000164
EFTA00008664
06/29/20   35
Q•   If you could turn to slide 17.        Can you please
2   explain for the grand jury what we're looking at here?
3          A.   This is an excerpt from               application to III
4                                           On it is listed who is
5   financially responsible for her, and that is
6    Jeffrey Epstein.
7          Q.   From what           told you, did Maxwell encourage
8            to accept Epstein's financial help?
9           A.   Yes.
10          Q.   When          moved to New York City who was she
11   living with?
12          A.   She lived with her mother and brother in
13
14          Q.   Did Epstein help pay for her rent?
15          A.   He did.
16          Q.   During that year, her senior year of high school
17   when she was in New York City, did               remain in contact
18   with Epstein?
19          A.   Yes.
20          Q.   What was the nature of their contact like during
21   this time period?
22          A.   During this time he was still sexually abusing
23   her.
24          Q.   Did that continue to occur in his townhouse in
25   Manhattan that year?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000165
EFTA00008665
06/29/20   35
A.   Yes, it did.
2        Q.   What happened at the end of her senior year of
3   high school?
4        A.   She moved to Los Angeles to pursue a career in
acting.
6         Q.   Did she get a job as an actress when she was 18?
7        A.   She did.
8         Q.   Has        lived in Los Angeles and worked as an
9    actress on television ever since then?
10        A.   Yes.
11        Q.   After she moved to Los Angeles did she continue
12   being in touch with Epstein?
13        A.   For a short period of time.
14        Q.   Did she ultimately break contact with him?
15        A.   Yes, she did.
16        Q.   Is         currently pursuing a civil lawsuit
17   against Maxwell and Epstein's estate?
18        A.   Yes.
19        Q.   Have you talked with          about whether when she
20   was a teenage girl when all of this was happening whether
21   she told anyone that she was being sexually abused?
22        A.   Yes, she said she didn't tell anyone.         She te_
23   like she couldn't.   She -- the -- nothing was talked about
24   outside of that room, so it made it so that she couldn't
25   talk about it.   And then she also -- her mother is Middle
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000166
EFTA00008666
06/29/20
1   Eastern, and her mother raised her that women are supposed
2    to do what they're told even if someone is beating you.
3             And when she was 13 and her father passed, she was
4   -- she went to a guidance counselor at school to talk about
5   it, and her mother found out about it and smacked her.       So
6    she felt like she couldn't talk to anyone about it.
7        Q.   Did          mother encourage her to accept
8    Epstein's financial assistance?
9         A.   Yes, she did.
10        Q.   Have you become aware that in 2005, police
11   officers from the Palm Beach Police Department executed a
12   search warrant at Epstein's house at the El Brillo Way
13   address in Palm Beach?
14        A.   Yes.
15        Q.   Have you reviewed some of the materials seized
16   during the search?
17        A.   Yes.
18        Q.   Did they find massage tables and sex toys?
19        A.   Yes, they did.
20        Q.   Did they find any photographs of
21        A.   Yes.
22        Q.   Was one of the photographs signed by
23        A.   Yes, it was.
24        Q.   Did it say
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000167
EFTA00008667
06/29/20
A.   Yes.
2        Q.   During your interviews with               did        tell
3   you how she felt about Epstein and Maxwell in the '90's when
4   she was a young girl?
5        A.   She did.   She expressed that she felt like they
6    loved her, she felt like they were her family.         That they
7   supported her and that she felt she was made to feel like
8    that she needed to be grateful to them.
9         Q.   Okay.   Did she tell you that she felt like they
10   were trying to help her?
11        A.   Yes.
12        Q.   Have you talked with          about how she feels
13   about this now?
14        A.   Yes.
15        Q.   What was           demeanor like when she described
16   to you what Epstein and Maxwell had done to her?
17        A.   She was upset.    She recognized that now, it's
18   affected her life to a great degree.      She's struggled in
19   relationships with opening up to people and trusting people,
20   both personal and professional relationships.
21        Q.   Did she tell you that she struggled to tell anyone
22   what had happened to her for most of her adulthood?
23        A.   Yes.
24        Q.   When was the first time that you interviewed
25
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000168
EFTA00008668
06/29/20   39
A.   Last fall.
2          Q.   Was that the first time she'd ever reported this
3   to law enforcement?
4          A.   Yes, it was.
5          Q.   Now, you testified earlier about your interviews
6    with                who worked at Epstein's Palm Beach house.
7   Did he remember a girl named            coming to the house
8    during that time?
9           A.   Yes, he did.
10          Q.   Did he recall           Maxwell, and Epstein being in
11   the Palm Beach house together?
12          A.   Yes.
13          Q.   What was his understanding of why              was there?
14          A.   He thought that Epstein was helping her, that'
15   what Epstein had told him, and             had told him that
16   Epstein was helping her.
17          Q.   Did he ever observe Epstein interacting with
18   physically?
19          A.   Yes.
20          Q.   What did he see?
21          A.   He saw Epstein kiss             cheek and pat her on
22   the bottom.
23          Q.   Did he have any knowledge about what was happening
24   with Epstein or Maxwell when he wasn't present?
25          A.   He didn't.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000169
EFTA00008669
06/29/20   40
Q.     Did          ever recall picking up            from her
2   house?
3         A.     Yes.
4         Q.    And when he would pick her up from her house,
5   would he then bring her back to the Palm Beach house:
6          A.     Yes.
7         Q.     Did he remember who in general would tell him to
8    pick up            from her house?
9          A.     Maxwell would be the one to tell him to pick her
10   up.
11         Q.     Did he recall ever driving               to the movies?
12         A.     Yes.
13         Q.     What did he tell you about that?
14         A.     That it would usually be Epstein, Maxwell, anc
15              They'd go to the movies and it would usually be late
16   at night.
17         Q.     Did he tell you about what his memory was about
18   how old            was?
19         A.     He said she was young and that he knew that
20   because he had picked her up from school and that he knew
21   she was too young to drive.
22         Q.    Switching gears.      I want to talk to you about a
23   different aspect of your interviews with                         Based
24   on what he told you about his job duties, were there ever
25   times when he would have to clean Epstein's massage room?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000170
EFTA00008670
06/29/20   41
A.   Yes.
2       Q.    What did he tell you about that?
3        A.   He said that he found sex toys in the massage room
4   and he had to wash them afterwards.
5       Q.    Aside from those experiences, was he aware of
6    there being sex toys in the house?
7        A.   Yes.   There was a basket of sex toys that were
8    kept in Maxwell's closet.
9        Q.    Did         stop working for Epstein in
10   approximately 2002?
11        A.   Yes.
12       Q.    Was he told that he was being replaced?
13        A.   Yes.
14       Q.    And was he generally aware that the person who
15   replaced him was much younger?
16        A.   Yes.
17       Q.    Did         tell you that a few months after he
18   left working for Epstein he became suicidal because of
19   issues in his marriage?
20        A.   Yes.
21       Q.    Did he tell you that he went to Epstein's house
22   and tried to take Epstein's gun?
23        A.   Yes, he did.
24       Q.    Did he tell you he took several thousand dollars?
25        A.   Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000171
EFTA00008671
06/29/20   42
Q.     Did Epstein discover this and confront him about
2   it?
3         A.     Yes, he did.
4         Q.    Did         admit to Epstein and the police what
he'd done?
6         A.     Yes.
7         Q.     Did Epstein also tell the police his gun was
8    missing?
9          A.     Yes.
10         Q.     Were there any charges filed?
11         A.    No.
12         Q.     Was he ever arrested?
13         A.     I don't believe so.
14         Q.    And did Epstein pursue any charges about this
15   incident?
16         A.    No, he didn't pursue anything.
17         Q.     Have you interviewed one of Epstein's former
18   pilots?
19         A.     Yes.
20         Q.     Is that pilot named
21         A.     Yes.
22         Q.     Was he one of the pilots for Epstein's private jet
23   in the 1990's?
24         A.     Yes.
25         Q.     Did he remember                  traveling on the je
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GJ_SDNY_00000172
EFTA00008672
06/29/20
in the 90's?
2       A.     He remembered her traveling, but he didn't
3   remember specifics.
4       Q.     So just to be clear, is your testimony that he
5   didn't remember the specific dates of the flights, but he
6    remembered her traveling on the jet during the 1990's?
7       A.     Yes.
8        Q.     And did he remember                      specifically as
9    a person who traveled?
10        A.    Yes.
11       Q.     Did you discuss with him the flight records that
12   we talked about earlier that lists a person named               as
13   passenger?
14       A.     Yes.
15       Q.     Did he have a specific memory of those exact
16   flights?
17       A.     No.
18       Q.     But was he aware of any other              flying on the
19   jet besides                  in the 1990's?
20        A.    No, no other         at that time.
21       Q.     Earlier when we were looking at Interlochen
22   attendance records for the summer of 1994, you noted tha
23   •             was one of the names on that record.        Is that
24   right?
25       A.     Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000173
EFTA00008673
06/29/20   44
Q.   Is that
2        A.   Yes.
3        Q.   Have you interviewed
4        A.   Yes, I have.
5        Q.   Did he tell you that he remembered               talking
6    that summer at camp about having met Jeffrey Epstein?
7        A.   Yes.
8         Q.   Did he tell you that he remembered               going
9    over to Epstein's house in Palm Beach when they were in high
10   school?
11        A.   Yes.
12        Q.   Did he remember that             would often talk about
13   spending time with Maxwell and Epstein during this time?
14        A.   Yes.
15        Q.   Did he remember            telling him when they were
16   in high school about at least one trip to New York City that
17   she took with Epstein?
18        A.   Yes.
19        Q.   Did he remember            describing Epstein's
20   townhouse in Manhattan?
21        A.   Yes.
22        Q.   And does he remember             talking often about
23   Ghislaine Maxwell?
24        A.   Yes.
25        Q.   Now, based on your interviews with               did he
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000174
EFTA00008674
06/29/20     45
tell you whether he knew back then when they were in high
2   school whether             was being sexually abused by Epstein?
3         A.     He didn't know back then.
4         Q.     Did III ever meet Ghislaine Maxwell?
5         A.     Yes, he did.
6          Q.     What did he remember about that?
7           A.   He remembered Epstein, Maxwell, and                 being
8    near a movie theatre and he was approximately 16 at the time
9    and          would've been 15, and just the little bit of
10   interaction they had.       And then after that,             had told
11   him that Maxwell had said something to the effect I could
12   teach                    a thing or two.
13         Q.     Is that something that he remembers                 telling
14   him back then that Maxwell had said?
15         A.     Yes.
16         Q.     During the course of this investigation, have you
17   participated with interviews with an individual named
18
19         A.     Yes.
20         Q.     So for today's purposes I'm just going to refer to
21   her as              How many times have you interviewed
22           A.   Approximately twice.
23         Q.     Now, does          know                      Have they
24   ever met as far as you know?
25           A.   As far as I know, no.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000175
EFTA00008675
06/29/20   46
Q.     Turning to the next slide.       Are these photographs
2   of          when she was in high school?
3        A.      Yes.
4        Q.     And is her date of birth
5        A.      Yes.
6         Q.      When        was approximately 16 and a junior in
7   high school, where was she living?
8         A.     She was living in Arizona with her mother.
9         Q.     Does she have any siblings?
10        A.     An older sister.
11        Q.      What did her older sister do?
12        A.      Her older sister lived -- worked for Epstein.
13        Q.      Where did she work for Epstein?
14        A.      Here in New York.
15        Q.      Did there come a time in approximately December
16   1995 when           had a phone conversation with her sister
17   about traveling to New York City?
18        A.      Yes.
19        Q.      What did they discuss?
20        A.     They discussed her coming to New York and meetinc
21   Epstein.
22        Q.      What did her sister tell           about why she
23   should meet Epstein?
24        A.     She said that he could help her with college.
25        Q.     And did she say -- did the sister say whether the
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000176
EFTA00008676
06/29/20   47
sister wanted her to meet Epstein or did she say whether
2   Epstein wanted to meet
3        A.   Epstein wanted to meet
4        Q.   Now, let me just pause here.       You testified that
5   this happened in approximately December of 1995.          Just for
6    context, the years that we were talking about with
7                    was that 1994 through 1997?
8         A.   Yes.
9         4.   So is this approximately the same time period
10   while what you described           telling you happened?
11        A.   Yes.
12        Q.   So in January of 1996, did               fly on a
13   commercial airline to New York City to spend a weekend with
14   her sister and meet Jeffrey Epstein?
15        A.   Yes.
16        Q.   Did she tell you that?
17        A.   Yes.
18        Q.   During the trip, did            tell you that she met
19   Epstein at his townhouse in New York City?
20        A.   Yes, she did.
21        Q.   Did she tell you that Epstein discussed her plan.,,
22   for college applications and offered to help her?
23        A.   Yes.
24        Q.   What was            first impression of
25   Jeffrey Epstein?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000177
EFTA00008677
06/29/20    4P
A.   She was very impressed by him.
2          Q.   What did she -- what was her impression based on
3   this conversation of what Epstein was going to do for her?
4          A.   That he was going to help her with her future
5   plans for college.
6           Q•   During that trip to New York City, did she stay at
7   Epstein's townhouse or at her sister's apartment?
8           A.   Her sister's apartment.
9           Q.   During that trip, did she tell you that she saw
10   Epstein a second time when he took                and her sister to
11   the movies?
12          A.   Yes.
13          Q.   What did she tell you happened at the movies?
14          A.   She said that they were sitting in the theatre and
15   Epstein was between           and her sister, and Epstein put
16   his hand on her leg, he rubbed her arm and held hands with
17   her.
18          Q.   From what she told you what was her impression
19   about whether her sister could see what was going on?
20          A.   She felt like her sister couldn't see.
21          Q.   What was her reaction to this happening?
22          A.   She was uncomfortable.
23          Q.   After the movie did she tell her sister what had
24   happened?
25          A.   No, she didn't.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000178
EFTA00008678
06/29/20   49
Q.    Did she say why not?
2       A.    She said that she knew            -- her sister really
3   liked Epstein and that Epstein could help them, so she
4   didn't tell her.
Q.    After this trip did           go back home to
6         A.   Yes.
7       Q.    Did Epstein contact her afterwards?
8         A.   Yes.
9        Q.    Did he discuss with her her ongoing college plans?
10        A.   Yes, he did.
11       Q.    Did he invite her to a weekend at his ranch in New
12   Mexico in the spring of 1996?
13       A.    Yes.
14       Q.    Was she 16 at the time?
15       A.    Yes, she was.
16       Q.    From what she told you, what was
17   impression of who would be on this trip to New Mexico?
18       A.    She knew Maxwell would be there.
19       Q.    Did she -- was she told anyone else was going to
20   be present during this trip?
21       A.    She said that there would be, like, other students
22   her -- kids her age.
23       Q.    And what was her understanding of who these other
24   kids were and why they'd be there?      Sorry, let me
25       A.    Rephrase.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000179
EFTA00008679
06/29/20   50
Q.     -- rephrase the questions.     You testified that she
2   was told that on this trip that there would be other
3   students.    Was she under the impression that there would be
4   other young students like her on the trip who were also
5   being mentored by Epstein?
6         A.     Yes.
7        Q.     Now, you testified just a moment ago that she was
8    also told that Maxwell would be there.       Are you referring to
9    Ghislaine Maxwell?
10        A.     Yes.
11        Q.     At the point that she was told that
12   Ghislaine Maxwell would be on this trip, had she ever met
13   Ghislaine Maxwell?
14        A.     No, she hadn't.
15        Q•     Had she heard her sister talk about
16   Ghislaine Maxwell?
17        A.     Yes.
18        Q.     How did -- from what she described to you, how did
19   her expectation that Maxwell would be on this trip make her
20   feel about the trip?
21        A.     It made her comfortable.    Her sister had talked
22   highly of Maxwell.
23        Q.     Did       tell you that she flew to New Mexico
24   that spring when she was 16?
25        A.     Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000180
EFTA00008680
06/29/20   51
Q.   Did she meet Ghislaine Maxwell when she arrived in
2   New Mexico?
3        A.   Yes, she did.
4        Q.   How did she describe Maxwell's demeanor and
5   attitude when she met her?
6         A.   She described Maxwell as being very charming.          She
7   gave her a tour of the house and Maxwell took
8    shopping, which made her feel special.
9         Q.   What does she remember talking about with
10   Ghislaine Maxwell?
11        A.   They talked about school, homework, trips.
12        Q.   Did she talk with her about applying to college?
13        A.   Yes.
14        Q.   Did she talk about her classes in high school?
15        A.   Yes.
16        Q.   Did she talk with her about the homework that she
17   had to do that weekend?
18        A.   Yes.
19        Q.   Did she talk with Maxwell about her family?
20        A.   Yes.
21        Q.   Did she talk with her about her home life and
22   living with her mother?
23        A.   Yes.
24        Q.   From what        told you, when she got there who
25   else was at the ranch besides Ghislaine Maxwell and
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_0000018I
EFTA00008681
06/29/20   52
1   Jeffrey Epstein?
2        A.   It was just them.
3       4.    Was it just the three of them the entire weekend
4   of the visit?
5       A.    Yes.
6        Q.    Were there any other school kids there?
7       A.    No.
8        Q.    When they were at the ranch, from what              told
9    you, did Maxwell say anything to            about massages?
10       A.    Yes.
11       Q.    Did she say anything to her about foot massages?
12       A.    Yes.
13       Q.    What did          tell you about that?
14       A.    Maxwell told          to give Epstein a foot massage,
15   and then she showed her and instructed her how to do it.
16         was a little uncomfortable, but Maxwell was joking
17   around so she just followed her lead.
18       Q.    Did         tell you what Maxwell and Epstein took
19   her to the movies that weekend?
20       A.    Yes.
21       Q.    What did she tell you about that trip to t
22   movies?
23       A.    She said that when they went outside the theatre
24   Maxwell was joking around and pulled Epstein's pants down a
25   little bit.   And then once they went inside the theatre,
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000182
EFTA00008682
06/29/20
1   Epstein -- when they were sitting down, Epstein touched
2              leg, he rubbed her arm, held her hand.        And this
3   time he --         felt that he wasn't trying to hide it from
4   Maxwell.
5        Q.     What was            reaction to all of this?
6         A.    She was uncomfortable.
7        Q.     During the same weekend, was there another
8    occasion when Maxwell talked about massages?
9         A.     Yes.
10        Q.     What happened?
11        A.     Maxwell had asked         if she ever had a massage,
12   and Maxwell told her she could give her one.          So        was
13   on her back and Maxwell had pulled the sheet down exposing
14   her chest, she was nude from the top up, and proceeded to
15   massage around her chest and breast area.
16        Q.     From what         told you when she was describing
17   to you what you just described to the grand jury, how did
18   she feel while this was happening?
19        A.    She felt really uncomfortable.
20        Q.     Did         also tell you about an incident that
21   happened one morning when she was in New Mexico?
22        A.     Yes.
23        Q.     What did she tell you happened?
24        A.    She said she was in bed and Epstein came into the
25   room and told her that he wanted to cuddle.          So he laid down
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000183
EFTA00008683
06/29/20   54
next to her and spooned her.     She told him she had to go tc
2   the bathroom to get out of the situation.
3         Q•    What was her reaction to that when Epstein got
4   into her bed?
5         A.    She was uncomfortable.    She didn't know what to
6    do.
7         Q.    Did       go back home to               when the weekend
8    was over?
9          A.    Yes, she did.
10         Q.    Did she tell anyone when she got home about what
11   happened?
12         A.    No.
13         Q.    Is that for the same reason you described earlier?
14         A.    Yes.
15         Q.    Did Epstein end up paying for             to go on a
16   trip to Thailand that summer?
17         A.    Yes.
18         Q.    Did       have any contact with Maxwell or Epstein
19   after that trip?
20         A.    Not that she recalled.
21         Q.    When you interviewed           what was her demeanor
22   like when she described her interactions with
23   Jeffrey Epstein and Ghislaine Maxwell?
24         A.    She became upset, emotional.
25         Q.    Is       currently pursuing a civil lawsuit
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000184
EFTA00008684
06/29/20
against Maxwell and Epstein's estate?
2        A.    Yes, she is.
3        Q.    What does        do for a living now?
4        A.    She's a psychologist who works with trauma
5   victims.
6         Q.    During the course of this investigation, have you
7   interviewed someone named
8         A.    Yes.
9         Q.    For today's purposes, I'm just going to refer to
10   her as            How many times have you interviewed
11   approximately?
12        A.    Approximately three times.
13        Q.    Turning to the next slide.     Is this a photograph
14   of          that she provided to you?
15        A.    Yes.
16        Q.    And did she tell you that this was taken when she
17   was in -- approximately 16 or 17 years old?
18        A.    Yes.
19        Q.    Is             date of birth
20        A.    Yes.
21        Q.    Did         grow up in England?
22        A.    Yes, she did.
23        Q.    Did she tell you that there came a point when she
24   met Ghislaine Maxwell when she was about 17?
25        A.    Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000185
EFTA00008685
06/29/20   56
Q.    How did she tell you that they met?
2        A.    She said they met through a mutual friend.
3   Q.   Did she tell you that this would've happened in 4
around 1994 or 1995?
5        A.    Yes.
6         Q.    And is that within the same time period that we've
7   been talking about today?
8         A.    Yes.
9         Q.    What happened after she was introduced to
10   Ghislaine Maxwell from what she told you?
11        A.    She said Maxwell treated her like they were
12   sisters.   Her quote was, "like naughty school girls" is how
13   Maxwell treated with -- her.
14        Q.    Did she tell you that Maxwell seemed to
15   immediately take an interest in her?
16        A.    Yes.
17        Q.    Did she tell you that they began spending time
18   together in London?
19        A.    Yes.
20        Q.    And just to be clear, was Maxwell in her 30's
21   while this was happening?
22        A.    Yes.
23        Q.    Did Maxwell -- did           ever remember Maxwell
24   ever talk about having a boyfriend named Jeffrey Epstein?
25        A.    Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000186
EFTA00008686
06/29/20
Q.     What did she tell            about that?
2        A.     Maxwell told            that Epstein was going to
3   like her.
4        Q.     Did there come a time when she was 17 that
described that Maxwell introduced her to Jeffrey Epstein?
6         A.     Yes.
7        Q.     How did she describe that occurring?
8         A.     Epstein had flown to London.      He was at Maxwell's
9    residence in London and Maxwell had called                 over.     So
10             went over and when she got there, Maxwell was saying
11   to Epstein kind of -- the words               used was giving him
12   a resume of her attributes.      Saying she's so pretty, she's
13   so strong, and then Maxwell asked her to give Epstein a
14   massage.
15        Q.     Now, you testified just a moment ago that Maxwell
16   -- that            described to you that Maxwell asked her to
17   give Epstein a massage during this first meeting.              Is that
18   correct?
19        A.     Yes.
20        Q.     Did Maxwell say to her in sum and substance since
21   you're so strong I'd appreciate it if you give Jeffrey a
22   massage because he needs a massage every day or I get in
23   trouble?
24        A.     Yes, she said that.
25        Q.     Is that what           said to you in sum and
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000187
EFTA00008687
06/29/20
substance?
2        A.      Yes.
3       Q.       When that happened, did            remember Maxwell
4   leading her to a room in the house?
5        A.      Yes.
6         Q•      What happened?
7        A.      When         went in the room, Epstein was in a
8    robe.     He took his robe off and she started massaging him,
9    and then he touched             and pulled her hand to his
10   penis.
11       Q.       What does          remember Epstein saying when he
12   did this?
13        A.     Don't be frigid.
14       Q.      What was her reaction to this happening from what
15   she told you?
16        A.     She was taken back by it.
17       Q.       When this episode ended and              left the room
18   did she tell you that she remembered Maxwell being just
19   outside the room when she left?
20        A.      Yes.
21       4•      Did she remember Maxwell saying to her, did you
22   have fun?     Did he like it?
23        A.      Yes.
24       Q.      Does she remember Maxwell calling her several days
25   afterwards or at some short period of time afterwards?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000188
EFTA00008688
06/29/20   59
A.   Yes, she did.
2        Q.   Did          remember Maxwell saying to her on the
3   phone call in sum and substance, well, aren't you a clever
4   girl, Jeffrey was very impressed?
5        A.   Yes.
6         Q.   Shortly after this incident, does she remember
7   Maxwell asking her to come back over to the house?
8         A.   Yes.
9         Q.   And when she got there did she tell you she
10   remembered Maxwell saying to her, in substance, thank God
11   you're here; if it's not you or someone it falls to me?
12        A.   Yes.
13       4•    Does she remember Maxwell bringing her up the
14   stairs to the house on that occasion?
15        A.   Yes, she did.
16        Q.   What does she remember happening when Maxwell
17   opened the door to the room?
18        A.   Epstein was standing there nude.
19       4•    Does she remember Maxwell then saying I'll leave
20   you guys to it?
21        A.   Yes.
22        Q.   After these first two encounters, did Epstein and
23   Maxwell invite               to travel with them to Palm
24   Beach, U.S. Virgin Islands, Paris, and New York for the next
25   several years?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000189
EFTA00008689
06/29/20     60
A.   Yes, they did.
2        Q.   Does she remember whether these trips began before
3   or after her 18th birthday?
4        A.   She couldn't remember specifically.
5        Q.   Before these trips started, you were describing
6    earlier when          told you about the time that she spent
7   with Maxwell when they first met when she was 17.           Is that
8    right?
9         A.   Yes.
10        Q.   During these conversations when she would spend
11   time with Maxwell, did           remember talking with her
12   about her life and her family, and her personal
13   circumstances with Maxwell?
14        A.   Yes.
15        Q.   Now, you testified a moment ago that                 told
16   you that at some point she began traveling with Maxwell and
17   Epstein, and she wasn't sure whether or not whether these
18   trips started before she turned 18.     Is that right?
19        A.   Yes.
20        Q.   Did         describe to you that Epstein sexually
21   abused her during these trips, typically in the context of a
22   sexualized massage?
23        A.   Yes, he did.
24        Q.   Did Epstein give her money?
25        A.   Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000190
EFTA00008690
06/29/20   61
Q.      Did she tell you that he would give her cash?
2        A.   Yes.
3        Q.      Did she describe to you that the abuse included,
4   among other things, Epstein groping her and using a massager
5   device on her genitals?
6         A.   Yes.
7        Q.   And was the massager device like a vibrator?
8         A.   Yes, it was.
9         Q.   From what             told you, was Maxwell in the
10   room during these encounters?
11        A.   Maxwell wasn't in the room.
12        Q.   What did she tell you would typically happen when
13                 left the room after these episodes; was Maxwell
14   typically nearby?
15        A.   Yes.    She was usually right near the room.
16        Q.   Does she remember Maxwell asking her, after she'd
17   leave the room from one of these sessions, 'how was it, is
18   he happy?'
19        A.   Yes.
20        Q.      Did she also tell you that she remembers Maxwell
21   telling her at some point, in sum and substance, 'you know
22   how he is when he's not happy and you know what makes him
23   happy, he has to have sex all the time, he's like a super
24   hero?'
25        A.   Yes, she said that.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000191
EFTA00008691
06/29/20   62
Q.     Did         tell you about an incident that
2    occurred after she turned 18 in Palm Beach when she was
3   staying at the Palm Beach house?
4        A.     Yes.
5        Q.     Did the incident she described to you involve a
6    school-girl outfit?
7        A.     Yes, it did.
8         Q.     Could you please describe for the grand jury what
9              told you about that incident?
10        A.             said that Maxwell had shown her to a
11   bedroom and on the bed was a school-girl outfit and Maxwell
12   told her when --            confronted her about it and Maxwell
13   said 'well, I thought it would be adorable if you gave
14   Jeffrey his tea in this.'     So           felt like she had to
15   put it on so she put it on, took Epstein his tea, and
16   Epstein then slapped her on the buttocks and reached under
17   the skirt and touched her.
18        Q.     What was her demeanor like when she described this
19   incident to you?
20        A.    She was crying; she was very upset.
21        Q.     When           described seeing the school-girl
22   outfit and talking to Maxwell about it, did she remember
23   Maxwell telling her 'don't be so frigid?'
24        A.     Yes.
25        Q.     Does she remember that later in the day, after she
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000192
EFTA00008692
06/29/20   63
had delivered Epstein his tea and he assaulted her, does she
2   remember Maxwell telling her 'I heard you did well?'
3        A.    Yes.
4        Q.    During the years that            was in contact with
5   Maxwell and Epstein did she remember whether Maxwell would
6    ever ask her if she knew any other girls who could massage
7   Epstein?
8         A.    Yes.
9         Q.    Does she remember Maxwell saying, in sum and
10   substance, 'do you know anyone who can give him a blow job
11   today; I don't feel like it?'
12        A.    Yes.
13        Q.    Does she remember Maxwell saying, when she asked
14   her to bring other girls, that they have to look young at
15   least?
16        A.    Yes.
17        Q.    From your conversations with               did she tell
18   you whether or not she ever brought any other girls?
19        A.           didn't bring any girls.
20        Q.    Did she tell you why not?
21        A.    She didn't want anyone else to go through that.
22        Q.    From your interviews with               did she tell you
23   that there came a time when she was in her early 20s when
24   she stopped traveling with Maxwell and Epstein?
25        A.    Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000193
EFTA00008693
06/29/20   64
Q.    Was she struggling with substance abuse at tha
2   point?
3       A.    Yes, she was.
4       Q•    Did she tell you that she got sober in her 20s?
5       A.    Yes, she did.
6        Q.    What is her current profession?
7       A.    She runs a non-profit for people who struggle with
8    addiction and trauma.
9        Q.    Did           provide you with several emails that
10   she exchanged with Epstein in the early 2000s?
11        A.   Yes, she did.
12       Q.    And were those emails very friendly in tone?
13        A.   Yes, they were.
14       Q.    What did she say to you when you talked with her
15   about those emails?
16       A.    She said she didn't, at the time, want to
17   acknowledge what was going on to her; that looking back on
18   it's different.
19       Q.    Did your squad at the FBI execute a search warrant
20   at Jeffery Epstein's townhouse in Manhattan in July 2019?
21       A.    Yes.
22       Q.    Did you personally participate in the search of
23   Epstein's residence?
24        A.   Yes, I did.
25       Q.    Did the townhouse include a massage room?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000194
EFTA00008694
06/29/20   69
A.      Yes.
2       Q.      Have you yourself been in that massage room?
3        A.     Yes, I have.
4       Q.      Could you please describe for the grand jury what
5   that massage room looked like?
6        A.      It was dark.   It had dark draperies covering the
7   windows.    There was a massage table.      There were oils.
8    There was a hand-held massager in there along with
9    handcuffs, a whip, and along the walls were nude photographs
10   of young females.
11       Q.      I believe you testified a moment ago tha-
12                 told you that there was a time when Maxwell
13   asked her to wear a school-girl outfit for Epstein when they
14   were in Palm Beach.     Did you find a school-girl outfit in
15   Epstein's New York townhouse?
16        A.     Yes, we did.
17       Q.      Where did you find it?
18       A.      It was found in a room next to the massage room.
19       Q.      And to be clear, did the FBI find sex toys during
20   the search?
21        A.     Yes.
22       Q.      What was found?
23        A.     Butt plugs, dildo, vibrators.
24       Q.      We've talked about three minor girls today,
25         and             is that right?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000195
EFTA00008695
06/29/20   66
A.    Yes.
2        Q.    Have you reviewed the proposed indictment, marked
3   Grand Jury Exhibit 1?
4        A.    Yes, I have.
5        Q.    Is        the individual referred to as Victim 1 in
6    the proposed indictment?
7        A.    Yes.
8         Q.    Is        the individual referred to as Victim 2 in
9    the proposed indictment?
10        A.    Yes.
11        Q.    Is           the individual referred to as Victim 3
12   in the indictment?
13        A.    Yes.
14        Q.    During all of Maxwell's interactions with the
15   victims when they were underage girls, based on the
16   timeframe and your knowledge of Maxwell's birth date, was
17   she in her 30s?
18        A.    Yes, she was.
19        Q.    Just one moment.    All right.    Switching gears.
20   Have you become aware that in or about 2016 Maxwell gave
21   sworn testimony in a civil deposition in connection with a
22   lawsuit?
23        A.    Yes.
24        Q.    Could you please explain for the grand jury what
25   is a deposition?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000196
EFTA00008696
06/29/20    67
A.    It is a statement made under oath.
2       Q.    And in the course of civil litigation is it common
3   for witnesses or the parties of the lawsuit to give a
4   deposition under oath where they testify about the substance
5   of the case?
6        A.    Yes.
7       Q.    And is deposition testimony live and in person and
8    under oath?
9         A.   Yes.
10       Q.    Is a court reporter present when a deposition
11   takes place?
12        A.   Yes.
13       Q.    Now before we talk about Maxwell's deposition
14   testimony, I want to talk with you about the lawsuit that
15   the testimony was about.       Have you become aware that in or
16   about 2015 an individual named                          filed a
17   lawsuit against Ghislaine Maxwell here in the Southern
18   District of New York?
19        A.   Yes.
20       Q.    And was             suing Maxwell for defamation?
21        A.   Yes, she was.
22       Q.    Was the lawsuit captioned                            against
23   Ghislaine Maxwell with Docket Number 15-CV-7433 here in the
24   Southern District of New York?
25       A.    Yes.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000197
EFTA00008697
06/29/20   68
Q.   Generally speaking, in broad strokes, what was the
2    lawsuit about?   What was the claim that                was bringing
3   against Maxwell?
4        A.            had stated that she had been sexually
5    abused by Epstein and Maxwell as a minor.          Maxwell came
6    forward publically and called her a liar.          So
7   her for defamation.
8              MS.          So just a small legal instruction on
9    this topic.   Ladies and gentleman, I instruct you that the
10   allegations in the lawsuit are not being presented to you as
11   evidence that those incidents occurred.       I instruct you that
12   you should not consider those allegations for their truth;
13   instead, the circumstances of the lawsuit are being
14   presented to you so that you can consider the context of the
15   case and the circumstances under which Maxwell made
16   statements under oath.
17   BY MS.
18        Q.   Turning back to the deposition.          Did Maxwell's
19   deposition take place over two different days?
20        A.   Yes.
21        Q.   On both days did she give testimony in Manhattan?
22        A.   Yes, she did.
23        Q.   Is that where the deposition took place?
24        A.   Yes.
25        Q.   And on both days was Maxwell sworn under oath?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000198
EFTA00008698
06/29/20
A.    Yes.
2       Q.    If you could flip through the remaining slides in
3   the presentation.     Do those slides contain true and accurate
4   excerpts of the transcript of that deposition?
3       A.    Yes.
6         Q.   Turning to the next slide, is this the cover page
7   of the transcript of the first deposition that took place on
8    April 22, 2016?
9         A.   Yes.
10       Q.    And does it have the case caption on it?
11        A.   Yes, it does.
12       Q.    Turning to the next slide, is this an excerpt from
13   the transcript?
14        A.   Yes.
15        Q.   I imagine the grand juries can't read it from
16   their seats so if you could read it with me, I'll read the
17   questions and if you could read the answers.
18             Question: "Did Jeffrey Epstein have a scheme to
19   recruit underage girls for underage massages?"
20             And it appears there was an objection from the
21   lawyer.
22             Question: "If you know."
23       A.    Answer: "I don't know what you are talking about."
24       Q.    Just to be clear with the question and answer, is
25   the answer here Maxwell's testimony?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000199
EFTA00008699
06/29/20   70
A.   Yes.
2          Q.   Just to be clear, you testified earlier that
3   participated in sexualized massages with Epstein and
4   Maxwell; is that right?
5          A.   Yes.
6           Q.   And       was a minor when that occurred?
7          A.   Yes.
8           Q.   And did you also testify earlier that Maxwell --
9    that                         told you that Maxwell asked her to
10   give Epstein massages when she was a minor?
11          A.   Yes.
12          Q.   If you could turn to the next slide, please.
13   this another excerpt from that same deposition?
14          A.   Yes, it is.
15          Q.   All right.    I'll read the question and you can
16   read the answer.
17               Question: "List all the people under the age of 18
18   that you've interacted with at any of Jeffrey Epstein's
19   properties?"
20          A.   Maxwell's answer: "I'm not aware of anybody that I
21   interacted with, other than obviously                   who was 1.7
22   at this point."
23          Q.   Just to be clear, you testified earlier about two
24   girls under the age of 18 who interacted with Maxwell at
25   Epstein's properties; is that correct?
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000200
EFTA00008700
06/29/20    11
A.    Yes.
2       Q.    And those individuals were                      and
3                    who told you that, correct?
4       A.    Yes, that's correct.
5       Q.    Turning to the next slide, is this the cover page
6    of the transcript from the deposition that took place on
7   July 22, 2016?
8       A.    Yes.
9       Q.    And again, was this Maxwell giving testimony as
10   part of the testimony under oath here in Manhattan?
11        A.   Yes.
12       Q.    If you could please turn to the next slide.            Is
13   that an excerpt -- are these two excerpts from that
14   deposition?
15       A.    Yes.
16       Q.    Again, I'll read the questions if you could please
17   read the answers.
18             Question: "Were you aware of the presence of sex
19   toys or devices used in sexual activities in Mr. Epstein's
20   Palm Beach house?"
21             There's an objection from the lawyer.
22       A.    Maxwell's answer: "No, not that I recall."
23       Q.    "Do you know whether Mr. Epstein possessed sex
24   toys or devices used in sexual activities?"
25             There's an objection from the lawyer.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GNLGUDNYJX000201
EFTA00008701
06/29/20    72
A.    Maxwell's answer: "No."
2        Q.    Just to be clear, you testified earlier that
3                 told you he found sex toys in the massage room
4   in Palm Beach and also that he had seen that Maxwell had a
5   basket of sex toys in her closet there; is that correct?
6         A.    Yes, that's correct.
7        Q.    And is it correct that you testified earlier that
8    Epstein had used a vibrator on                       is that
9    correct?
10        A.    Yes, that's correct.
11        Q.    And did you also testify earlier that
12                         told you he did that, as well?
13        A.    Yes, that's correct.
14        Q.    And did you also testify earlier that sex toys
15   were found by the police in the Palm Beach house in 2005; is
16   that right?
17        A.    Yes.
18        Q.    And did you also testify earlier that the FBI
19   found sex toys in Epstein's New York City townhouse in 2019?
20        A.    Yes, that's correct.
21        Q.    If you could please turn to the next slide.          This
22   is on page 27.    Is this -- are these also excerpts from that
23   same deposition?
24        A.    Yes.
25        Q•    Again, I'll read the questions if you could please
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000202
EFTA00008702
06/29/20    73
read the answers.
2               Questions: "Other than yourself, and the blonde
3   and brunette that you have identified as having been
4   involved in three-way sexual activities, with whom did
5   Mr. Epstein have sexual activities?"
6                There's an objection from the lawyer.
7       A.      Maxwell's answer: "I wasn't aware that he was
8    having sexual activities with anyone when I was with him
9    other than myself."
10       Q.      Question: "I want to be sure that I'm clear, is i-
11   your testimony that in the 1990s and 2000s you were not
12   aware that Mr. Epstein was having sexual activities with
13   anyone other than yourself and the blonde and brunette on
14   those few occasions when they were involved with you?"
15       A.      Maxwell's answer: "That is my testimony.           That is
16   correct."
17       Q.      Have you reviewed the deposition transcript --
18        A.     Yes.
19       Q.      -- in full?     Now, the excerpt we just read has a
20   reference to a blonde and brunette.       Are those individuals
21   completely different from the individuals we've been talking
22   about today?
23       A.      Yes.
24       Q.      Just to be clear, is it correct that you testified
25   earlier that          and           told you that Epstein
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GNLGUDNYJX0000203
EFTA00008703
06/29/20   14
sexually abused them repeatedly; is that correct?
2        A.     Yes.
3        Q.     And did you also testify earlier that Maxwell was
4   occasionally present when Epstein was abusing                 based
5   on what she told you?
6         A.     Yes, that's correct.
7        Q.     Turning to the next slide, is this also an excerpt
8    from the same deposition?
9         A.     I'm sorry?
10        Q.     I'm so sorry.   Turning to the next slide, on page
11   28, is this also an excerpt from the same deposition?
12        A.     Yes.
13        Q.     Thank you.   Okay.   Again, if we could read that
14   together I'll take the question if you could take the
15   answer.
16               Question: "Let's just tie that down.        Is it your
17   testimony that you've never given anybody a massage?"
18        A.     Maxwell's answer: "I have not given anyone a
19   massage."
20        Q.     "You never gave Mr. Epstein a massage; is that
21   your testimony?"
22        A.     Maxwell's answer: "That is my testimony."
23        Q.     "You never gave                 a massage; is that
24   your testimony?"
25        A.     Maxwell's answer: "I never gave
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000204
EFTA00008704
06/29/20   75
1    massage."
2         Q.     Just to be clear, as you testified earlier, is it
3   correct that                  told you that Maxwell gave her a
4   massage when they were in New Mexico?
5         A.     Yes.
6         Q.     Have you told the grand jury everything that you
7   know about this case or have you just answered the questions
8    that I've asked?
9         A.     I've just answered the questions you've asked.
10        Q.     And when you testified about the documents that
11   you reviewed or the conversations that you had with others,
12   were you testifying to the exact words used or just the
13   substance of the documents or conversations?
14        A.     The substance?
15        Q.     And are you willing to return to the grand jury if
16   the grand jury has any further questions for you?
17        A.     Yes.
18               MS.           With the Foreperson's permission I'd
19   ask that the witness be excused at this time.
20               FOREPERSON.     You're excused.
21               MS.        Thank you.
22               (Witness Excused)
23               (Time Noted:    11:41 a.m.)
24               (Colloquy Follows)
25
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000205
EFTA00008705
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDNY_00000206
EFTA00008706
1                       CERTIFICATE
2
3            I hereby certify that the foregoing is a true and
4    accurate transcription, to the best of my skill and ability,
5    from my electronic notes of this proceeding.
6
7    July 6, 2020
Date
8                                 Acting Grand Jury Reporter
Free State Reporting, Inc.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area [Phone Redacted]
Balt. & Annap. [Phone Redacted]
GM_GLSDN Y_00000207
EFTA00008707
Extracted Images (77) #

People (2) #

Extracted Text #

Extracted Images (77) #

People (2) #

Extracted Text #

Report Image
