EFTA00008744 - Dataset 6

Extracted Text #

2
3   UNITED STATES GRAND JURY
4   SOUTHERN DISTRICT OF NEW YORK
5                                       -x
UNITED STATES OF AMERICA
6
-V-                        : January 19, 2021 Additional
7
GHISLAINE MAXWELL
8    (2018R01618)
x
9
10                                           United States Courthouse
Foley Square
11                                           New York, New York
12                                           March 29, 2021
10:05 a.m.
13
14   APPEARANCE             S:
15
States Attorney
16
17                                                       d States Attorney
18
19
20
21
22
23
M        inury          Reporter
24
25
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1             (Colloquy Precedes)
2             (Witness Enters Room)
3             (Time Noted:    10:14 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.    Good morning.
10       Q.    Would you please state your name for the record?
11        A.   Detective
12       Q.    Detective          where do you work?
13        A.   New York City Police Department.
14       Q.    I'm going to ask you to please keep your voice up,
15   and speak as slowly as you can.
16             UNIDENTIFIED SPEAKER.
17   BY MS.
18       Q.    And you can pull the microphone toward you so that
19   everyone in this big room can hear you.     Thank you.    Where
20   do you work?
21       A.    New York City Police Department.
22       Q.    What is your title there?
23       A.    Detective.
24       Q.    How long have you been with the NYPD?
25       A.    About 15 years.
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1        Q.    Are you currently part of a federal task force?
A.    Yes.
3        Q.    What task force?
4        A.    The Child Exploitation and Human Trafficking Task
5    Force with the FBI.
6         Q.    What is your title on the task force?
7        A.    Task force officer.
8         Q.    How long have you been a task force officer with
9    the FBI?
10        A.    Since about 2017.
11        Q.    Generally, what are your duties and
12   responsibilities on the task force?
13        A.    We address cases of child sex-trafficking, adult
14   sex-trafficking, child pornography, and child enticement.
15        Q.    Over the last, approximately, three years have you
16   been involved in an investigation into Jeffrey Epstein and
17   his associates, including an individual named
18   Ghislaine Maxwell?
19        A.    Yes.
20        Q.    During your investigation have you spoken with
21   other people, including other law enforcement officers?
22        A.    Yes.
23        Q•    Have you reviewed reports and documents prepared
24   by others, and transcripts of testimony in other court and
25   grand jury proceedings?
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1          A.   Yes.
2          Q.   Will your testimony today be based in part on
3   those conversations and documents that you have reviewed?
4          A.   Yes.
5                MS.          Ladies and gentlemen, some of the
6    testimony you are going to hear from Detective              will
7   include hearsay.   That means he is not going to testify only
8    from his own personal observations, he will also be
9    testifying about what other people have told him and what he
10   has read in documents.
11               Hearsay evidence, as you know, is admissible and
12   proper in these proceedings, and you are permitted to rely
13   on it in determining whether there is probable cause to
14   indict the defendant, but if you want to hear testimony from
15   other witnesses, or see particular documents, please let me
16   know, and I will make my best efforts to bring those before
17   you.
18   BY MS.
19          Q.   Detective         over the course of your
20   investigation has another member of the FBI task force
21   you're a part of testified before a different grand jury
22   about the facts of this case?
23          A.   Yes.
24          Q.   I'd like to ask you to please pick up what should
25   be in front of you and marked as Grand Jury Exhibit 3.        Do
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1   you recognize that?
9         A.   Yes.
3        Q.   Is this document a fair and accurate transcript of
4   testimony given by FBI Special Agent                      before a
5    different grand jury, on June 29, 2020?
6         A.   Yes.
7         Q.   I'd like to read back a portion of this
8    transcript.   We will start at Page 2, Line 18.        I will read
9   the questions, you read the answers.
10        Q.   "Where do you currently work?"
11        A.   "The Federal Bureau of Investigation."
12        Q.   "What is your title?"
13        A.   "Special agent."
14        Q.   "How long have you worked as a special agent?"
15        A.   "About three years now."
16        Q.   "Where are you currently assigned?"
17        A.   "I work on the Violent Crimes Against Children's
18   Squad."
19        Q.   "What are your duties and responsibilities as -
20   special agent on that squad?"
21        A.   "We investigate crimes that have to do with child
22   sexual abuse material, sextortion, exploitation, and
23   enticement of minors, sex-trafficking."
24             MS.            You can stop there.       I'll now jump to
25   Page 4, line 13.
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1   BY MS.
2        Q.     "Have you participated in an investigation of
3    Ghislaine Maxwell?"
4        A.     "Yes, I have."
5         Q.     "Have you spoken to other people, including other
6    law enforcement officers about this investigation?"
7         A.     "Yes."
8        Q.     "Have you reviewed reports and documents prepared
9   by others regarding this case?"
10        A.     "Yes."
11        Q.     "Is your testimony today based in part on those
12   conversations with other law enforcement officers and
13   documents that you have reviewed?"
14        A.     "Yes."
15               MS.            Stepping out of the read back.     At
16   this point the AUSA provided the same hearsay instruction to
17   the grand jury, at that time, as I just provided to you all.
18   So that instruction applies with respect to
19                             testimony the same way it applies to
20   Detective             testimony.
21               We can now go down to Page 5, line 17.
22   BY MS.
23        Q.                               we've placed on the desk in
24   front of you a PowerPoint that is Grand Jury Exhibit 2 which
25   we're entering into the record.        Do you recognize this?"
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1        A.    "Yes."
2       Q.     "What is it?"
3        A.    "It's a PowerPoint presentation to assist in
4   testifying today."
5        Q.     "Did you participate in preparing this Exhibit in
6    connection with your testimony today?"
7        A.    "Yes, I did."
8        Q.     "If you could please turn to the first slide.       Who
9    are the individuals depicted in these photographs?"
10        A.    "The picture on the left is Ghislaine Maxwell, and
11   the picture on the right is Jeffrey Epstein with
12   Ghislaine Maxwell."
13       Q.     "Based on your participation in this investigation
14   and your review of public source materials, have Maxwell and
15   Epstein been photographed together many times over the
16   years?"
17        A.    "Yes."
18       Q.     "Based on your participation in this investigation
19   and your review of public materials, where is Maxwell from?"
20        A.    "Maxwell was born in France, she grew up in United
21   Kingdom, was educated in Oxford and is from a wealthy
22   family."
23       Q.     "Is she a citizen of France, the United Kingdom,
24   and the United States?"
25        A.    "Yes."
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1       Q.    "How old is she currently?"
2       A.    "Fifty-eight."
3       Q.    "Has the FBI investigated Maxwell and Epstein':
4   conduct with minors during the 1990s?"
5        A.    "Yes."
6        Q.    "Generally speaking, what have you learned about
7   the relationship between Maxwell and Epstein during the
8    1990s?"
9        A.    "Epstein and Maxwell had a romantic relationship,
10   and she also worked for him; managing his homes, hiring and
11   firing individuals."
12       Q.    "During that time period, was she one of his
13   closest associates?"
14       A.    "Yes."
15       Q.    "During the course of this investigation have you
16   learned where Epstein maintained properties in the 1990s?"
17       A.    "Yes."
18       Q.    "Where did he maintain properties?"
19       A.    "New York, Palm Beach, and New Mexico."
20       Q.    "Turning to the next slide, did he maintain an
21   address in Manhattan located at 9 East 71st Street?"
22       A.    "Yes."
23       Q.    "Does this slide fairly and accurately depict that
24   residence?"
25       A.    "Yes."
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1        4•      "Can you please describe that property for the
2    grand jury?"
3       A.      "It's a seven-story home.       It's located near
4   Central Park.    It's reportedly the largest residence in
5    Manhattan."
6        Q.      "Based on your participation in this
7   investigation, did that house include a room that was used
8    as a massage room?"
9         A.     "Yes, it did."
10       Q.      "All right.    We'll talk more about that later but
11   for now, moving on to the other properties.          Did he maintain
12   an address in Palm Beach, Florida, located at
13   358 El Brillo Way?"
14       A.      "Yes."
15       Q.      "Turning to the next slide.       Does this slide
16   fairly and accurately depict the residence?"
17        A.     "Yes, it does."
18       Q.      "Could you please describe that property for the
19   grand jury?"
20       A.      "It's a water-front estate.       It has an in-ground
21   pool and a detached dwelling, or pool house, on the property
22   as well."
23       Q.      "Aside -- and from your participation in this
24   investigation and your review of other materials, did that
25   house include a room that was used as a massage room?"
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1        A.   "Yes."
2       Q.    "Turning to the next property.       Did Epstein also
3   own a ranch in New Mexico?"
4       A.    "Yes, he did."
5        Q.    "And turning to the next slide, was that a
6    property located at 49 Zorro Ranch Road in Stanley,
7   New Mexico?"
8         A.   "Yes."
9        4.    "Looking at the photograph on this slide does this
10   accurately depict that property?"
11        A.   "Yes, it does."
12       Q.    "And we've been talking about the properties that
13   Epstein owned during this time period.       Did he also own a
14   private jet?"
15       A.    "Yes."
16       4•    "Is it fair to say that he was a multi-millionaire
17   during this time period?
18       A.    "Yes."
19       Q.    "During the 1990s did Epstein have an employee,
20   ■              who ran his house in Palm Beach?"
21        A.   "Yes, he did."
22       Q.    "What was his job?"
23        A.   "His job was making sure that everything in the
24   house ran smoothly.    He referred -- he described that
25   Epstein liked to have his house run like a five-star hotel;
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1    that everything had to be in its proper place.           So he was
2    responsible for managing that."
3       Q.      "Have you interviewed
4        A.     "Yes."
5        Q.      "How many times?"
6         A.     "Twice."
7       Q.      "And is the information you're about to provide
8    based on your interviews with
9        A.      "Yes."
10       Q.      "Did          begin working for Epstein in the early
11   1990s?"
12       A.      "Yes, he did."
13       Q.      "At the time           came to work for Epstein in
14   Palm Beach, was Epstein dating Ghislaine Maxwell at that
15   point?"
16       A.      "Not at that time."
17        4•     "Was it a few years before Epstein began dating
18   Maxwell after            started working there?"
19       A.      "Yes."
20               MS.            I'm going to step out of the read
21   back.     It sounds like the grand jurors are having difficulty
22   hearing.    Are you having difficulty hearing me, the witness,
23   or both?
24                GRAND JURORS.     The witness.
25               MS.            So Detective              I'm going to ask
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1    you to please keep your voice up.        Try to shout into the
2    microphone.      Can you pull the microphone toward you?       Lift
3   it and pull it all the way up to you?         Thank you.     We left
4   off reading at Page 10, line 12.
5    BY MS.
6        Q.     "From what                  told you, how did
7   work change once Maxwell arrived on the scene?"
8        A.     ''I'll' described Epstein as being of more
9    pleasant to work with prior to Maxwell coming into the
10   picture.   Once she came into the picture, he said things
11   became more secretive.        He wasn't allowed to be in the room
12   with guests, wasn't allowed to talk with them, associate
13   with them; it became a different environment."
14              MS.             Detective           I'm going to ask you
15   to take the microphone and try to put it right under where
16   your mouth would be when you're reading because as you're
17   looking down, you're moving your mouth away from the
18   microphone.      Thank you.   Picking back up at Page 10,
19   line 20.
20   BY MS.
21        Q.    "You talked about some of the rules that were
22   placed, changing.      Were there any rule changes about eye
23   contact once Maxwell began staying at the Palm Beach house?"
24       A.     "Yes.              wasn't allowed to make eye contact
25   with Epstein and others."
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1                  MS.            We're going to jump now to Page 11,
2    Line 6.
3   BY MS.
4          Q.     "Shifting gears.     I want to talk to you about
5    someone else that you've interviewed during this
6    investigation.        During the course of this investigation,
7   have you participated in interviews with an individual named
8
9           A.     "Yes."
10          Q.     "So for these purposes, I'm just going to refer t
11   her as         .    Is that okay?"
12          A.     "Yes."
13          Q.     "How many times have you interviewed             ?"
14          A.     "Approximately five times."
15          Q.     "If you could please just page through the next
16   two slides in front of you?         Are these photographs of
17            II
18          A.     "Yes."
19          Q.     "Is it your understanding that these photographs
20   depict           from approximately ages 13 to approximately
21   17?"
22          A.     "Yes, it does."
23          4•     "Okay.    Let's take a look at some of those
24   photographs.        I'm going to publish the next slide.
25          's date of birth
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1        A.   "Yes."
2        Q.   "Are these two photographs of            ?"
3        A.   "Yes, they are."
4        Q.   "If you could turn to the second slide of
?It
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 years old?"
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        's father do before he passed away?
18   What was his profession?"
19        A.   "He was involved in
20                                     .'
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?"
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1        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 was in
7         .   So did she turn 14 in
8         A.   "Yes."
9         Q.   "What did she do that summer?"
10        A.   "She attended an arts camp at Interlochen Center
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 she found out that she was also from Palm Beach
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1    and that he said he gives scholarships to students."
2        Q.     "How did they leave the conversation?          Was there
3   any contact information exchanged?"
4       A.     "They asked for         's phone number."
5        Q.     "As part of your investigation have you attempted
6    to gather records to corroborate that               , Maxwell, and
7   Epstein were all at that summer camp that summer?"
8        A.     "Yes."
9        Q.     "If you could turn to the next slide, please.
10   Have you obtained records from Interlochen for the summer of
11   1994?"
12       A.     "Yes."
13       Q.     "And what are we looking at on this slide?"
14       A.     "This shows who -- some of the individuals that
15   were there, were present for that camp in '94.           On here is
If
16
17       Q.     "And have you investigated whether Maxwell and
18   Epstein were also at Interlochen that summer of 1994 as
19        described?"
20       A.     "Yes."
21       Q.     "Based on your review of records from Interlochen,
22   what is your understanding of Epstein's relationship with
23   Interlochen?"
24       A.     "My understanding was that he was a donor to the
25   school."
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1          Q.   "Did he make any substantial donations?"
2          A.   "He did."
3          Q.   "Did he donate a lodge to the camp in the summer
4   of 1994?"
5           A.   "Yes, he did."
6           Q.   "Did he have a long-standing relationship as a
7   donor to Interlochen?"
8           A.   "Yes."
9           Q.   "Turning to the next slide.       Is this an excerpt of
10   a letter from Interlochen to Epstein?"
11          A.   "Yes, it is."
12          Q.   "And does this letter thank Epstein for donating a
13   scholarship lodge?"
14          A.   "Yes."
15          Q.   "Does it invite Epstein to visit in August of
16   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 -iet?"
21          A.   "Yes."
22          Q.   "Do those logs include passenger lists and the
23   airport code for the airports the plane flew into and out
24   of?"
25          A.   "Yes."
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1       Q.     "Turning to the next slide.       Is this a page of the
2   flight logs that you 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 TBC?"
7       A.     "Yes."
8        Q.     "Is TBC the airport code for Cherry Capitol
9    Airport in Traverse City, Michigan?"
10        A.    "Yes, it is."
11       Q.     "About how far is that airport from Interlochen by
12   car?"
13        A.    "About 25 minutes, give or take."
14       Q.     "And who were the listed passengers on this
15   flight?"
16        A.    "Jeffrey Epstein,                    (ph), and
17                    (ph)."
18       Q.     "Turning to the next slide.       Is it the same
19   excerpt just with a different arrow?"
20       A.     "Yes."
21       Q.     "Okay.   So a few lines down is there a flight out
22   of Traverse City just two days later, on August 20, 1994?"
23       A.     "Yes."
24       Q.     "And do the passengers listed in the flight out of
25   Traverse City include the initials GM?"
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1        A.     "Yes, they do."
2        Q.     "Are those Ghislaine Maxwell's initials?"
3        A.     "Yes."
4        Q.     "Have you obtained any records from Interlochen to
5    indicate that Maxwell was at Interlochen in 1994?"
6         A.     "Yes."
7        Q.     "If we could turn to the next slide.       Can you
8    please explain for the grand jury what we're looking at on
9    this slide?"
10        A.     "This was a letter from Interlochen
11   explaining -- addressed to Maxwell -- telling her that they
12   had found an envelope in the lodge that they had been
13   staying."
14        Q.     "All right.      We were talking a few minutes ago
15   about how         described meeting Maxwell and Epstein at
16   summer camp and you testified that she provided them with
17   her phone number.      Did        explain to you whether or not
18   she had any contact with Epstein or Maxwell after she
19   returned home to Palm Beach?"
20        A.     "Yes."
21        Q.     "When was the next time that happened?"
22        A.     "Shortly thereafter."
23        Q.     "And how did that occur?"
24        A.     "She was invited to his house, so her and her
25   mother went to Epstein's house to visit."
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1        Q.   "What did            tell you about that visit to
2    Epstein's house with her mother?"
3        A.   "She said it was -- wait, can you rephrase that?"
4        Q.   "Of course.    Did           go to the house by
5    herself or with her mother?"
6         A.   "With her mother."
7        Q.   "Okay.     When they went to the house what did they
8    do there?"
9         A.   "They had tea."
10        Q.   "Who was there when they had tea at the house?"
11        A.   "Epstein and Maxwell."
12        Q.   "What did they discuss as they had tea?"
13        A.   "They just talked about her life and, you know,
14   what she wanted to do."
15        Q.   "Did Epstein make any offers?"
16        A.   "He said that he gives scholarships; he likes to
17   mentor people."
18        Q.   "How did           's mother react when Epstein said
19   this?"
20        A.   "She was happy for her daughter and often times
21   referred to Epstein as         's godfather."
22        Q.   "After that occasion when they went over to the
23   house, thereafter, did             subsequently begin regularly
24   spending time with Maxwell and Epstein at Epstein's house in
25   Palm Beach?"
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1          A.   "Yes."
2          Q.   "Did that start when she was approximately age
3   14?"
4          A.   "Yes."
5           4•   "Did it continue until she was about age 17?"
6           A.   "Yes, it did."
7          Q.   "And during those years does she regularly go over
8    to Epstein's house in Palm Beach and spend time with Maxwell
9    and Epstein?"
10          A.   "Yes."
11          Q.   "What happened in the summer of 1997 when
12   was 17, about to turn 18?"
13          A.   "She moved to New York City."
14          Q.   "Why did she move to New York City?"
15          A.   "She wanted to pursue a career in acting and
16   modeling."
17          Q.   "We'll talk about that in a moment, but for now, I
18   want to focus on the years you talked about, in Palm Beach,
19   from the ages 14 to 17, when             would regularly go to
20   Epstein's house.     In the beginning, in the first few months
21   when she went there, what kinds of things did she do when
22   she would visit the house when Maxwell and Epstein were
23   there?"
24          A.   "They'd hang out by the pool.       He -- they would
25   take her to the movies, take her shopping.           She described
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1    that behavior as grooming."
2        Q.    "When you say grooming, did she explain what she
3   meant by that?"
4       A.    "She meant that they were building a relationship
5    with her, giving her things, taking her places, and then
6    usually when the grooming happens, an offender will -- once
7   they gain that trust -- they will make their relationship
8    turn sexual."
9        Q.    "Now you testified just a moment ago that
10   described to you that she felt at this time period they were
11   grooming her, is that right?"
12       A.    "Yes."
13        Q.   "Is that something that she realized at the time
14   when she was 14, or is that something she's described to you
15   now?"
16       A.    "Something she's described now.          She didn't
17   realize that at the time."
18       Q.    "So we'll talk a little bit more about grooming in
19   a moment, but just to give context, are you familiar with
20   the term grooming based on your experience investigating
21   crimes involving sexual exploitation of minors?"
22       A.    "Yes."
23       Q.    "Generally speaking, you were touching on this a
24   moment ago, but if you could just explain it in full, what
25   is grooming?"
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A.   "Grooming is when someone builds a relationship
2    with a child.   They will find a vulnerability or a need and
3   then they work on gaining that child's trust.       And then
4   often times gaining a parent's trust.       Once they have that
5    trust, they show that in ways that they can care about them;
6    like giving them gifts and promises.       And then once that's
7   established, they then turn the relationship sexual; often
8    times, making sexual comments and normalizing the behavior."
9          Q.   "Now during these visits that you've been
10   describing, that         told you about, did             say whether
11   Epstein ever gave her anything?"
12         A.   "Yes, she did."
13         Q.   "What did he give her?"
14         A.   "He gave her cash.    Sometimes he'd tell her to
15   give the cash to her mom because he knew that they needed
16   it.   He paid for her voice lessons as well."
17         Q.   "Now you were describing how            has
18   characterized these visits now, but based on your
19   conversations with her, at the time did she feel that these
20   visits were strange at all?"
21         A.   "She thought they were strange, but Maxwell
22   normalized it for her.    She was like a cool, older sister
23   and made comments like, this is what grownups do."
24         Q.   "You used the phrase cool, older sister.         Is that
25   a phrase that         used to describe how she felt about
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1    Maxwell at the time, and what Maxwell was like?"
2         A.    "Yes.    Those are her words."
3         Q.    "Did there come a time -- these visits --
4              saw Maxwell topless by the pool?"
5          A.    "Yes."
6          Q.    "What did she tell you about that?"
7         A.    "She was a little taken back, but Maxwell just
8    acted normal."
9          Q.    "Did         tell you about an incident several
10   months into this arrangement when she was alone with Epstein
11   in the pool house?"
12         A.    "Yes."
13         Q.    "And when they were alone together, did Epstein
14   ask          what she wanted to do with her life?"
15         A.    "He did."
16         Q.    "What did she say?"
17         A.    "She said she wanted to be an actress and n
18   model."
19         Q.    "How did Epstein respond?"
20         A.    "He told her that he was best friends with the
21   owner of Victoria's Secret.       Told her that she would have to
22   have photographs taken and that she had to be comfortable in
23   her underwear and not be a prude.        When she was asked what
24   she meant by that, he pulled her into his lap and
25   masturbated."
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1          Q•    "What was her reaction?"
2          A.    "She felt paralyzed.      She froze."
3          Q.    "After this incident did             's encounters with
4   Epstein begin to include sexual contact?"
5           A.    "Yes."
6           Q.    "Over time did the sexual abuse escalate?"
7          A.    "It did."
8           Q.    "From what she's described to you, did the abuse
9    include Epstein digitally penetrating
10          A.    "Yes."
11          Q.    "Did it include Epstein using a vibrator on her?"
12          A.    "Yes."
13          Q.    "Did she describe to you that there were times
14   when Epstein would direct              to massage him while he
15   masturbated?"
16          A.    "Yes."
17          Q.    "Did         explain to you what her memories are
18   like of the abuse?"
19          A.    "Yes."
20          Q.    "What did she say about that?"
21          A.    "She said that it happened so often that it al
22   kind        it all runs together for her.      That it's hard to
23   separate out some of the different instances of abuse."
24          Q.    "You were describing how            explained to you
25   that the abuse began.       Did that occur, based on what
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1    told you, within the first year that she met Epstein and
2    Maxwell?"
3          A.   "Yes."
4          Q.   "Now did          also describe to you that once this
5    abuse started Epstein would also bring her into his massage
6    room in his house?"
7          A.   "Yes."
8           Q.   "And were there times, where he did this, where
9    there were other women present, including Maxwell?"
10          A.   "Yes."
11          Q.   "Was         abused during those episodes?"
12          A.   "Yes, she was."
13          Q.   "During these group encounters what were              and
14   the adult women wearing?"
15          A.   "They were usually just in their underwear."
16          Q.   "Once they were all in the massage room, how would
17   these episodes generally start?"
18          A.   "They would generally start with one of the girls
19   massaging Epstein.             was usually massaging his feet.
20   Maxwell was kind of teasing the other girls.         She'd grab the
21   girl's breasts, and she would direct the girls on what to
22   do."
23          Q.   "When these episodes would start, in general, was
24   Epstein generally lying face down on the massage table?"
25          A.   "Yes."
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1         Q.   "What would happen as things progressed, generally
2    speaking, from what she described to you?"
3        A.   "When Epstein would decide he was kind of done
4   with the regular massage, he would turn over on his back,
5    and he'd grab whichever girl he wanted to, either, touch him
6    or whatever girl he wanted to touch."
7        Q.   "Did these episodes include sex acts that over
8    time, in various instances, included Epstein masturbating,
9    Epstein receiving oral sex, and Epstein engaging in
10   intercourse?"
11        A.   "Yes."
12        Q.   "You were describing for a moment what            tos,
13   you about Maxwell's role during these group encounters.
14   Would Maxwell sometimes guide the women and give
15   instructions about what to do?"
16        A.   "Yes, she would."
17        Q.   "What would            typically do during these
18   episodes?"
19        A.   "She would try not to look at Maxwell because she
20   gave off that sister-vibe, so it felt weird for her.       She
21   would try to be invisible in the room so they would ignore
22   her as much as possible."
23        Q.   "In the beginning, when             's approximately 16
24   or 15, would she generally begin by just massaging Epstein's
25   feet?"
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1        A.   "Yes."
2       Q.    "Is that something she was told to do?"
3        A.   "Yes."
4       Q.    "Did she -- you mentioned that she tried to be
5    invisible -- was -- I believe that was your testimony?"
6        A.    "Yes."
7       Q.    "And over time has she described to you that over
8    time she believed she became more involved in the sexual
9    activity which varied in each encounter?"
10       A.    "Yes."
11       Q.    "Were there times         let me rephrase that.   How
12   did -- you touched on this for a moment, but just to be
13   clear -- how did          describe Maxwell's attitude during
14   these incidents?"
15       A.    "It was very casual; she acted like this was
16   normal.   She gave off that vibe to her and yeah."
17       Q.    "Did that make her feel more comfortable with what
18   was happening?"
19       A.    "It did."
20       Q.    "Was          sometimes fully nude during these
21   episodes?"
22       A.    "Yes."
23       Q.    "And during these episodes did the abuse include
24   Epstein touching         's breasts?"
25       A.    "Yes."
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1         Q.   "Did it include directing            to touch Epstein's
2    genitals?"
3        A.   "Yes."
4        Q.   "Beginning when            's approximately 14, does
5    she begin to travel with Epstein and Maxwell to
6    New York City on occasion?"
7        A.   "Yes, she did."
8         Q.   "Was that to the property you testified about
9    earlier; the townhouse on the upper-east side?"
10        A.   "Yes."
11        Q.   "When         traveled to New York City, did she
12   stay in Epstein's townhouse in New York City?
13        A.   "Yes, she did."
14        Q.   "Did she recall that Maxwell and Epstein took her
15   shopping on one of her early trips to New York City?"
16        A.   "Yes."
17        Q.   "Did she remember them buying her anything?"
18        A.   "She recalled them buying her white cotton
19   underwear.   Her description was that they were like little
20   girl's underwear."
21        Q.   "From ages 14 to 17 did Epstein ask              to
22   periodically fly to New York for weekends at that townhouse
23   in New York?"
24        A.   "I'm sorry, say it again?"
25        Q.   "You testified that she began travelling to
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1   New York City at age 14.     Did she then periodically travel
2   to New York City, in a similar manner, from ages 14 to 17?"
3        A.   "Yes."
4       Q.    "Were there times, when she travelled on those
5    trips, when she flew on Epstein's private jet?"
6         A.   "Yes."
7       Q.    "Did she also sometimes fly commercially?"
8        A.    "Yes, she did."
9        Q.    "Was Maxwell sometimes present on the trips to New
10   York?"
11       A.    "Yes."
12       Q.    "You testified earlier that              was sexually
13   abused in Palm Beach.    Did she describe to you that she was
14   also sexually abused on these trips to New York?"
15       A.    "Yes, she did."
16       Q.    "Did Maxwell encourage            to go on these
17   trips?"
18       A.    "Yes."
19       Q.    "What does          -- what did          tell you about
20   her memory of how these trips were arranged?"
21       A.    "She recalled that Maxwell was usually the one
22   that would schedule her flights.      If she was flying
23   commercially she would schedule the flights, sometimes
24   calling her mother to schedule."
25       Q.    "Was that the general impression of how they were
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1    arranged?"
2        A.   "Yes."
3        Q.   "In addition to the trips to New York City you
4   just described, did          also remember travelling, at least
5    once, to Epstein's ranch in New Mexico?"
6         A.   "Yes, she did."
7        Q.   "Does she remember whether or not she was sexually
8    abused in New Mexico?"
9         A.   "She couldn't recall.      She couldn't remember."
10        Q.   "In general, how would            get to the airport in
11   Florida when she would fly on Epstein's jet; what did she
12   describe to you?"
13        A.   "Usually a driver; one of Epstein's drivers would
14   pick her up from her house and take her to the airport."
15        Q.   "Now you testified earlier that you reviewed
16   flight records for Epstein's private jet, is that correct?"
17        A.   "Yes."
18        Q.   "And have you reviewed records from the 1990s to
19   see if there -- whether there's a person named             listed
20   on the records?"
21        A.   "Yes."
22        Q.   "Turning to the next slide.       Is this an excerpt
23   from those records?"
24        A.   "Yes, it is."
25        Q.   "And does the red arrow point to         does the red
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1    arrow point to a November 11th, 1996 flight?"
2       A.      "Yes, it does."
3       Q.      "And does this say -- does this flight log reflect
4   that it was a flight from Palm Beach, Florida to Teterboro,
5    New Jersey?"
6        A.      "Yes."
7       Q.      "Is there a private airfield in Teterboro,
8    New Jersey?"
9        A.      "Yes, there is."
10       Q.      "What's it called?"
11       A.      "Teterboro Airport."
12        Q.     "Are the passengers listed on this entry JE?"
13        A.     "Yes."
14        Q.     "Are the -- do the entries also include
15             (ph) plus friend, Jeff Shamf's (ph), family,
16
17
■   (ph),
A.     "Yes."
(ph),          (ph), and          ?"
18        Q.     "Was           , based on your awareness of          's
19   date of birth and the date of this flight, was                   on
20   the date of this flight?"
21       A.      "Yes, she was."
22       Q.      "Turning to the next slide.       You testified earlier
23   about Teterboro Airport.       What are we looking at on this
24   slide?"
25       A.      "This is directions from Teterboro Airport to
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1    Epstein's residence here in Manhattan."
2          Q.    "So based on your review of this map, if someone
3   were to fly into Teterboro and travel to New York City,
4   would they -- would the most natural route be to travel to
5    Teterboro Airport and crossing into New York through
6    Manhattan?"
7         A.    "Yes."
8          Q.    "Turning to the next slide.       Is this also an
9    excerpt from the flight records that you've reviewed?"
10         A.    "Yes, it is."
11         Q.    "And does this show a May 9, 1997 flight from
12   Teterboro, New Jersey to Santa Fe, New Mexico?"
13         A.    "Yes, it does."
14         Q.    "And are the passengers listed on this log JE, GM,
? II
15   and
16         A.    "Yes."
17         Q.    "Based on your knowledge of              's birthdate and
18   the date of this flight, would                have been 16 on the
19   date of this flight?"
20         A.    "Yes, she would have been."
21         Q.    "Turning to the next flight -- slide.          Is this
22   also an excerpt from the flight records?"
23         A.    "Yes."
24         Q.    "And does the red arrow point to a flight entry on
25   May 3, 1998?"
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A.     "Yes, it does."
Q.     "Based on the airport codes, did this reflect that
3   there is a flight on that date from Palm Beach, Florida to
4    Teterboro, New Jersey?"
5          A.     "Yes."
6          Q.     "And are the passengers listed on this log JE, GM,
7    ET,          , Glenn (ph),                (ph),            (ph), Manny
8    (ph),                     (ph)?"
9           A.   "Yes."
10         Q.     "Based on your knowledge of              's birthday and
11   the date of this flight, would                 have been 17 on this
12   date?"
13           A.   "Yes."
14         Q.     "Am I correct that you testified earlier that in
15   addition to sometimes flying on Epstein's private jet, she
16   also travelled on commercial airlines, is that right?"
17         A.     "Yes, it is."
18         Q.     "Based on your review of these flight logs, does
19   every flight entry list the name of every single passenger;
20   or are there sometime when a passenger is noted female?"
21         A.     "There's times where a passenger is just noted
22   female."
23         Q.     "I'm going to walk -- talk to you about two
24   examples of that.       Turning ahead two slides.        Looking at
25   Slide 18, does this reflect a January 3rd, 1995 flight where
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1    the flight log says JE, two females?"
2       A.      "Yes, it does."
3       Q.      "And do the two entries below, also, just list
4   female next to the initials JE?"
5         A.     "Yes, they do."
6        Q.      "Turning to the next slide, Slide 19.       Is this
7   another example of an entry like that; focusing on the entry
8    on February 12, 1995?"
9        A.      "Yes."
10       Q.      "Does that entry also say, female?"
11       A.      "Yes, it does."
12       Q.      "Now, you testified that            sometimes flew on
13   commercial airlines and that arrangements for her travel
14   were made for her to fly commercially for these trips, is
15   that right?"
16        A.     "Yes."
17       Q.      "Have you been able to obtain commercial flight
18   records?"
19       A.      "We tried.    We were not able to obtain those
20   records."
21       Q.      "Why is that?"
22       A.      "Airlines do not keep records past a certain
23   year."
24       Q.      "Does         recall group sexualized massages
25   involving Epstein and Maxwell, in both the New York and
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1   Florida residences, during the time period we've been
2   talking about?"
3       A.    "Yes."
4       Q.    "You testified earlier about the time that Epstein
5    and Maxwell would spend together and the activities that
6    they were involved in.    During this time period did
7   have occasions to talk with Maxwell?"
8        A.    "She -- I'm sorry, can you ask the question
9    again?"
10       Q.    "During the beginning when she was 14, when she
11   began spending time with Epstein and Maxwell, and through
12   the years, did         often have conversations with Maxwell
13   about her life?"
14       A.    "Yes."
15       Q.    "Did they talk about that often?"
16       A.    "They did."
17       Q.    "Did Maxwell ask           about her family, her
18   classes, and other aspects of her life?"
19        A.   "Yes, she did."
20       Q.    "You testified earlier, just before she turned 18,
21         moved to New York City, is that right?"
22       A.    "Yes."
23       Q.    "Did she go to school there in New York City her
24   senior year?"
25       A.    "Yes, she did."
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1         Q.   "What school did she go to?"
2         A.   "She went to the
3         Q.   "What is the
4         A.   "They cater to individuals who want to pursue
5    careers in the arts."
6          Q.   "Have you reviewed records from the
VI
7
8          A.   "Yes."
9          Q.   "If you could turn to Slide 17.          Can you please
10   explain for the grand jury what we're looking at here?"
11         A.   "This is an excerpt from           's application to
12   the                                        On it is listed, who is
13   financially responsible for her, and that is
14   Jeffrey Epstein."
15         Q.   "From what          told you did Maxwell encourage
16           to accept Epstein's financial help?"
17         A.   "Yes."
18         Q.   "When          moved to New York City who was she
19   living with?"
20         A.   "She lived with her mother and her brother
21   in --                    apartment."
22         Q.   "Did Epstein help pay for her rent?"
23         A.   "He did."
24         Q.   "During that year, her senior year of high school,
25   when she was in New York City, did             remain in contact
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1    with Epstein?"
2          A.   "Yes."
3          Q•   "What was the nature of their contact like during
4   that time period?"
5           A.   "During this time he was still sexually abusing
6    her."
7          Q.   "Did that continue to occur at his townhouse in
8    Manhattan that year?"
9           A.   "Yes, it did."
10          Q.   "What happened at the end of her senior year of
11   high school?"
12          A.   "She moved to Los Angeles to pursue a career in
13   acting."
14          Q.   "Did she get a job as an actress when she turned
15   18?"
16          A.   "She did."
17          Q.   "Has         lived in Los Angeles and worked as an
18   actress on television ever since then?"
19          A.   "Yes."
20          Q.   "After she moved to Los Angeles, did she continue
21   being in touch with Epstein?"
22          A.   "For a short period of time."
23          Q.   "Did she ultimately break contact with him?'
24          A.   "Yes, she did."
25          Q.   "Is         currently pursuing a civil lawsuit
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1    against Maxwell and Epstein's estate?"
2        A.   "Yes."
3        Q.   "Have you talked with            about whether, when
4   she was a teenage girl and all of this was happening,
5    whether she told anyone that she was being sexually abused?"
6         A.   "Yes.    She said she didn't tell anyone.        She felt
7   like she couldn't.    She -- the -- nothing was talked about
8    outside of that room, so it made it so that she couldn't
9    talk about it.    And then she also -- her mother is Middle
10   Eastern, and her mother raised her that women are supposed
11   to do what they're told even if someone is beating you.
12             When she was 13 and her father passed, she, she
13   went to a guidance counselor at school to talk about it, and
14   her mother found out about it and smacked her.       She felt
15   like she couldn't talk to anyone about it."
16        Q.   "Did        's mother encourage her to accept
17   Epstein's financial assistance?"
18        A.   "Yes, she did."
19        Q.   "Have you become aware that in 2005 police
20   officers from the Palm Beach Police Department executed
21   search warrant at Epstein's house at the
22   El Brillo Way address in Palm Beach?"
23        A.   "Yes."
24        Q.   "Have you reviewed some of the materials seized
25   during the search?"
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1        A.   "Yes."
2        Q.   "Did they find massage tables and sex toys?"
3        A.   "Yes, they did."
4        Q.   "Did they find any photographs of
5         A.   "Yes."
6         Q.   "Was one of the photographs signed by
7        A.   "Yes, it was."
8         Q.   "Did it say,
9
10        A.   "Yes."
11        Q.   "During your interviews with             , did         tell
12   you how she felt about Epstein and Maxwell in the 90s when
13   she was a young girl?"
14        A.   "She did.    She expressed that she felt like they
15   loved her.   She felt they were her family; that they
16   supported her, and that they felt like -- she was made to
17   feel that she was needed to be grateful to them."
18        Q.   "Okay.    Did she tell you that she felt like they
19   were trying to help her?"
20        A.   "Yes."
21        Q.   "Have you talked with            about how she feels
22   about this now?"
23        A.   "Yes."
24        Q.   "What was        's demeanor like when she described
25   to you what Epstein and Maxwell had done to her?"
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1           A.   "She was upset.     She recognized that now.     It's
2    affected her life to a great degree.         She's struggled in
3   relationships with opening up to people and trusting people;
4   both personal and professional relationships."
5           Q.   "Did she tell you that she struggled to tell
6    anyone what had happened to her for most of her adulthood?"
7          A.   "Yes."
8           Q.   "When was the first time you interviewed
9           A.   "Last fall."
10          Q.   "Was that the first time she ever reported this to
11   law enforcement?"
12          A.   "Yes, it was."
13          Q.   "Now you testified earlier about your interviews
14   with                  who worked at Epstein's Palm Beach house.
15   Did he remember a girl named             coming to the house
16   during that time?"
17          A.   "Yes, he did."
18          Q.   "Did he recall         , Maxwell, and Epstein meeting
19   in the Palm Beach house together?"
20          A.   "Yes."
21          Q.   "What was his understanding of why
22   there?"
23          A.   "He thought that Epstein was helping her.        That's
24   what Epstein had told him, and              had told him that
25   Epstein was helping her."
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1          Q.   "Did he ever observe Epstein interacting with
2           physically?"
3          A.   "Yes."
4          Q.   "What did he see?"
5           A.   "He saw Epstein kiss          's cheek and pat her on
6    the bottom."
7          Q.   "Did he have any knowledge about what was
8    happening with Epstein or Maxwell when he wasn't present?"
9           A.   "He didn't."
10          Q.   "Did          ever recall picking up           from her
11   house?"
12          A.   "Yes."
13          Q.   "And when he would pick her up from her house,
14   would he then bring her back to the Palm Beach house?"
15          A.   "Yes."
16          Q.   "Did he remember who, in general, would tell him
17   to pick up           from her house?"
18          A.   "Maxwell would be the one to tell him to pick her
19   up."
20          Q.   "Did he recall ever driving              to the movies?"
21          A.   "Yes."
22          Q.   "What did he tell you about that?"
23          A.   "That would usually be Epstein, Maxwell, and
24          ; they would go to the movies, and it would usually be
25   late at night."
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1       Q.    "Did he tell you about what his memory was about
2    how old          was?"
3       A.    "He said she was young, and that he knew that
4   because he had picked her up from school, and that he knew
5    she was too young to drive."
6        Q.    "Switching gears.      I want to talk to you about a
7   different aspect of your interviews with                     Based
8    on what he told about his job duties, were there ever times
9    where he would have to clean Epstein's massage room?"
10       A.    "Yes."
11       Q.    "What did he tell you about that?"
12        A.   "He said that he found sex toys in the massage
13   room, and he had to wash them afterwards."
14       Q.    "Aside from those experiences, was he aware it
15   there were any sex toys in the house?"
16        A.   "Yes.    There was a basket of sex toys that were
17   kept in Maxwell's closet."
18       Q.    "Did           stop working for Epstein in
19   approximately 2002?"
20       A.    "Yes."
21       Q.    "Was he told that he was being replaced?"
22       A.    "Yes."
23       Q.    "And was he generally aware that the person who
24   replaced him was much younger?"
25       A.    "Yes."
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1           Q.   "Did          tell you that a few months after he
2    left working for Epstein he became suicidal because of
3   issues in his marriage?"
4          A.   "Yes."
5           Q.   "Did he tell you that he went to Epstein's house
6    and tried to take Epstein's gun?"
7          A.   "Yes, he did."
8           Q.   "Did he tell you that it's worth several thousand
9    dollars?"
10          A.   "Yes."
11          Q.   "Did Epstein discover this and confront him about
12   it?"
13          A.   "Yes, he did."
14          Q.   "Did          admit to Epstein and the police what
15   he had done?"
16          A.   "Yes."
17          Q.   "Did Epstein also tell the police his gun was
18   missing?"
19          A.   "Yes."
20          Q.   "Were there any charges filed?"
21          A.   "No."
22          Q.   "Was he ever arrested?"
23          A.   "I don't believe so."
24          Q.   "And did Epstein pursue any charges about this
25   incident?"
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1        A.    "No.   He didn't pursue anything."
2       Q.     "Have you interviewed one of Epstein's former
3   pilots?"
4       A.     "Yes."
5        Q.     "Is that pilot named David Rodgers?"
6         A.    "Yes."
7       Q.     "Was he one of the pilots for Epstein's private
8    jet in the 1990s?"
9        A.     "Yes."
10       Q.     "Did he remember                    travelling on the
11   jet in the 90s?"
12        A.    "He remembered her travelling, but he didn't
13   remember specifics."
14       Q.     "So just to be clear, is your testimony that he
15   didn't remember the specific dates of the flights, but he
16   remembered her travelling on the jet during the 1990s?"
17       A.     "Yes."
18       Q.     "And did he remember                     specifically as
19   a person who travelled?"
20       A.     "Yes."
21       Q.     "Did you discuss with him the flight records that
22   we talked about earlier that lists a person named              as a
23   passenger?"
24       A.     "Yes."
25       Q.     "Did he have a specific memory of those exact
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1   flights?"
2        A.     "No."
3        Q.     "But was he aware of any other                flying on the
4   jet, besides                   , in the 1990s?"
5         A.     "No.    No other        at the time."
6         Q.     "Earlier, when we were looking at Interlochen
7   attendance records for the summer of 1994, you noted that
8                   was one of the names on that record, is that
9    right?"
10        A.     "Yes."
11        Q.     "Is that                    ?"
12        A.     "Yes."
13        Q.     "Have you interviewed                    ?"
14        A.     "Yes, I have."
15        Q.     "Did he tell you that he remembered                talking
16   that summer at camp about having met Jeffrey Epstein?"
17        A.     "Yes."
18        Q.     "Did he tell you that he remembered               going
19   over to Epstein's house in Palm Beach when they were in high
20   school?"
21        A.     "Yes."
22        Q.     "Did he remember that            would often talk about
23   spending time with Maxwell and Epstein during this time?"
24        A.     "Yes."
25        Q.     "Did he remember           telling him they -- when
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1    they were in high school -- about at least one trip to
2    New York City that she took with Epstein?"
3       A.     "Yes."
4       Q.     "Did he remember           describing Epstein's
5    townhouse in Manhattan?"
6        A.     "Yes."
7       Q.     "And does he remember            talking often about
8    Ghislaine Maxwell?"
9        A.     "Yes."
10       Q.     "Now based on your interviews with            did he
■,
11   tell you whether he knew back then, when they were in high
12   school, whether          was being sexually abused by Epstein?"
13       A.     "He didn't know back then."
14       Q.     "Did ■     ever meet Ghislaine Maxwell?"
15       A.     "Yes, he did."
16       Q.     "What did he remember about that?"
17        A.    "He remembered Epstein, Maxwell, and              being
18   near a movie theatre, and he was approximately 16 at the
19   time and          would have been 15, and just the little bit
20   of interaction they had.      And then after that,           had
21   told him that Maxwell had said something to the effect of, I
22   could teach                  a thing or two."
23       Q.     "Is that something that he remembers              telling
24   him back then, that Maxwell said?"
25       A.     "Yes."
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1         Q•     "During the course of this investigation have you
2    participated in any interviews with an individual named
?II
3
4        A.     "Yes."
5         Q.     "So for today's purposes, I'm just going to refer
6    to her as           .     How many times have you referred to
7   (verbatim)              ?"
8         A.     "Approximately, twice."
9                MS.                Excuse me.
10   BY MS.
?   11
11        Q.     "How many times have you interviewed
12        A.     "Approximately twice."
13        Q.     "Now does              know                  ?   Have they
14   ever met before as far as you know?"
15        A.     "As far as I know, no."
16        Q.     "Turning to the next slide.           Are these photographs
17   of        when she was in high school?"
18        A.     "Yes."
19        Q.     "And is her date of birth                        ?"
20        A.     "Yes."
21        Q.     "When             was approximately 16 and a junior in
22   high school where was she living?"
23        A.     "She was living in                  with her mother."
24        Q.     "Does she have any siblings?"
25        A.     "An older sister."
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1       Q.      "What did her older sister do?"
2        A.     "Her older sister lived -- worked for Epstein."
3       Q.      "Where did she work for Epstein?"
4        A.     "Here in New York."
5        Q.      "Did there come a time, in approximately December
6    1995, when           had a phone conversation with her sister
7   about travelling to New York City?"
8        A.      "Yes."
9        Q.      "What did they discuss?"
10       A.      "They discussed her coming to New York and meeting
11   Epstein."
12       Q.      "What did her sister tell            about why she
13   should meet Epstein?"
14       A.      "She said that he could help her with her
15   college."
16       Q.      "And did she say -- does the sister say whether
17   the sister wanted her to meet Epstein, or did she say
18   whether Epstein wanted to meet
19       A.      "Epstein wanted to meet
20       Q.      "Now let me just pause here.       You testified that
21   this happened in approximately December of 1995.         Just for
22   context, the years that we were talking about with
23         , was that 1994 through 1997?"
24        A.     "Yes."
25       Q.      "So is this approximately the same time period
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1    while what you described             telling you happened?"
2       A.      "Yes."
3       Q.      "So in January of 1996 did               fly on a
4   commercial airline to New York City to spend a weekend with
5    her sister and meet Jeffrey Epstein?"
6        A.      "Yes."
7       Q.      "Did she tell you that?"
8        A.      "Yes."
9        Q.      "During the trip did            tell you that she met
10   Epstein at his townhouse in New York City?"
11       A.      "Yes, she did."
12       Q.      "Did she tell you that Epstein discussed her plans
13   for college applications and offered to help her?"
14       A.      "Yes."
15       Q.      "What was         • s first impression of Jeffrey
16   Epstein?"
17       A.      "She was very impressed by him."
18       Q.      "What did she -- what was her impression, based on
19   this conversation, of what Epstein was going to do for her?"
20       A.      "That he was going to help her with her future
21   plans for college."
22       Q.      "During that trip to New York City did she stay at
23   Epstein's townhouse or at her sister's apartment?"
24        A.     "Her sister's apartment."
25       Q.      "During that trip did she tell you that she saw
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1    Epstein a second time when he took                 and her sister to
2    the movies?"
3       A.         "Yes."
4       Q.         "What did she tell you happened at the movies?"
5        A.         "She said that they were sitting in the theatre
6    and Epstein was between               and her sister, and Epstein
7   put his hand on her leg; he rubbed her arm and held her
8    hands -- held hands with her."
9        Q.         "From what she told you, what was her impression
10   about whether her sister could see what was going on?"
11        A.        "She felt like her sister couldn't see."
12       Q.         "What was her reaction to this happening?"
13        A.        "She was uncomfortable."
14       Q.         "After the movie did she tell her sister what hac
15   happened?"
16       A.         "No, she didn't."
17       Q.         "Did she say why not?"
18       A.         "She said that she knew           , her sister, really
19   liked Epstein and that Epstein could help them.            So she
20   didn't tell her."
21       Q.         "After this trip did           go back home to
7"
22
23        A.        "Yes."
24       Q.         "Did Epstein contact her afterwards?"
25        A.        "Yes."
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1        Q.      "Did he discuss with her, her ongoing college
2    plans?"
3       A.      "Yes, he did."
4       Q.      "Did he invite her to a weekend at his ranch in
5    New Mexico in the spring of 1996?"
6         A.     "Yes."
7       Q.      "Was she 16 at the time?"
8        A.      "Yes, she was."
9        Q.      "From what she told you, what was
10   impression of who would be on this trip to New Mexico?"
11       A.      "She knew Maxwell would be there."
12       Q.      "Did she -- was she told anyone else was going to
13   be present during this trip?"
14       A.      "She said that there would be like other students
15   her -- kids her age."
16       Q.      "And what was her understanding of who these other
17   kids were and why they would be there?         Sorry, let me --"
18       A.      "Rephrase."
19       Q.      "Rephrase that question.      You testified that she
20   was told that on this trip that there would be other
21   students.    Was she under the impression that there would be
22   other students like her on the trip who were also being
23   mentored by Epstein?"
24       A.      "Yes."
25       Q.      "Now you testified just a moment ago that she was
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1    also told that Maxwell would be there.       Are you referring to
2    Ghislaine Maxwell?"
3       A.    "Yes."
4       Q.    "At the point that she was told that
5    Ghislaine Maxwell would be on this trip, had she ever met
6    Ghislaine Maxwell?"
7       A.    "No, she hadn't."
8        Q.    "Had she heard her sister talk about
9    Ghislaine Maxwell?"
10       A.    "Yes."
11       Q.    "How did -- from what she described to you -- how
12   did her expectation that Maxwell would be on this trip make
13   her feel about the trip?"
14        A.   "It made her comfortable.       Her sister had talked
15   highly of Maxwell."
16       Q.    "Did         tell you that she flew to New Mexico
17   that spring when she was 16?"
18       A.    "Yes."
19       Q.    "Did she meet Ghislaine Maxwell when she arrived
20   in New Mexico?"
21       A.    "Yes, she did."
22       Q.    "How did she describe Maxwell's demeanor and
23   attitude when she met her?"
24       A.    "She described Maxwell as being very charming.
25   She gave her a tour of the house, and Maxwell took
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1    shopping which made her feel special."
2         Q.   "What does she remember talking about with
3   Ghislaine Maxwell?"
4        A.   "They talked about school, homework, trips."
5         Q.   "Did she talk with her about applying to college?"
6         A.   "Yes."
7        Q.   "Did she talk about her classes in high school?"
8         A.   "Yes."
9         Q.   "Did she talk with her about the homework that she
10   had to do that weekend?"
11        A.   "Yes."
12        Q.   "Did she talk with Maxwell about her family?"
13        A.   "Yes."
14        Q.   "Did she talk with her about her home life and
15   living with her mother?"
16        A.   "Yes."
17        Q.   "From what          told you, when she got there, who
18   else was at the ranch besides Ghislaine Maxwell and
19   Jeffrey Epstein?"
20        A.   "It was just them."
21        Q.   "Was it just the three of them there the entire
22   weekend of the visit?"
23        A.   "Yes."
24        Q.   "Were there any other school kids there?"
25        A.   "No."
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1         Q.    "When they were at the ranch, from what                   to_
2    you, did Maxwell say anything to               about massages?"
3        A.    "Yes."
4        Q.    "Did she say anything about -- to her about foot
5    massages?"
6         A.    "Yes."
7        Q.    "What did          tell you about that?"
8         A.    "Maxwell told           to give Epstein a foot massage
9    and then showed her and instructed her on how to do it.
10           was a little uncomfortable, but Maxwell was joking
11   around so she just followed her lead."
12        Q.    "Did         tell you what Maxwell and
13   Epstein -- took her to the movies that weekend?"
14        A.    "Yes."
15        Q.    "What did she tell you about that trip to the
16   movies?"
17        A.    "She said that when they went outside the theatre
18   Maxwell was joking around and pulled Epstein's pants down a
19   little bit.   And then once they went inside the theatre,
20   Epstein, when they were sitting down, touched             's leg,
21   and rubbed her arm, held her hand.       And that this time
22   he --         felt -- he wasn't trying to hide it from
23   Maxwell.
24        Q.    "What was         's   reaction   to all of this?"
25        A.    "She was uncomfortable."
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1           Q.   "During the same weekend was there another
2    occasion when Maxwell talked about massages?"
3          A.   "Yes."
4          Q.   "What happened?"
5           A.   "Maxwell had asked           if she had ever had a
6    massage, and Maxwell told her she could give her one.
7           was on her back, and Maxwell pulled the sheet down
8    exposing her chest; she was nude from the top up and
9    proceeded to massage around her chest and breast area."
10          Q.   "From what          told you when she was describing
11   to you what you just described to the grand jury, how did
12   she feel while this was happening?"
13          A.   "She felt really uncomfortable."
14          Q.   "Did         also tell you about an incident that
15   happened one morning when she was in New Mexico?"
16          A.   "Yes."
17          4.   "What did she tell you happened?"
18          A.   "She said that she was in bed, and Epstein came
19   into the room and told her that he wanted to cuddle.         So he
20   laid down next to her and spooned her.         She told him that
21   she had to go to the bathroom to get out of the situation."
22          Q.   "What was her reaction to that, when Epstein got
23   into her bed?"
24          A.   "She felt uncomfortable.      She didn't know what to
25   do."
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1        Q.      "Did         go back home to             when the
2    weekend was over?"
3       A.      "Yes, she did."
4       Q.      "Did she tell anyone, when she got home, about
5    what had happened?"
6         A.     "No."
7       Q.      "Is that for the same reason you described
8    earlier?"
9         A.     "Yes."
10       Q.      "Did Epstein end up paying for            to go on
11   trip to Thailand that summer?"
12       A.      "Yes."
13       Q.      "Did         have any contact with Maxwell or
14   Epstein after that trip?"
15       A.      "Not that she recalled."
16       Q.      "When you interviewed          , what was her demeanor
17   like when she described her interactions with
18   Jeffrey Epstein and Ghislaine Maxwell?"
19       A.      "She became upset and emotional."
20       Q.      "Is         currently pursuing a civil lawsuit
21   against Maxwell and Epstein's estate?"
22       A.      "Yes, she is."
23       Q.      "What does          do for a living now?"
24       A.      "She's a psychologist who works with trauma
25   victims."
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1         Q.    "During the course of this investigation have you
2    interviewed someone named
3        A.    "Yes."
4        Q.    "For today's purposes I'm just going to refer to
5    her as           .   How many times have you interviewed
6             , approximately?"
7        A.    "Approximately three times."
8         Q.    "Turning to the next slide.        Is this a photograph
9    of           that she provided to you?"
10        A.    "Yes."
11        Q.    "And did she tell you that this was taken when she
12   was in -- approximately 16 or 17 years old?"
13        A.    "Yes."
14        Q.    "Is           's date of birth
15        A.    "Yes."
16        Q.    "Did            grow up in England?"
17        A.    "Yes, she did."
18        Q.    "Did she tell you that there came a point where
19   she met Ghislaine Maxwell when she was about 17?"
20        A.    "Yes."
21        Q.    "How did she tell you that they met?"
22        A.    "She said they met through a mutual friena."
23        Q.    "Did she tell you that this would have happened in
24   around 1994 or 1995?"
25        A.    "Yes."
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1        Q.     "And is that within the same time period that
2    we've been talking about today?"
3       A.     "Yes."
4       Q.     "What happened after she was introduced to
5    Ghislaine Maxwell, from what she told you?"
6        A.     "She said Maxwell treated her like they were
7   sisters.   Her quote was 'like naughty school girls' is how
8    Maxwell treated with her."
9        Q.     "Did she tell you that Maxwell seemed to
10   immediately take an interest in her?"
11       A.     "Yes."
12       Q.     "Did she tell you that they began spending time
13   together in London?"
14       A.     "Yes."
15       Q.     "And just to be clear was Maxwell in her thirties
16   while this is happening?"
17       A.     "Yes."
18       Q.     "Did Maxwell -- did              ever remember Maxwell
19   ever talking about having a boyfriend named
20   Jeffrey Epstein?"
21       A.     "Yes."
22       Q.     "What did she tell             about that?"
23       A.     "Maxwell told             that Epstein was going to
24   like her."
25       Q.     "Did there come a time when she was 17 that
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1              described that Maxwell introduced her to
2    Jeffrey Epstein?"
3        A.    "Yes."
4        Q.    "How did she describe that occurring?"
5         A.    "Epstein had flown into London.             He was at
6    Maxwell's residence in London, and Maxwell had called
7             over.   So             went over, and when she got there
8    Maxwell was saying to Epstein, kind of -- the words
9    used was -- giving him a resume of her attributes, saying,
10   she's so pretty, she's so strong; and then Maxwell asked hel
11   to give Epstein a massage."
12        Q.    "Now you've testified just a moment ago that
13   Maxwell -- that               described to you that Maxwell asked
14   her to give Epstein a massage during this first meeting, is
15   that correct?"
16        A.    "Yes."
17        Q.    "Did Maxwell state to her, in sum and substance,
18   since you're so strong, I'd appreciate it if you'd give
19   Jeffrey a massage because he needs a massage every day or I
20   get in trouble?"
21        A.    "Yes, she said that."
22        Q.    "Is that what                said to you, in sum and
23   substance?"
24        A.    "Yes."
25        Q.    "When that happened did                 remember Maxwell
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1   leading her to a room in the house?"
A.     "Yes."
3        Q.     "When            went in the room -- oh excuse m(
4    what happened?"
5         A.     "When            went in the room Epstein was in
6    robe.   He took off his robe, and she started massaging him.
7    And then he touched              and pulled her hand to his
8    penis."
9        Q.     "What does            remember Epstein saying when he
10   did this?"
11        A.     "Don't be frigid."
12        Q.     "What was her reaction to this happening, from
13   what she told you?"
14        A.     "She was taken back by it."
15        Q.     "When this episode ended and              left the
16   room, did she tell that she remembered Maxwell being just
17   outside the room when she left?"
18        A.     "Yes."
19        Q.     "Did she remember Maxwell saying to her, did you
20   have fun?    Did he like it?"
21        A.     "Yes."
22        Q.     "Does she remember Maxwell calling her several
23   Jays afterwards, or at some short period of time
24   afterwards?"
25        A.     "Yes, she did."
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1           Q.   "Did           remember Maxwell saying to her on the
2    phone call, in sum and substance, well, aren't you a clever
3   girl, Jeffrey was very impressed?"
4          A.   "Yes."
5           Q.   "Shortly after this incident does she remember
6    Maxwell asking her to come back over to the house?"
7          A.   "Yes."
8           Q.   "And when she got there did she tell you she
9    remembered Maxwell saying to her, in substance, thank God
10   you're here, if it's not you or someone else it falls to
11   me?"
12          A.   "Yes."
13          Q.   "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          Q.   "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
24   Palm Beach, U.S. Virgin Islands, Paris, and New York, for
25   the next several years?"
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1        A.   "Yes, they did."
2        Q.   "Does she remember whether these trips began
3   before 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 she spent with
7   Maxwell when they first met, when she was 17, is that right?
8         A.   "Yes."
9         Q.   "During these conversations when she would spend
10   time with Maxwell, did             remember talking with her
11   about her life, and her family, and her personal
12   circumstances, with Maxwell?"
13        A.   "Yes."
14        Q.   "Now you testified a moment ago that              told
15   you that at some point she began travelling with Maxwell and
16   Epstein, and she wasn't sure whether or not these trips
17   started before she turned 18, is that right?"
18        A.   "Yes."
19        Q.   "Did           describe to you that Epstein sexually
20   abused her during these trips, typically in the context of a
21   sexualized massage?"
22        A.   "Yes, he did."
23        Q.   "Did Epstein give her money?"
24        A.   "Yes."
25        Q.   "Did she tell you that he would give her cash?"
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1        A.   "Yes."
2       Q.    "Did she describe to you that the abuse included,
3   among other things, Epstein groping her and using a massager
4   device on her genitals?"
5        A.    "Yes."
6        Q.    "And was the massager device like a vibrator?"
7        A.   "Yes, it was."
8        Q.    "From what            told you, was Maxwell in the
9    room during these encounters?"
10       A.    "Maxwell wasn't in the room."
11       Q.    "What did she tell you would typically happen when
12               left the room after these episodes; was Maxwell
13   typically nearby?"
14       A.    "Yes.    She was usually right near the room."
15       Q.    "Does she remember Maxwell asking her, after she'd
16   leave the room from one of these sessions, how was it; is he
17   happy?"
18       A.    "Yes."
19       Q.    "Did she also tell you that she remembers Maxwell
20   telling her at some point, in sum and substance, you know
21   how he is when he's not happy, and you know what makes him
22   happy; he has to have sex all the time; he's like a super
23   hero?"
24       A.    "Yes, she said that."
25       Q.    "Did           tell you about an incident that
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1    occurred, after she turned 18, in Palm Beach when she was
2    staying at the Palm Beach house?"
3        A.    "Yes."
4        Q.    "Did the incident she described to you involve a
5    school-girl outfit?"
6         A.    "Yes, it did."
7        Q.    "Could you please describe for the grand jury what
8              told you about that incident?"
9         A.               said that Maxwell had shown her a bedroom
10   and upon the bed was a school-girl outfit.          Maxwell had told
11   her -- when            confronted her about it -- and Maxwell
12   said, well, I thought it would be adorable if you gave
13   Jeffrey his tea in this; so              felt like she had to put
14   it on.    And so she put it on, took Epstein his tea, and
15   Epstein then slapped her on the buttocks and reached under
16   the skirt and touched her."
17        Q.    "What was her demeanor like when she described
18   this incident to you?"
19        A.    "She was crying.     She was very upset."
20        Q.    "When           described seeing the school-girl
21   outfit and talking to Maxwell about it, did she remember
22   Maxwell telling her, don't be so frigid?"
23        A.    "Yes."
24        Q.    "Does she remember that later in the day, after
25   she had delivered Epstein his tea and he assaulted her, does
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1    she remember Maxwell telling her, I heard you did well?"
2        A.     "Yes."
3        Q.     "During the years that              was in contact with
4   Maxwell and Epstein, did she remember whether Maxwell had
5    ever asked her if she knew any other girls who could massage
6    Epstein?"
7        A.     "Yes."
8         Q.     "Does she remember Maxwell saying, in sum and
9    substance, do you know anyone who could give him a blowjob
10   today, I don't feel like it?"
11        A.     "Yes."
12        Q.     "Does she remember Maxwell saying, when she asked
13   her to bring other girls, that they have to look young at
14   least?"
15        A.     "Yes."
16        Q.     "From your conversations with              , did she
17   tell you whether or not she ever brought any other girls?"
18        A.     "'I'll didn't bring any girls."
'
19        Q.     "Did she tell you why not?"
20        A.     "She didn't want anyone else to go through that."
21        Q.     "From your interviews with               , did she tell
22   you that there came a time, when she was in her early
23   twenties, when she stopped travelling with Maxwell and
24   Epstein?"
25        A.     "Yes."
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1         Q.     "Was she struggling with substance abuse at that
point?"
3        A.     "Yes, she was."
4        Q.     "Did she tell you that she got sober in her
5    twenties?"
6         A.     "Yes, she did."
7        Q.     "What is her current profession?"
8         A.     "She runs a non-profit for people who struggle
9    with addiction and trauma."
10        Q.     "Did           provide you with several emails that
11   she exchanged with Epstein in the early 2000s?"
12        A.     "Yes, she did."
13        Q.     "And were those emails very friendly in tone?"
14        A.     "Yes, they were."
15       4•      "What did she say to you when you talked with her
16   about those emails?"
17        A.     "She said she didn't, at the time, want to
18   acknowledge what was going on to her.         That looking
19   back -- on -- it's different."
20        Q.     "Did your squad at the FBI execute a search
21   warrant at Jeffrey Epstein's townhouse in Manhattan in July
22   of 2019?"
23        A.     "Yes."
24        Q.     "Did you personally participate in the search of
25   Epstein's residence?"
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1        A.     "Yes, I did."
2       Q.      "Did the townhouse include a massage room?"
3        A.     "Yes."
4       Q.      "Have you yourself been in that massage room?"
5        A.      "Yes, I have."
6        Q.      "Could you please describe for the grand jury what
7   that massage room looked like?"
8         A.     "It was dark.     It had dark draperies covering the
9    windows.    There was a massage table; there were oils, there
10   was a handheld massager in there; along with handcuffs, a
11   whip, and along with -- walls were nude photographs of young
12   females."
13       Q.      "I believe you testified a moment ago that
14                 told you that there was a time when Maxwell
15   asked her to wear a school-girl outfit for Epstein when they
16   were in Palm Beach.      Did you find a school-girl outfit in
17   Epstein's New York townhouse?"
18       A.      "Yes, we did."
19       Q.      "Where did you find it?"
20        A.     "It was found in a room next to the massage room."
21       Q.      "And to be clear did the FBI find sex toys during
22   the search?"
23       A.      "Yes."
24       Q.      "What was found?"
25       A.      "Butt plugs, dildo, and vibrators."
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1        Q.     "We've talked about three minor girls today;
2                                , is that right?"
3        A.     "Yes."
4        Q.     "Have you reviewed the proposed indictment marked
5    Grand Jury Exhibit 1?"
6         A.     "Yes, I have."
7        Q.     "Is         the individual referred to as Victim 1
8    in the proposed indictment?"
9         A.     "Yes."
10        Q.     "Is         the individual referred to as Victim 2
11   in the proposed indictment?"
12        A.     "Yes."
13        Q.     "Is           the individual referred to as Victim 3
14   in the indictment?"
15        A.     "Yes."
16        Q.     "During all of Maxwell's interactions with the
17   victims when they were underage girls, based on the
18   timeframe and your knowledge of Maxwell's birthdate, was she
19   in her thirties?"
20        A.     "Yes, she was."
21        Q.     "Just one moment.     All right.    Switching gears.
22   Have you become aware that in or about 2016 Maxwell gave
23   sworn testimony in a civil deposition in connection with a
24   lawsuit?"
25        A.     "Yes."
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1        Q.   "Could you please explain for the grand jury, what
is a deposition?"
3        A.   "It is a statement made under oath."
4        Q.   "And in the course of civil litigation is it
5    common for witnesses or parties of the lawsuit to give a
6   deposition, under oath, where they testify about the
7   substance of the case?"
8        A.   " Yes.   "
9        Q.   "And is deposition testimony live, and in-person,
10   and under oath?"
11        A.   "Yes."
12        Q.   "Is a court reporter present when a deposition
13   takes place?"
14        A.   "Yes."
15        Q.   "Now before we talk about Maxwell's deposition
16   testimony, I want to talk to you about the lawsuit that the
17   testimony was about.        Have you become aware that in or about
18   2015 an individual named                              filed a lawsuit
19   against Ghislaine Maxwell here in the Southern District of
20   New York?"
21        A.   "Yes."
22        Q.   "And was                suing Maxwell for defamation?"
23        A.   "Yes, she was."
24        Q.   "Was the lawsuit captioned
25   against Ghislaine Maxwell, the docket number 15CB 7433, here
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1    in the Southern District of New York?"
2        A.   "Yes."
3        Q.   "Generally speaking, in broader strokes, what was
4   the lawsuit about; what was the claim that                 was
5    bringing against Maxwell?"
6               WITNESS.    I'm sorry.    What line are we on again?
7              MS.           Page 68, line 4.
8               WITNESS.              had stated that she had been
9    sexually abused by Epstein and Maxwell as a minor.         Maxwell
10   came forward publically and called her a liar, so
11   sued her for defamation."
12             BY MS.
13        Q.   "So just a small legal instruction on this topic.
14   Ladies and gentlemen, I instruct you that the allegations in
15   the lawsuit are not being presented to you as evidence that
16   those incidents occurred.     I instruct you that you should
17   not consider those allegations for their truth.       Instead,
18   the circumstances of the lawsuit are being presented to you
19   so that you can consider the context of the case and the
20   circumstances under which Maxwell made statements under
21   oath.   Turning back to the deposition, did Maxwell's
22   deposition take place over two different days?"
23        A.   "Yes."
24        Q.   "On both days does she give testimony in
25   Manhattan?"
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1        A.   "Yes, she did."
2       Q.    "Is that where the deposition took place?"
3        A.   "Yes."
4       Q.    "And on both days was Maxwell sworn under oath?"
5        A.    "Yes."
6        Q.    "If you could flip through the remaining slides of
7   the presentation, do those slides contain true and accurate
8    excerpts of the transcript of that deposition?"
9        A.    "Yes."
10       Q.    "Turning to the next slide, is this the cover page
11   of the transcript of the first deposition that took place on
12   April 22, 2016?"
13        A.   "Yes."
14       Q.    "And does it have the case caption on it?"
15       A.    "Yes, it does."
16       Q.    "Turning to the next slide.       Is this an excerpt
17   from the transcript?"
18       A.    "Yes."
19       Q.    "I imagine the grand jurors can't read it from
20   their seats so if you could read it with me, I'll read the
21   questions, and if you could read the answers."
22             "'Did Jeffrey Epstein have a scheme to recruit
23   underage girls for underage massages?'"
24             MS.            And it appears there was an objection
25   from the lawyer.
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1             BY MS.
2       Q.    "'If you know.'"
3        A.   "'I don't know what you are talking about.'"
4       Q.    "Just to be clear, was the question and
5    answer    is the answer here Maxwell's testimony?"
6        A.    "Yes."
7       Q.    "Just to be clear you testified earlier that
8    participated in sexualized massages with Epstein and
9    Maxwell, is that right?"
10       A.    "Yes."
11       Q.    "And         was a minor when that occurred?"
12       A.    "Yes."
13       Q.    "And did you also testify earlier that
14   Maxwell -- that                         told you that Maxwell
15   asked her to give Epstein massages when she was a minor?"
16       A.    "Yes."
17       Q.    "If you could turn to the next slide please.       Is
18   this another excerpt from that same deposition?"
19       A.    "Yes, it is."
20       Q.    "All right.    I'll read the question and you can
21   read the answer."
22             "'Was all the people, under the age of 18 that
23   you've interacted at with, at any of Jeffrey Epstein's
24   properties?'"
25       A.    "'I'm not aware of anybody that I interacted with,
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1    other than, obviously,               who was 17 at this point.'"
2        Q.     "Just to be clear, you testified earlier about two
3   girls under the age of 18 who interacted with Maxwell at
4   Epstein's properties, is that correct?"
5        A.     "Yes."
6        Q.     "And those individuals were                  and
7             who told you that, correct?"
8         A.    "Yes, that's correct."
9        Q.     "Turning to the next slide.       Is this the cover
10   page of the transcript from the deposition that took place
11   on July 22, 2016?"
12       A.     "Yes."
13       Q.     "And again, was this Maxwell giving testimony as
14   part of the testimony under oath here in Manhattan?"
15       A.     "Yes."
16       Q.     "If you could please turn to the next slide.          Is
17   that an excerpt -- are these two excerpts from that
18   deposition?"
19       A.     "Yes."
20       Q.     "Again, I'll read the questions, if you could
21   please read the answers."
22              "'Were you aware of the presence of sex toys or
23   devices used in sexual activities in Mr. Epstein's
24   Palm Beach house?'"
25              MS.            There is an objection from the
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1    lawyer.
2               WITNESS.     "'No, no.    Not that I recall.'"
3   BY MS.
4        Q.   "'Do you know whether Mr. Epstein possessed sex
5    toys or devices used in sexual activities?'"
6              MS.             There's an objection from the lawyer.
7              WITNESS.     "'No."
8               BY MS.
9         Q.   "Just to be clear you testified earlier that
10               told you he found sex toys and a massager in
11   Palm Beach and also that he had seen Maxwell had a basket of
12   sex toys in her closet there, is that correct?"
13        A.   "Yes, that's correct."
14        Q.   "And is it correct you testified earlier that
15   Epstein used a vibrator on                    , is that correct?"
16        A.   "Yes, that's correct."
17        Q.   "And did you also testify earlier that
18             told you he did that as well?"
19        A.   "Yes, that's correct."
20        Q.   "And did you also testify earlier that sex toys
21   were found by the police in the Palm Beach house in 2005, is
22   that right?"
23        A.   "Yes."
24        Q.   "And did you also testify earlier that the FBI
25   found sex toys in Epstein's New York City townhouse in
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1    2019?"
2        A.   "Yes, that's correct."
3        Q.   "If you could please turn to the next slide.           This
4   is on Page 27.   It says, are these also excerpts from that
5    same deposition?"
6         A.   "Yes."
7        Q.   "Again, I'll read the questions if you could
8    please read the answers."
9        4.    "'Other than yourself, and the blonde and brunette
10   that you have identified as having been involved in
11   three-way sexual activities, with whom did Mr. Epstein have
12   sexual activities?'"
13             MS.            There's an objection from the lawyer.
14             WITNESS.     "'I wasn't aware that he was having
15   sexual activities with anyone when I was with him, other
16   than myself.'"
17             BY MS.
18        Q.   "'I want to be sure that I'm clear.       Is it your
19   testimony that in the 1990s and 2000s you were not aware
20   that Mr. Epstein was having sexual activities with anyone
21   other than yourself and the blonde and brunette on those few
22   occasions when they were involved with you?'"
23        A.   "'That is my testimony.      That is correct.'"
24        Q.   "Have you reviewed the deposition transcript?"
25        A.   "Yes."
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1        Q.      "In full?    Now the excerpt we just read has the
2    reference to a blonde and a brunette.         Are those individuals
3   completely different from the individuals we've been talking
4   about today?"
5        A.      "Yes."
6        4•      "Just to be clear, is it correct that you
7   testified earlier that             and          told you that
8    Epstein sexually abused them repeatedly, is that correct?"
9        A.      "Yes."
10       Q.      "And did you also testify earlier that Maxwell was
11   occasionally present when Epstein was abusing            , based
12   on what she told you?"
13       A.      "Yes, that's correct."
14       Q.      "Turning to the next slide.       Is this also an
15   excerpt from the same deposition?"
16       A.      "I'm sorry?"
17       Q.      "I'm so sorry.     Turning to the next slide, on
18   Page 28.    Is this also an excerpt from the same deposition?"
19       A.      "Yes."
20       Q.      "Thank you.    Okay.   Again, if we could read that
21   together.    I'll take the question and you can take the
22   answer."
23       Q.      "'Let's just tie that down.       Is it your testimony
24   that you've never given anybody a massage?'"
25       A.      "'I've not given anyone a massage.'"
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1        Q.     "'You never gave Mr. Epstein a massage?          Is that
2    your testimony?'"
3       A.     "'That is my testimony.'"
4       Q.     "'You never gave                   a massage?     Is that
5    your testimony?'"
6        A.     "'I never gave                   a massage.'"
7       Q.     "Just to be clear, as you testified earlier, is it
8    correct that                  told you that Maxwell gave her a
9    massage when they were in New Mexico?"
10       A.     "Yes."
11              MS.            We're going to stop the read back
12   there.   Ladies and gentlemen, let's take a five minute break
13   and we'll come back to finish the presentation in about five
14   minutes.   With the Foreperson's permission, I will ask that
15   the witness please be excused.
16              FOREPERSON.      Yes, he may.
17              MS.            Thank you.
18              (Witness Temporarily Excused)
19              (Time noted:    11:21 a.m.)
20              (Recess taken)
21
22
23
24
25
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1             (Colloquy Precedes)
2             (Witness Resumes)
3             (Time Noted: 11:34 a.m.)
4             BY MS.
5        Q.    Welcome back, Detective.
6        A.    Thank you.
7       Q.    I have placed in front of you what has been marked
8    as Grand Jury Exhibit 5.     Do you recognize that?
9        A.    I do.
10       Q.    Is this a PowerPoint presentation concerning some
11   of the facts and evidence that you have gathered in your
12   investigation?
13       A.    Yes.
14       Q.    Did you participate in preparing this Exhibit in
15   connection with your testimony today?
16       A.    Yes.
17       Q.    Will it assist you in testifying today?
18       A.    Yes.
19       Q.    Then we're going to have it up on the screen and
20   we'll use it as you testify.     During the course of this
21   investigation have you participated in multiple interviews
22   with an individual named                      ?
23        A.   Yes.
24       Q.    Did those interviews take place in the year 2020
25   and the year 2021?
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A.     Yes.
Q.      Were there approximately five of those interviews
3   in total?
4        A.     Yes.
5        Q.      For today's purposes I'm going to refer to her as
6               Have you also reviewed reports from other law
7   enforcement interviews for
A.     Yes.
9       Q.      And is your testimony today based on both the
10   review of those reports and your personal participation in
11   interviews with
12        A.     Yes.
13       Q.      Turning to the next slide.     Are these photographs
14
15       A.      Yes.
16       Q.      Did         tell you approximately how old she was
17   in one of these photographs?
18        A.     Yes.
19       Q.      Which photograph did she identify?
20       A.      The one on the right.
21       Q.      Where is the one on the right from, according to
22
23       A.      Oh, I'm sorry.   That was from her MySpace page.
24       Q.      And about how old did            recall being in this
25   photograph from her MySpace page?
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A.   Sixteen years old.
Q.   What is               date of birth?
3          A.
4           Q.   Where was             living when she was about 14
5    /ears old?
6           A.   West Palm Beach, Florida.
7           Q.   What was               home life like when she was 14
8    years old?
9          A.   It was troubled.      She grew up -- she had been
10   molested multiple times as a child.          Her mother was addicted
11   to drugs and alcohol.       Her parents were separated, she often
12   fought with her brother and her mother.
13          Q.   When            was 14 years old, did she have a
14   boyfriend?
15          A.   Yes.
16          Q.   What was his name?
17          A.
18          Q•   How old was                   when they were dating
19   when           was 14 years old?
20          A.   Approximately 17.
21          Q.   So was          about three years older than
22          A.   Yes.
23          Q.   Did there come a time when                learned of and
24   met Jeffrey Epstein?
25          A.   Yes.
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1          Q.    According to              how did that happen?
2          A.    Her boyfriend           was friends with someone named
3                        (ph) who was dating
4                The four of them would often hang out together.
5    On one particular occasion                  was asked by them and
6               if she would like to make some money by massaging
7    an older man.
8          Q.    How did             respond?
9          A.    She agreed to do it.
10          Q.    About what year does               remember this
11   conversation taking place?
12          A.    2001.
13          Q.    So how old was              at that time?
14          A.    Fourteen.
15          Q.    During your investigation have you learned of
16                            date of birth?
17          A.    Yes.
18          Q•    How old was                        at the time of the
19   conversation with                 in 2001, about massaging an old
20   guy?
21          A.    Seventeen.
22          Q.    After that conversation with                did
23   meet Epstein?
24          A.    Yes.
25          Q.    What did             remember happening the first time
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1   she met Epstein?
2           A.   She was brought there by                   She recalls
3    going in through the side door and being introduced to
4    Maxwell as they entered.
5           Q.   Based on her interactions with Maxwell, as she and
6                entered, what was                 understanding of
7    whether              and Maxwell had met before?
8           A.   She understood that they had met before.
9          Q.    And did Maxwell, in substance, tell                  to
10   show            what to do?
11          A.    Yes.
12          Q.    What happened next?
13          A.    They went upstairs to the massage room.           They set
14   up the massage room, waited for Epstein to enter.              At that
15   point they participated in giving him a massage.
16          Q.    How did             describe the massage room in the
17   Florida house?
18          A.   She described it as having a few doors inside of
19   it, some of them entering a closet.          She described there
20   being a -- it's like a bathroom, basically, that had a sink
21   inside of it.       And inside of the closet had a massage table
22   which they had to take out in order to set it up.
23          Q.    What, if any, photographs did               recall
24   seeing in and around the massage room?
25          A.   She recalls nude photographs of Maxwell.
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Q.    And of other females?
A.    Yes.
3          Q.    After            and           had set up the massage
4    table, what happened next?
5           A.    Jeffrey Epstein came into the room; they massaged
6    him.    At some point during the massage he turned over and
7                got on top.   They had sex, and            sat on the
8    couch and tried not to watch.
9          Q.    According to             did            and
10   Jeffrey Epstein engage in sexual intercourse during that
11   massage?
12          A.    Yes.
13          Q.    At the end of the massage what happened?
14          A.    Jeffrey left, they got dressed, and each got paid,
15   and they walked downstairs.         They got paid $300 each.
16          Q.    So to clarify, did              and           each
17   receive $300?
18          A.    Yes.
19          Q.    And how did they receive that money; in what
20   denomination?
21          A.    Crisp one hundred dollar bills.
22          Q.    After that first visit did              go to Epstein's
23   Palm Beach residence on multiple occasions to provide
24   sexualized massages to Jeffrey Epstein between 2001 and
25   2004?
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A.   Yes.
Q.   Approximately how many times does                estimate
3    she massaged Jeffrey Epstein?
4         A.   About one hundred times.
5         Q.   Do             memories of the events at Epstein's
6    residence run together after that first visit with
7         A.   Yes.
8         Q.   At some point after her first or second visit to
9   Epstein's residence, did             give her phone number to
10   someone at Epstein's house?
11        A.   Yes.
12        Q.   After that did             go to Epstein's house by
13   herself without             accompanying her?
14        A.   Yes.
15        Q.   After           provided her phone number, how did
16   she schedule times to massage Epstein at his house?
17        A.   She would either call herself or she would receive
18   a phone call.
19        Q.   Did           explain why she would call herself to
20   ask to schedule a time to massage Epstein?
21        A.   Yes.    At the time she wanted to make more money so
22   she could buy drugs.
23        Q.   During her time seeing Epstein did                become
24   addicted to certain drugs?
25        A.   Yes.
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1        Q.    What drugs was she primarily using?
2        A.    Cocaine and marijuana.
3        Q.    When someone would call            to schedule her
4   for massages with Epstein, who does               remember making
5    those calls?
6         A.    Maxwell or
7        Q.    And were there particular time periods, over the
8    course of the years when            was interacting with
9    Epstein, that one or the other of those two individuals
10   would call?
11        A.    Yes.
12        Q.    What did          say about that?
13        A.    She recalled that for the first several months of
14   going to Epstein she would get calls primarily from Maxwell.
15   After that, she would receive calls primarily from
16   but at the same time, occasionally receiving calls from
17   Maxwell.
18        Q.    And did she also remember receiving calls from
19   other Epstein employees whose names               did not know?
20        A.    Yes.
21        Q.    Did          refer to Maxwell as Maxwell?
22        A.    Yes.
23       4•     And then you mentioned another person; what was
24   the other person's name?
25        A.
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1         Q.    And did she primarily refer to              -- did
2               primarily refer to                    as
3         A.     Yes.
4          Q.     Who was                 , according to
5          A.    She was another employee of Epstein's.         She was an
6    assistant who made phone calls, arranged massage
7    appointments, and took photographs.
8          Q.    When Maxwell would call                to schedule
9   massage appointments with Epstein, did Maxwell ever tell
10              where Maxwell was calling from?
11         A.     Yes.
12         Q.    What did              remember about that?
13         A.    She recalls her saying that they were in New York,
14   and that they would be travelling to Florida at a certain
15   time period and asking if she would be available for that
16   time when they return.
17         Q.    And when you say "they" would be in New York, who
18   was           referring to?
19         A.    Epstein and Maxwell.
20         Q.    So did              understand from these conversations
21   that Maxwell and Epstein, at the time of those phone calls,
22   were in New York?
23         A.     Yes.
24         Q.     What phone numbers would Epstein's employees call
25   to schedule appointments for                 to massage Epstein?
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1        A.    They would call multiple phone numbers, including
2              cell phone, her mother's phone, her landline, or
3   her home line, and her boyfriend               's phone.
4        Q.     How did             get to Epstein's residence for
5    each massage appointment?
6        A.    She would either be driven by her boyfriend; she
7    would drive herself on occasion even though she did not have
8    a license; she had been driven there by                    and also
9   Epstein or Maxwell would send him             send her a cab    to be
10   picked up.
11        Q.     Did              boyfriend           ever meet anyone at
12   Epstein's house?
13        A.     Yes.
14        Q.    What did              remember about that?
15        A.    She recalls that he met Epstein.
16        Q.     What did she say about that?
17        A.     He met in the driveway.       There was a car that
18   Epstein was driving at the time and that he was showing to
19             And she recalls that               really liked the car, and
20   she had to hear about him talking about the car for several
21   days to weeks after that.
22        Q.     According to               did         ever meet any of
23   Epstein's employees?
24        A.     No.
25        Q.     When            arrived at Epstein's house for each
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1    appointment, what happened when she first arrived?
2        A.     She would arrive through the side door and
3   generally be greeted by someone.
4       Q.      Would that be in the kitchen?
5         A.     Yes.
6        Q.       Does she recall, at times, Maxwell being the
7   person who would greet her in the kitchen?
8        A.      Yes.
9        Q.     After being greeted in the kitchen, what would
10             do next?
11       A.     She would go upstairs and arrange the massage room
12   and the massage table.
13       Q.     Once            was in the massage room, what
14   happened during each appointment?
15       A.     Epstein would generally come out, he would get on
16   the table.    She would begin her massage.       During the massage
17   he would flip over and she would generally play with
18   nipples.    He would masturbate, he would touch her breasts
19   and buttocks, and she said that every instance ended with
20   Epstein ejaculating.
21       Q.      What would            be wearing during these
22   appointments?
23       A.     At first she just started wearing her underwear
24   but was told that she would make more money to be completely
25   nude, so she started getting totally nude.
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1        Q.    And so after her first few visits to Epstein's,
2    was she -- did it become              practice to be fully nude
3   during the massages?
4        A.    Yes.
5         Q.    On a few occasions during these massages did
6   Epstein touch             vagina?
7        A.    Yes.
8        Q.    On one occasion does            recall Epstein
9   touching her vagina with a vibrator?
10        A.    Yes.
11        Q.    And you mentioned that            recalled each
12   massage ended with Epstein ejaculating; so is it
13   recollection that every single massage she performed for
14   Epstein involved a sex act?
15        A.    Yes.
16        Q.    After each massage, what happened?
17        A.    Epstein would get up,            would get dressed;
18   she would get paid.    The money would generally be on the
19   table or on the sink, or she would go downstairs and be paid
20   by Maxwell.
21        Q.    How much did           recall being paid for each
22   massage?
23        A.    Three hundred dollars.
24        Q.    In what denomination?
25        A.    One hundred dollar bills.
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1        Q.     You mentioned that            would sometimes be
2   greeted by Maxwell when she arrived at Epstein's house.
3    Earlier on in her visits to Epstein's, would Maxwell engage
4             in conversation?
5         A.     Yes.
6         Q.    And then later on, after           started primarily
7    being the person to schedule these appointments, would
8    Maxwell still be present sometimes?
9        A.     Yes.
10        Q.    But during those later periods would Maxwell
11   primarily just say hello and not really have extended
12   conversations with
13        A.     Yes.
14        Q.     During the earlier period when            was going
15   over to Epstein's Palm Beach house, what types of
16   conversations does she recall having with Maxwell?
17        A.    She talked with Maxwell about her home life.         She
18   talked with Maxwell about her abuse that occurred when she
19   was younger.   She recalled Maxwell asking about her sexual
20   experiences that she's had.      She recalled Maxwell asking her
21   if she used a vibrator or a toy ever on herself.
22        Q.     Did she also recall conversations about travel?
23        A.     Yes.
24        Q.    I'd like to go through each of those topics that
25             recalled discussing.    First, what did          tell
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1   Maxwell about                 home life in response to Maxwell's
questions?
3          A.    She told her that she -- her mother was addicted
4   to drugs and that she had been molested several times as a
5   child.
6          Q.    Did she also tell Maxwell that the parents were
7   separated?
8          A.    Yes.
9          Q.    You also mentioned sexual topics coming up.        What
10   does               recall about the time or times when sexual
11   topics came up with Maxwell?
12          A.    Maxwell has asked her if she was sexually active.
13               had told her that she's currently sexually active
14   with her boyfriend.        Maxwell asked her if she'd ever used a
15   toy to pleasure herself, and she had said no.
16          Q.    Did            recall that, the same day that Maxwell
17   asked about whether she ever used a toy, was the day that
18   Epstein placed a vibrator on                    genitals during the
19   massage?
20          A.    Yes.
21          Q.    What did             recall about conversations with
22   Maxwell about travel?
23          A.    She recalls that on multiple occasions Maxwell
24   asked her if she wanted to travel, specifically, overseas.
25   She had told her that she was 14 years old and that her
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1    mother wouldn't let her.        Maxwell offered to get her a
2    passport so she would be able to travel.
3          Q.    When you said "she had told her that she was
4   14 years old," did you mean that                told Maxwell that
5                was 14 years old?
6           A.    Yes.
7          Q.     Does         recall that these conversations took
8    place when she was about 14 years old?
9           A.    Yes.
10          Q.     Does         recall Maxwell saying specifically
11   where Maxwell wanted              to travel with Epstein?
12          A.    No.
13          Q.     Did Epstein ever invite            to travel with
14   him?
15          A.    Yes.
16          Q.    What did           remember about that?
17          A.    They were similar conversations where she had
18   told -- he had asked her if she would like to travel and
19   said that                        had also travelled with him.     She
20   had told him that she was 14 and, likely, her mother
21   wouldn't let her travel.        He had also offered to get her
22   passport.
23          Q.     Did         ever actually travel with Maxwell or
24   Epstein?
25          A.    No.
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1       Q.     After           told Maxwell and Epstein that she
was 14 years old, did Maxwell still call her to schedule
3   massage appointments for Epstein?
4       A.      Yes.
5       Q.      Did         still see Maxwell at the Palm Beach
6    residence after telling Maxwell that she was 14 years old?
7        A.      Yes.
8       Q.      Did Maxwell ever see            naked?
9        A.     Yes.
10       Q.     In particular does            recall that there were
11   between one and three times when Maxwell saw her naked?
12       A.      Yes.
13       Q.      How did that happen, according to
14        A.    It happened in the massage room.
15       Q.     And was there one time, in particular, when
16             recalls Maxwell touching her while               was
17   naked?
18        A.     Yes.
19       Q.     What did           remember about that?
20       A.     She recalls being in the massage room undressing;
21   Maxwell complimented her body and then asked if her breasts
22   were real, at which point, she touched her breasts.
23       Q.     And when you say "she touched her breasts," do you
24   mean Maxwell touched               breasts?
25       A.      Yes.
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1         Q.    And on those occasions, just to be clear,
2    according to            why was she getting undressed in the
3   massage room when Maxwell was present?
4        A.    For getting prepared for the massage with
5    Jeffrey Epstein.
6         Q.    Other than during her first visit or two with
7              did          ever participate in massages with
8    Epstein during which another female was in the room?
9         A.    Yes.
10       4•     In particular does she recall two occasions when
11   Epstein brought another girl into the room?
12        A.    Yes.
13        Q.    Would you please describe for the grand jury what
14             recalled about one such occasion?
15        A.    She recalled that the girl looked like a model.
16   She recalls at one point during the massage Jeffrey Epstein
17   attempted to have sex with her; he slightly penetrated her
18   at least once or twice, that she can recall; she told him
19   no, at which point he began to have sex with the other
20   female and at the same time she was performing oral on
21
22        Q.    Now just to clarify some of the pronouns there.
23   You said that Epstein attempted to penetrate, or have sexual
24   intercourse, with her; do you mean that              recalls that
25   Epstein attempted to penetrate                vagina with his
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1   penis?
2        A.   Yes.
3        Q.   Does          recall Epstein attempting to do that
4   and actually inserting his penis into her vagina on one or
5    two occasions?
6         A.   Yes.
7        Q.   And in response, did             say no?
8         A.   Yes.
9         Q.   And in response to that did Epstein then engage in
10   sexual intercourse with the other girl?
11        A.   Yes.
12       4•    And at the same time was the other girl performing
13   oral sex on
14        A.   Yes.
15        Q.   Was there another instance where Epstein brought a
16   different girl into the room?
17        A.   Yes.
18        Q.   What did           remember happening during that
19   other instance?
20        A.   Similar instance where Epstein would have sex with
21   the other female at the same time while she was performing
22   oral on
23        Q.   So Epstein would have intercourse with the other
24   girl and the other girl would perform oral sex on
25        A.   Yes.
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1       Q.       Did          ever bring other girls to massage
2    Epstein?
3        A.      Yes.
4       Q.       Why did she do that?
5        A.     She was told she could earn more money.
6        Q.       Who told her, or asked her, to bring other girls?
7        A.      Both Jeffrey and Maxwell.
8        Q.       What, in particular, did they ask her to do?
9         A.      They asked if she could bring younger girls.
10       Q.       Did           in fact, bring multiple girls over to
11   Epstein's house?
12       A.       Yes.
13       Q.       Can she remember the name of every girl that she
14   brought over?
15       A.       No.
16       4•     Are there some examples of names that she
17   remembers of girls that                  brought over?
18       A.       Yes.
19       4•       What are some examples?
20       A.              (ph) and         •
21       Q.     According to              was          younger than
22
23       A.       Yes.
24       Q.     And according to                 was          about a year
25   older than
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1       A.      Yes.
2       Q.      When           brought these girls would Epstein
3   engage in sex acts, in the presence of both                and the
4   girls she had brought, during the massage?
5         A.     Yes.
6        Q.      After each massage would both            and the girl
7   get paid?
8        A.      Yes.
9        Q.      How much did           remember them getting paid?
10       A.      Three hundred dollars.
11       Q.      So did each,          and the girl, get $300?
12       A.      Yes.
13       Q.      Did         receive any gifts from Epstein?
14        A.     Yes.
15       Q.      What's an example of some gifts that she remembers
16   receiving from Epstein?
17       A.      Flowers, a book called "Massage for Dummies," and
18   Victoria's Secret underwear.
19       Q.      Does she recall receiving multiple packages of
20   Victoria's Secret lingerie?
21       A.      Yes.
22       Q.      Before she first received Victoria's Secret
23   lingerie, did Maxwell ask her for her address and her bra
24   size?
25       A.      Yes.
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1        Q.     How does           remember receiving packages
2    Victoria's Secret underwear?
3       A.     She recalls receiving them at her house in West
4   Palm Beach.
5        Q.     And how would they get to her house?
6         A.    Either FedEx or UPS.
7       Q.     What, if anything, does             remember about the
8    return address on those packages?
9        A.     She recalls that they stated they were from New
10   York.
11       Q.     Does she remember whose name was on the return
12   address?
13       A.     She recalls Jeffrey's and Maxwell's name.
14       Q.     What did           do with the money she made
15   massaging Epstein?
16       A.     She used it to purchase drugs.
17       Q.     Did she and her boyfriend then use those drugs?
18       A.     Yes.
19       Q.     Did          continue going to school after she met
20   Jeffrey Epstein?
21       A.     No.
22       Q.     About how old was she when she dropped out?
23       A.     About 14.
24       Q.     Was she in middle school when she dropped out?
25        A.    Yes.
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1       Q.     So did           ever attend high school?
2       A.     No.
3       Q.     In or about 2003 did              become pregnant with
4   her boyfriend
5        A.     Yes.
6        Q.     Did           continue to massage Epstein after she
7   became pregnant, until she began showing her pregnancy?
8        A.     Yes.
9        Q.      Did          give birth to her son in 2004, when
10             was about 17 years old?
11       A.     Yes.
12       Q.     After the birth of her son did
13   massage Epstein on a small number of occasions?
14       A.     Yes.
15       Q.     What did            tell you about that?
16       A.     She was doing it to -- excuse me -- support her
17   baby.
18       Q.     Was that because she needed the money?
19        A.    Yes.
20       Q.     Have you reviewed the proposed superseding
21   indictment marked Grand Jury Exhibit 6?
22       A.     It's not in front of me right now, but I have
23   reviewed it.
24       Q.     Have you reviewed the proposed superseding
25   indictment or would you like me to provide you with a copy?
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1       A.     Yes, I reviewed it.
2       Q.     Is         the individual referred to as
3   Minor Victim 4 in the proposed superseding indictment?
4        A.    Yes.
5        Q.     Before you began investigating Epstein and his
6    associates was there a prior investigation by a different
7   FBI office in Florida into Jeffrey Epstein?
8        A.     Yes.
9        Q.     During that investigation was              interviewer
10   in 2007?
11        A.    Yes.
12       Q.     Have you reviewed a report from that interview?
13        A.    Yes.
14       Q.     During that interview did              describe
15   providing numerous paid sexualized massages to Epstein at
16   his Palm Beach residence when she was underage?
17       A.     Yes.
18       Q.     Did         mention Maxwell at all during that
19   interview?
20       A.     No.
21       Q.     During your more recent interviews with her in
22   2021 did          explain why she did not mention Maxwell
23   during her 2007 interview?
24       A.     Yes.
25       Q.     What did she say about that?
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1        A.   She was not asked.
2        Q.   She was not asked about Maxwell?
3        A.   Correct.
4        Q.   Did she think that Maxwell was important to the
5    interview in 2007?
6         A.   No.
7        Q.   Did           sue Jeffrey Epstein in approximately
8    2008?
9         A.   Yes.
10        Q.   Was she deposed, as part of that law suit, in
11   2009?
12        A.   Yes.
13        Q.   Have you reviewed a transcript of that deposition?
14        A.   Yes.
15        Q.   During that deposition in 2009 did            state
16   that Maxwell was one of the people who would call her to
17   schedule massage appointments with Epstein?
18        A.   Yes.
19        Q.   Was           asked any other questions about
20   Maxwell, or any follow-up questions about Maxwell, during
21   that 2009 deposition?
22        A.   No.
23        Q.   After that deposition did the law suit settle?
24        A.   Yes.
25        Q.   During her more recent interviews did
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1    admit that she lied during her 2009 deposition?
2        A.     Yes.
3        Q.     And in particular, in her 2021 interviews did
4             tell you that after she stopped seeing Epstein she
5    began working for an escort service?
6         A.     Yes.
7        Q.     During her 2021 interviews did            admit that,
8    as part of that escort service, she engaged in paid sex acts
9    with men?
10        A.     Yes.
11        Q.     Now, during her 2009 deposition was           asked
12   about her time working for an escort service?
13        A.     Yes.
14        Q.     Did she lie and claim that she had engaged in no
15   sex acts and only non-sexual dates as part of that escort
16   service?
17        A.     Yes.
18        Q.     Did she explain why she lied during her
19   deposition?
20        A.     Yes.
21        Q.     What did she say about that?
22        A.     She was embarrassed.
23        Q.     Was she ashamed to admit that she had worked as a
24   prostitute, during her deposition?
25        A.     Yes.
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1         Q.   Has          struggled with drug addiction in the
2    years since her time with Epstein?
3        A.   Yes.
4        Q.   Did she, in particular, become addicted to cocaine
5    and crack cocaine?
6         A.   Yes.
7        Q.   Was she also in a car crash after which she was
8    prescribed opioids?
9         A.   Yes.
10        Q.   And did she become addicted to opioids?
11        A.   Yes.
12        Q.   Between the ages of 18 and 26 was              arrested
13   and convicted, on multiple times including misdemeanors and
14   felonies, for crimes arising out of her drug use, such as
15   drug possession and traffic violations?
16        A.   Yes.
17        Q.   Was her last felony an incident involving stolen
18   property when she pawned an Xbox that belonged to one of
19       's friends?
20        A.   Yes.
21        Q.   As a result of that conviction did             spend
22   several weeks in jail?
23        A.   Yes.
24        Q.   And was that the longest jail sentence she had
25   ever served?
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1       A.      Yes.
2       Q.     After           was released from that jail sentence
3   did she go into drug treatment and obtain mental health
4   treatment?
5       A.      Yes.
6        Q.      Was that several years ago?
7        A.     Yes.
8       Q.      What does          do now?
9        A.     She's a stay-at-home mother.
10       Q.      Is she married?
11       A.      Yes.
12       Q.      To someone other than
13        A.     Yes.
14       Q.      Does she have three young children with her
15   current husband?
16       A.      Yes.
17       Q.      Does he work while she takes care of the kids?
18       A.      Yes.
19       Q.      Has         received treatment for depression,
20   anxiety, PTSD, and schizophrenia, among other mental health
21   issues?
22        A.     Yes.
23       Q.     As for her schizophrenia, does that manifest in
24             hearing voices telling her that someone's going to
25   take her children away and hurt her children?
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1        A.     Yes.
2        Q.     Does         believe that that comes from a fear
3   that what happened to her as a child could happen to her
4   children?
5         A.     Yes.
6         Q.     Is         able to tell the difference between
7   those voices and reality?
8         A.     Yes.
9         Q.     Does she take medication to help her not hear
10   those voices?
11        A.     Yes.
12        Q.     Does         currently take multiple medications
13   to help her manage her drug addiction and her mental health
14   issues?
15        A.     Yes.
16        Q.     Do those include Methadone, Xanax, and medical
17   marijuana?
18        A.     Yes.
19        Q.     Is         currently, or has she ever, sued
20   Maxwell?
21        A.     No.
22        Q.     Does she have any plans to do so?
23        A.     No.
24        Q.     Have you identified evidence that corroborates
25               account of her time interacting with Epstein and
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1   Maxwell?
2         A.      Yes.
3         Q.    Did you interview                  ex-boyfriend,
4
5         A.      Yes.
6         Q.    What is the current nature of             and
7    relationship?
8         A.    They have a child in common, and they talk very
9   minimally just because they have a child in common.
10        Q.    So do they only speak when necessary to discuss
11   their teenage son?
12        A.      Yes.
13        Q.      According to                were he and
14   dating when               was about 14 years old and Shawn was
15   about 17 years old?
16        A.      Yes.
17        Q.    Did            remember that he,           and
18                       and                       would hang out around
19   that time?
20        A.      Yes.
21        Q.      What di(         recall about how              came to
22   meet Jeffrey Epstein?
23        A.      He recalls that the four of them were hanging out,
24   and they had mentioned --               and            had mentioned
25   to them that              could go to massage an old man and she
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1   would be paid money in return for that.
Q.    After that what does            remember happening?
3          A.     He recalls that             went to Epstein's house,
4   with                 to do the massage.
5           Q.     Did         recall bringing              to Epstein's
6   Palm Beach residence on multiple occasions?
7          A.     Yes.
8          Q.     Did         remember receiving phone calls to
9   schedule appointments for                 to massage Epstein?
10          A.     Yes.
11          Q.    What, if anything, did             remember about
12   meeting Jeffrey Epstein?
13          A.     He recalls meeting him at his house          Epstein's
14   house; he recalls that Epstein was there with his car, and
15   he was showing off his car; he recalls that Epstein was
16   flashy.
17          Q.    What, if anything, did             remember
18   saying about Maxwell?
19          A.     He recalls that             said Maxwell was rude and
20   nasty and that she was supposed to be teaching her how to do
21   massages.
22          Q.    What did           remember doing with the money that
23               received from Epstein?
24          A.     They purchased drugs;              and
25          Q.               and        would purchase drugs?
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1         A.    Yes.
2        Q.     What did         understand was happening when
3             was at Epstein's Palm Beach residence?
4        A.    He understood that she was going in there to give
5    massages to Epstein but felt that there may have also been
6    something else going on.
7       Q.     What did         remember about             bringing
8    other girls to Epstein's residence?
9         A.    He recalls that she had brought other girls.
10       Q.     Did he remember that both               and the other
11   girls would get paid for going to Epstein's house?
12        A.    Yes.
13        Q.    Turning to the next slide.      During the prior
14   investigation into Epstein did the other FBI office obtain
15   certain Federal Express records regarding Epstein?
16        A.    Yes.
17       Q.     Was there one in particular from October of 2002
18   that is up on the slide right now?
19        A.    Yes.
20       Q.     Would you please walk the grand jury through what
21   we see on this slide?
22        A.    Sure.   On the left-hand side it says, picked up
23   October 7th of 2002.    The sender's address is on the bottom.
24   In the middle it says, Jeffrey E. Epstein; his address is
25   457 Madison Avenue, New York, New York.       It was sent
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1    to -- the recipient being --
2
3       Q.    And is              name spelled              instead CL
4            in the recipient column?
5        A.     Yes.
6        Q.    And the 457 Madison Avenue address, is that in
7   Manhattan?
8        A.     Yes.
9        Q.     How old was           on October 7, 2002?
10       A.    Fifteen.
11       Q.     Have you interviewed a man named
12       A.     Yes.
13       Q.     Is that the same man about whom we read back
14   testimony from Special Agent           earlier today?
15       A.     Yes.
16       Q.     To remind the grand jury, did                   work for
17   Epstein in the 1990s and early 2000s at Epstein's Palm Beach
18   residence?
19       A.     Yes.
20       Q.     Did         recall meeting
21       A.     Yes.
22       Q.     What did          remember about how he first met
23
24       A.     He recalls driving Maxwell to a massage
25   appointment at Mar-a-Lago.     He was told to wait in the car
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1    while she got her massage.    When she was done she got in the
2    car and they started leaving the property.        At some point
3   during that drive, while still on the property, she was --
4   asked him to stop.    She got out of the car and approached a
5    female who was wearing a uniform at the time.       Maxwell spoke
6    to that female for about 20 minutes, and Mr.             could
7   not hear the conversation.    Maxwell then got back in the car
8    and drove back to Epstein's house.      Shortly thereafter,
9    later that day, that same girl arrived at the house.       She
10   soon became a regular at the house, and             learned --
11   later learned -- her name to be
12         Q.   And when         said that                     became
13   a regular at the house, what was              understanding of
14   why                    was coming to Epstein's Palm Beach
15   residence?
16         A.   To give Epstein massages.
17         Q.   Turning to the next slide.     Have you reviewed
18   flight records for Jeffrey Epstein's private jet?
19         A.   Yes.
20         Q.   Do those show multiple flights that
21                     was on when she was under the age of 18?
22         A.   Yes.
23         Q.   Was Maxwell present for some of those flights with
24
25         A.   Yes.
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1          Q.   Are two such flights reflected on this slide?
2          A.    Yes.
3          Q.   I'd like to ask you to please walk the grand jury
4   through those two flight records.
5           A.   On December 11th and December 14th of 2000, you
6    can see all the way at the bottom of the page, on the
7   left-hand side it's marked 11 and 14; the first flight goes
8    from PBI to Teterboro, which is Palm Beach in Florida and
9    Teterboro is in New Jersey.      On that flight was Epstein,
10   Maxwell, and                       among others.    The next
11   flight, on the 14th, goes from Teterboro to the
12   Virgin Islands.     On that flight is Epstein, Maxwell,
13               among others.
14          Q.   Based on your understanding of
15   date of birth, how old was               on these two flights?
16          A.   Seventeen.
17          Q.   Turning to the next slide.      Does this slide show
18   three additional flights that                        took with
19   Jeffrey Epstein and Ghislaine Maxwell when she was 17 years
20   old?
21          A.    Yes.
22          Q.    Would you please walk the grand jury through these
23   three flights?
24          A.   Sure.   The first flight is January 26, 2001.       On
25   that flight is Jeffrey Epstein, Maxwell, and
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1                        among others.     That was from Teterboro to
2    Palm Beach.
3              Down a little bit further there's another date
4   that appears to be January 28th of 2001, although the 8
5    seems like it's a little faded, but does appear to be late
6    January 2001.     On that flight is Jeffrey Epstein,
7   Ghislaine Maxwell, and                         among others.
8               And the last flight is the 30th of January, also
9    2001; this flight's had Jeffrey Epstein, Ghislaine Maxwell,
10   and                     on that flight.
11         Q.   Based on your review of flight records for
12   Jeffrey Epstein's private jet have you found multiple
13   additional flights in 2001 that                        took with
14   Epstein and Maxwell when she was still 17 years old?
15         A.   Yes.
16         Q.   Have you reviewed certain phone records from the
17   year 2004?
18         A.   Yes.
19         Q.   Did those phone records show that on at least two
20   occasions in April and May of 2004 an employee of Epstein'.
21   called              phone number?
22         A.   Yes.
23         Q.   Turning to the next slide.       During the prior
24   investigation of Epstein was there a search executed at
25   Epstein's Palm Beach residence in 2005 by the Palm Beach
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1   Police Department?
2          A.   Yes.
3          Q•   During that search did the police recover message
4   pads from the residence?
5           A.   Yes.
6           Q.   Would you please explain to the grand jury what
7   message pads are?
8           A.   Sure.   So message pads, in this particular
9    instance, were pads that Epstein kept next to each of his
10   phones in his residence.       If someone was to call, whoever
11   would answer that phone would jot down a note as to who the
12   person was that was calling, who they were asking for, the
13   time and date, and their phone numbers, and any specific
14   message they wanted to leave.
15          Q.   Have you reviewed the message pads that were
16   recovered from Jeffrey Epstein's Palm Beach residence in
17   2005?
18          A.   Yes.
19          Q.   Do those message pads include several messages
20   with               name and/or phone number on them?
21          A.   Yes.
22          Q.   Do those message-pad excerpts date between the
23   years 2003 and 2005?
24          A.   Yes.
25          Q.   Up on this slide right now, are those two examples
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1    of message-pad excerpts that reference
2        A.   Yes.
3        Q.   Would you please walk the grand jury through these
4   message pad excerpts?
5         A.   Sure.   The first one says the message is for
6    Mr. Epstein.   The date is 3/1/2003.
7        Q.   I'm sorry, I think you said 3/1, did you mean
8    3/11?
9         A.   I'm sorry.    It's a little faded.      3/11/2003.    The
10   message is from            and the phone number -- also a
11   little faded here -- but says,             .   The second message
12   says it's for JE, Jeffrey Epstein; the date is March 16,
13   2003; the message is from            ; same number as the
14   previous message is           .   The message on the bottom
15   says she wants to work.
16        Q.   And just to remind the grand jury, did
17   tell you that there were times when she would call to ask to
18   massage Epstein so that she could get more money for drugs?
19        A.   Yes.
20        Q.   Turning to the next slide.      Are these additional
21   message pad excerpts seized from Jeffrey Epstein's
22   Palm Beach residence in 2005?
23        A.   Yes.
24        Q.   Would you please walk the grand jury through
25   these?
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1         A.     Sure.   The first one on the left says the message
2    is for JE, Jeffrey Epstein.       It's from
3   There's -- the date is missing on this one, but it says the
4   time is 12:30.      The phone number is                 .    The one
5    on the right says the message is also, again, JE for
6    Jeffrey Epstein.     There's no date; the time is 3:15 p.m.
7   It's from                      , phone number               The
8    message states, ■       wants to work.
9         Q.     During the search in 2005 of Epstein's Palm Beach
10   residence were additional messages recovered that are nor
11   included on these slides?
12        A.     Yes.
13        Q.     Additionally, were multiple massage tables seize°
14   from the residence in 2005?
15        A.     Yes.
16        Q•     Was at least one of those tables manufactured
17   outside of the state of Florida?
18        A.     Yes.
19        Q.     Have you reviewed photographs and a video
20   recording from that 2005 search of the Palm Beach residence?
21        A.     Yes.
22        Q.     Would you please describe for the grand jury,
23   based on those photographs and that video, what the massage
24   room in the Palm Beach residence looked like?
25        A.     Sure.    It was basically a master bathroom.     There
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1    was glass doors which appear to go back into a shower.
2    There's a sink in the room; there is a couch in the room;
3   there's several door in the room, one of which leads into a
4   closet.   Inside of the closet on the walls, also on the
5    walls of the massage room, there were multiple photographs,
6    some of them being of nude women.
7        Q.    Was there also a massage table in that closet?
8         A.    Yes.   Photographed was a massage table inside of
9    the closet.
10        Q.    Have you told the grand jury everything you know
11   about this case, or have you merely answered the questions
12   that I've asked you?
13        A.    I've merely answered the questions.
14        Q.    When you testified about conversations you had
15   with others, or documents you reviewed, did you testify to
16   the exact words or just the substance?
17        A.    Just the substance.
18        Q.   And are you willing to return to the grand jury if
19   the grand jurors have additional questions for you?
20        A.   Of course.
21              MS.           Then with the Foreperson's permission
22   I'll ask that the witness please be excused.
23             FOREPERSON.     Yes, he may.
24              MS.           Thank you.
25             (Witness Excused)
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CERTIFICATE
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   April 5, 2021
Date
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