[0:05]This is a deposition of Mr. Darren Indyke conducted by the House Committee on Oversight
[0:13]and Government Reform under the authority granted to it pursuant to House Rule 10.
[0:19]Accordingly, House Rule 10 grants the Committee broad jurisdiction for the Committee to conduct
[0:24]investigations of any matter at any time.
[0:28]On January 7, 2026, the Committee voted to approve a motion directing the Chairman
[0:32]to authorize an issue of subpoena to you for a deposition.
[0:37]On January 23, 2026, Chairman Comer issued a subpoena for Mr. Indyke to appear today
[0:43]for a deposition in furtherance of the Committee's investigation into the actions and investigations
[0:49]of Mr. Jeffrey Epstein and Ms. Ghislaine Maxwell.
[0:53]I will enter the subpoena and corresponding cover letter as Exhibit 1.
[1:00]The Committee noticed the deposition for Mr. Indyke on March 4, 2026.
[1:05]I will enter the notice for this deposition as Exhibit 2.
[1:11]Can the witness please state his name and spell his last name for the record?
[1:15]Darren Indyke, I-N-D-Y-K-E.
[1:22]Thank you, Mr. Indyke.
[1:23]My name is Jack Emmer and I am the Chief Counsel for Investigations for Chairman
[1:27]Comer.
[1:28]Under the Committee on Oversight and Government Reform's rules, you are allowed to have
[1:32]a counsel present to advise you during this deposition.
[1:35]Do you have a counsel representing you in a personal capacity present with you today?
[1:41]I do.
[1:43]Will counsel please identify themselves for the record?
[1:47]Mark Weinstein from Hughes, Hubbard & Reed.
[1:50]Daniel Weiner, also from Hughes, Hubbard & Reed.
[1:53]Thank you.
[1:54]Now, starting with the majority staff, can the additional staff members please introduce
[1:58]themselves with their name, title, and affiliation?
[2:01]Billy Grant, Deputy Chief Counsel for Investigations for Chairman Comer.
[2:06]Peter Spector, Deputy Director of Oversight for Chairman Comer.
[2:09]Daniel Ashworth, General Counsel for Chairman Comer.
[2:12]Brian Giacchetti, Chief Counsel for Chairman Comer.
[2:15]Will Harness, Professional Staff and Deputy Chairman Comer.
[2:18]Ellison Toland, Counsel for Chairman Comer.
[2:21]Brittany Redknapp, Senior Counsel for Chairman Comer.
[2:24]Emily Feineroggen, Counsel for Chairman Comer.
[2:26]Will Pappu, Professional Staff and Deputy Chairman Comer.
[2:29]Jack Ferla, Counsel for Chairman Comer.
[2:31]Melvin Soto, Deputy Director for Chairman Comer.
[2:37]Thank you all.
[2:39]Mr. Indyke, before we begin, I would like to go over the ground rules for this deposition.
[2:44]The questioning will proceed in rounds.
[2:46]The majority will ask questions for an hour, and then the minority will have an opportunity
[2:50]to ask questions for an hour if they choose.
[2:54]To the extent members have questions for the witness, they will be propounded during their
[2:58]side's respective rounds.
[3:00]The clock will stop if you need to confer with counsel, your counsel is speaking,
[3:05]and when members or staff are speaking during the opposing side's rounds of questions.
[3:10]We will alternate back and forth until there are no more questions.
[3:13]Do you understand?
[3:14]Thank you.
[3:15]There is a court reporter taking down everything I say and everything you say
[3:19]to make a written record of the deposition.
[3:22]For the record to be clear, please wait until the staffer questioning you finishes each question
[3:27]before you begin your answer, and the staffer will wait until you finish your response
[3:32]before proceeding to the next question.
[3:34]Further, to ensure the court reporter can properly record this deposition, please
[3:39]speak clearly, concisely, and slowly.
[3:42]Also, the court reporter cannot record non-verbal answers such as nodding or
[3:46]shaking your head, so it is important that you answer each question with an audible verbal
[3:52]answer.
[3:53]Do you understand?
[3:54]I do.
[3:56]Exhibits may be entered into the record.
[3:57]Majority exhibits will be identified numerically.
[4:00]Minority exhibits will be identified alphabetically.
[4:03]Do you understand?
[4:04]I do.
[4:06]We want you to answer our questions in the most complete and truthful manner possible,
[4:10]so we will take our time.
[4:12]If you have any questions or do not fully understand the question, please let us
[4:15]know.
[4:16]We will attempt to clarify, add context to, or rephrase our questions.
[4:21]If we ask about specific conversations or events in the past, and you are unable
[4:25]to recall the exact words or details, you should testify to the substance of those
[4:30]conversations or events to the best of your recollection.
[4:34]If you recall only a part of a conversation or event, you should give us your best
[4:39]recollection of those events or parts of conversations that you do recall.
[4:44]Do you understand?
[4:45]I understand.
[4:46]You are required, by law, to answer questions from Congress truthfully.
[4:52]This also applies to questions posed by congressional staff in this
[4:56]deposition.
[4:57]Do you understand?
[4:58]I do.
[4:59]If at any time you knowingly make false statements, you could be subject to
[5:04]criminal prosecution, including but not limited to perjury.
[5:08]Do you understand?
[5:09]I do.
[5:11]This includes both knowingly providing false testimony, but also stating that
[5:15]you do not recall or remember something when, in fact, you do.
[5:19]Do you understand?
[5:20]I do.
[5:21]Furthermore, you cannot tell half-truths or exclude information necessary to
[5:26]make statements accurate.
[5:28]You are required to provide all information that would make your
[5:32]response truthful.
[5:34]A deliberate failure to disclose information can constitute a false statement.
[5:39]Do you understand?
[5:40]I do.
[5:41]Is there any reason you are unable to provide truthful testimony in today's
[5:45]interview?
[5:46]No.
[5:47]Please note, if you wish to assert a privilege over any statement today,
[5:51]that assertion must comply with the rules of the Committee on Oversight and
[5:54]Government Reform.
[5:56]Pursuant to that, Committee Rule 16C1 states, for the Chair to consider
[6:00]assertions of privilege over testimony or statements, witnesses or entities
[6:04]must clearly state the specific privilege being asserted, and the reason
[6:08]for the assertion on or before the scheduled date of testimony or appearance.
[6:14]For the purposes of this deposition, objections must be stated
[6:17]concisely in a non-argumentative and non-suggestive manner.
[6:23]If the witness refuses to answer a question to reserve a privilege,
[6:27]the Committee may seek a ruling from the Chair.
[6:30]If the Chair overrules any such objection, the witness shall be ordered
[6:34]to answer.
[6:35]If the witness continues to refuse to answer a question despite being
[6:39]ordered to do so, the witness may be subject to sanction.
[6:42]Do you understand?
[6:43]I do.
[6:44]Ordinarily, we take a five-minute break at the end of each hour
[6:48]questioning, but if you need a longer break or a break before that,
[6:52]please let us know, and we will be happy to accommodate.
[6:55]However, to the extent there is a pending question, we would ask that
[6:59]you finish answering the question before we take the break.
[7:02]Do you understand?
[7:03]I do.
[7:04]Finally, I will note for everyone here today that the contents of what we
[7:09]discuss in the deposition today is confidential under the House
[7:13]deposition regulation.
[7:14]Under the rules, the Chairman and ranking minority members shall
[7:17]consult before any release of testimony or transcripts, including portions
[7:22]thereof.
[7:23]This means it is a violation of House and Committee rules to disclose
[7:27]the contents of the deposition prior to its official release.
[7:33]For this reason, the marked exhibits that we will use today will remain with
[7:37]the court reporter so that they can go into the official transcript, and any
[7:41]copies of those exhibits will be kept at the table or returned to us when
[7:45]we finish.
[7:46]Can that reporter please swear in the witness?
[7:49]Here is your right hand.
[7:51]Do you solemnly declare or affirm under penalty of perjury that the
[7:56]testimony you give today will be the truth, the whole truth, and nothing
[7:58]but the truth?
[7:59]I do.
[8:02]Do you have any questions before we begin?
[8:05]I do not.
[8:07]We understand that you have an opening statement that you would like to read
[8:09]into the record.
[8:10]I do, by the way.
[8:13]You may.
[8:14]Thank you.
[8:15]Good morning, everyone.
[8:21]I'd like to thank the Committee for working with the Epstein
[8:23]estate over the past six-plus months.
[8:26]As a co-executive of the estate, I have done my very best to
[8:30]cooperate with the Committee and to respond to the Committee's request
[8:33]for documents, photographs, and other information relating to Jeffrey
[8:37]Epstein.
[8:38]As you know, the estate produced voluminous materials in response to
[8:43]the Committee subpoena and communicated regularly with both the
[8:46]Committee's majority and minority staffs on the timing, scope, and
[8:50]content of the estate's responses.
[8:53]My appearance here today, as with my co-executive's testimony
[8:57]before the Committee last week, represents our continuing cooperation
[9:01]with the Committee's efforts to investigate matters regarding Mr.
[9:04]Epstein.
[9:05]In addition, since we were appointed in 2019 by the United States Virgin
[9:10]Islands Probate Court as co-executives of Mr. Epstein's estate, we have fully
[9:14]cooperated with the U.S. Department of Justice's investigation of
[9:18]Epstein-related matters.
[9:20]I'd also like to note the extensive efforts that my co-executor and I have
[9:24]made to address the wrongs committed by Mr. Epstein during his lifetime.
[9:30]At our direction, the estate initiated, developed, and funded the
[9:34]Epstein Victims' Compensation Program, the first of its kind established
[9:38]by an estate, which provided a private, voluntary, and non-confrontational
[9:43]means to compensate women who suffered sexual abuse by Mr. Epstein.
[9:49]Independently administered by preeminent figures in the field of
[9:51]victims' compensation, the EVCP awarded more than $121 million to
[9:58]136 women, all of which the estate funded, pursuant to our express
[10:03]direction that, one, there was to be no cap on monies awarded, either
[10:07]individually or in the aggregate, and, two, even women whose claims
[10:12]were time-bared or who had previously signed releases could participate.
[10:17]The estate has also directly settled claims by an additional 59 women
[10:21]for a total of more than $48 million, including the recently
[10:26]proposed settlement in a punitive class action lawsuit filed in 2024
[10:31]on behalf of all women abused by Mr. Epstein, a settlement that
[10:35]the court preliminary approved earlier this month.
[10:37]My co-executor and I have authorized payment by the Epstein
[10:41]estate of more than $200 million to women who assert they were
[10:45]abused or trafficked by Mr. Epstein.
[10:49]Let me be clear.
[10:51]I had no knowledge whatsoever of Jeffrey Epstein's wrongdoings.
[10:55]My complete lack of involvement in that misconduct is a matter of record.
[11:00]Not a single woman has ever accused me of committing sexual abuse or
[11:04]witnessing sexual abuse, nor claimed at any time that she or
[11:08]anyone else reported to me any allegation of Mr. Epstein's abuse.
[11:12]I did not socialize with Epstein, and I reject as categorically false
[11:17]any suggestion that I knowingly facilitated or assisted Mr.
[11:20]Epstein in his sexual abuse or trafficking of women, or
[11:24]that I was aware of his actions while I provided legal services to him.
[11:29]Far from being Mr. Epstein's lieutenant or chief of staff,
[11:32]as I have been incorrectly described by plaintiff's lawyers and
[11:36]uninformed journalists, I was one of many attorneys who Mr.
[11:40]Epstein regularly consulted, including such noted luminaries as Kenneth Starr,
[11:45]for entirely legitimate purposes.
[11:48]My primary role was to provide corporate, transactional, and
[11:52]general legal services to Mr. Epstein and his companies, and yes, I did so.
[11:58]The press and plaintiff's council have mischaracterized cash withdrawals I made
[12:01]from Mr. Epstein's bank accounts from 2013 to 2017.
[12:06]Entirely ignored in that reporting is the fact that the bank involved knew
[12:10]full well that these accounts belonged to Mr. Epstein.
[12:13]Neither I nor he made any effort to disguise his name or identity.
[12:18]And as part of its standard policy,
[12:20]the bank itself imposed a $7,500 limit on daily cash withdrawals.
[12:26]I was not attempting to structure such withdrawals to avoid federal
[12:29]reporting requirements.
[12:30]Quite the contrary, I simply sought to comply with the bank's internal
[12:34]requirements and limits with the bank's full knowledge.
[12:39]It is undisputed that during this time,
[12:40]Mr. Epstein had difficulty assessing credit cards from major banks.
[12:44]Instead, he and his staff required cash to pay for a wide variety of expenses,
[12:50]including maintenance, repairs, and daily household needs for
[12:54]his residential properties in New York, Florida, New Mexico,
[12:58]Paris, and the USVI, as well as meals, gifts,
[13:02]fortuities, and fuel for his private aircraft.
[13:06]For a person of Mr. Epstein's financial position with five
[13:09]multi-million-dollar residences, staffed by dozens of employees,
[13:14]and with an extensive travel itinerary, it did not strike me as unusual that
[13:18]Mr. Epstein's business, household, and
[13:21]personal needs required large amounts of cash on a regular basis.
[13:26]I never believed that the cash I withdrew from Mr. Epstein and
[13:29]his staff was used by Mr. Epstein or his staff for any improper purposes.
[13:36]There have also been allegations of my supposed involvement in
[13:39]facilitating forced or sham marriages between women in Mr. Epstein's life.
[13:44]Those allegations, too, are 100% untrue.
[13:47]I did not arrange, assist, or
[13:49]facilitate any marriages between acquaintances of Mr. Epstein.
[13:53]Nor was I aware in advance that such marriages took place.
[13:57]Same-sex marriage has been legal in New York since 2011
[14:01]with this passage of the Marriage Equality Act.
[14:04]I did not consider it appropriate to interrogate anyone as to the reasons for
[14:08]their decisions to marry or the bona fides of their relationships.
[14:14]I don't mean in any way to condone or
[14:16]excuse Mr. Epstein's reprehensible conduct.
[14:19]Quite the opposite, I condemn it wholeheartedly.
[14:23]Had I known that he was abusing or trafficking women,
[14:26]I would have quit working for him at once and severed all ties to him.
[14:30]The truth is that I did not know what Mr.
[14:33]Epstein did after hours, what he did behind closed doors, and
[14:37]what he did in places where I was not present.
[14:40]I first met Epstein in 1996, when he was already a highly successful businessman.
[14:46]After he pled guilty in 2008 to procuring a person under the age of 18 for
[14:50]prostitution, Mr.
[14:52]Epstein appeared to me to be devastated and extremely contrite.
[14:55]He was adamant that he had no idea that anyone involved was underage, and
[15:00]personally assured me that he would never again let himself be in that position.
[15:04]I believed him, and I made the mistake of believing that Mr.
[15:08]Epstein would not again commit a crime.
[15:11]I deeply regret doing so.
[15:14]Most importantly, I feel horrible for the women whom Mr. Epstein abused.
[15:20]While my professional association with Jeffrey Epstein has subjected my
[15:23]family to death threats and malicious personal attacks,
[15:26]I don't expect the members of the committee or
[15:28]of the public to feel sympathy for me.
[15:31]But I am left trying to explain what many people who knew Jeffrey Epstein
[15:34]have noted after his death.
[15:36]He led two entirely separate lives, his professional one and the other,
[15:40]a private, personal one that caused many others to suffer.
[15:45]That I did not know what my client did in his private life may be difficult
[15:49]for some to believe, but it's true.
[15:53]Thank you.
[15:55]Starting with the majority, may all individuals, members, and
[16:00]staff who have since joined us since the beginning,
[16:03]please announce themselves for the record.
[16:05]James Koller, chairman of Kentucky.
[16:07]Andy Bigg Scott from Arizona 5.
[16:10]William Timmons, Southerhouse 4th Congressional District.
[16:15]I, Dave Mann, about 147.
[16:18]James Launford, South Virginia 11.
[16:22]Thank you.
[16:23]The time reads 10.22, and the majority's time will begin now.
[16:29]Mr. Indyke, let's begin by discussing your education and experience.
[16:34]Where did you attend undergraduate school?
[16:36]Colgate University.
[16:38]And what degree did you graduate with?
[16:40]A degree in education and economics.
[16:42]What year did you graduate?
[16:43]1986.
[16:45]And where did you attend law school?
[16:48]Cornell Law School.
[16:49]And when did you graduate law school?
[16:52]1991.
[16:54]When were you admitted to practice law?
[16:57]1992.
[16:58]In what states were you admitted?
[17:00]New York, initially.
[17:03]Where have you since been admitted?
[17:05]In 2019, I was admitted to practice law in the state of Florida.
[17:10]Is your license currently in good standing?
[17:14]I believe my license is in both New York and Florida are in good stand.
[17:17]Can you briefly go through your professional career up until now?
[17:22]Sure.
[17:25]When I graduated Cornell Law School, I worked as first a clerk and
[17:31]then as an associate for the law firm of Golden Wachtel.
[17:35]I did that until, I think it was 1994.
[17:41]In 1995, I joined the law firm Greenberg Charg in New York City.
[17:47]I worked there until sometime in 1996, towards the beginning of 1996.
[17:52]At which point, I was asked by someone who was a former partner
[17:58]at Golden Wachtel to go work for him and with him to represent
[18:04]Jeffrey Epstein and his company.
[18:09]And since then, I have been working to represent primarily
[18:16]Jeffrey Epstein, both as an employee and then subsequently,
[18:24]in my capacity as a law firm, my own law firm.
[18:30]Prior to your employment with Mr. Epstein, what areas of law did you practice?
[18:35]Corporate securities and trademark law.
[18:41]When did you first meet Jeffrey Epstein?
[18:46]Sometime in 1996, towards the beginning of 1996.
[18:57]And Mr. Ndike, I understand that you're hard of hearing, so
[19:00]we're going to try to speak up.
[19:02]But if you could also speak up as well for everyone in the room.
[19:06]Sure.
[19:08]So let's begin again.
[19:09]When did you first meet Jeffrey Epstein?
[19:12]It was, I believe, towards the beginning of 1996.
[19:17]Where did you meet him?
[19:19]At his office in New York City.
[19:23]And why did you meet him at that time?
[19:27]Prior to my meeting Mr. Epstein, the partner that I worked for at
[19:31]Golden Wachtel had asked me to come work with him to represent
[19:38]Mr. Epstein, and as part of me doing that,
[19:45]he wanted me to meet Mr. Epstein in his office.
[19:48]So I did so.
[19:49]And for the record, I miss this, who else was present during this meeting?
[19:57]I don't recall, it was many years ago, that partner may have been there.
[20:05]So it would have been him and Mr. Epstein, I think.
[20:10]I don't recall anybody else.
[20:12]And what did you discuss with Mr. Epstein at this time?
[20:18]I can't recall specifically, but basically,
[20:23]he asked me questions about my background, the corporate and
[20:27]securities background, about the work I did at Golden Wachtel and
[20:30]the work I did at Greenberg Charg, told me I'd be doing similar work for him.
[20:37]Prior to meeting Mr. Epstein, what did you know about him?
[20:42]Very little.
[20:45]When I worked at Golden Wachtel,
[20:46]I understood that he was a client of Golden Wachtel.
[20:52]And I understood that the partner that I worked for
[20:57]at Golden Wachtel had done some work with him along with one of the name
[21:00]partners, Bob Gold, but that's the extent of what I knew about him.
[21:07]And what you testified to was all related to his business.
[21:11]Did he have any reputation outside of his business as it related to young
[21:16]women or girls at this time?
[21:17]Not that I knew of.
[21:22]What were your first impressions of Mr. Epstein?
[21:26]I was slightly intimidated because he was explained to me to be
[21:31]a very wealthy man.
[21:32]I was not very wealthy and I was very young at the time.
[21:40]And he was explained to me to be a very successful business man.
[21:44]My impressions for him was that he was no nonsense.
[21:48]He seemed pleasant enough.
[21:52]Nothing more than that.
[21:55]What did you understand his job to be at this time?
[21:59]I understood that I would be providing support and assistance to the partner
[22:04]that brought me in, in connection with representing Mr.
[22:09]Epstein's business interests.
[22:11]And you mentioned that...
[22:13]I think, Jack, could you ask what did you understand?
[22:15]His job to be or your job to be?
[22:18]Mr. Epstein's job.
[22:20]Oh, I'm sorry.
[22:21]Forgive me.
[22:23]Mr. Epstein's job, my understanding was that he was a financial consultant.
[22:29]For a wealthy individual.
[22:34]Did you know who his clients were at this time?
[22:38]No.
[22:43]Just because you mean before he took the job?
[22:45]Correct.
[22:50]We've had a member join.
[22:56]Mr. Indyk, recognizing that we'll discuss more specifics later,
[23:00]can you briefly describe the nature and extent of your relationship with Mr.
[23:03]Epstein?
[23:05]I was one of Mr.
[23:07]Epstein's many attorney.
[23:10]My goal, my goal, my role was primarily a role as a transactional corporate and
[23:19]transactional attorney.
[23:22]My role was to review documents, summarize documents, analyze documents,
[23:31]critique documents, draft documents, in a wide variety of areas.
[23:41]Investment documents, private placement memorandum,
[23:49]subscription agreements, option agreements, warrant agreements.
[23:56]Let's see what else.
[23:58]Registration rights agreements, stock purchase agreements.
[24:03]Rights of first refusal agreements.
[24:05]All of those and the kind of side letters for investments.
[24:09]All of those in the investment field.
[24:13]There were times when he would do some trading and
[24:20]my role was to review the trading confirmations.
[24:24]And to the extent there were documents required as a precursor to the trading
[24:28]like interest swap agreements, things like that,
[24:30]I would review the interest swap agreements to the extent that I had any
[24:33]comments on those, I would give my comments on those agreements.
[24:40]If Epstein was going to buy or sell a business,
[24:46]there were times when I would be required to draft basic business
[24:51]agreements or letters of intent or if he was or review a purchase
[24:56]agreement or a sale agreement and then critique it and
[25:00]summarize it and provide any evaluation on it.
[25:06]Epstein had aircraft and his clients had aircraft.
[25:12]I was involved as an attorney in connection with the acquisition and
[25:18]sale of aircraft, fixed wing aircraft, helicopters,
[25:22]rotocrafts, both new builds from manufacturers like Sikorsky and
[25:26]sometimes when they were resales of the aircraft.
[25:30]Also, there was lots of real estate that was being acquired and
[25:33]sold during this time.
[25:35]So I would work with local council.
[25:44]If it wasn't in New York, for example, I would work, and sometimes even if it
[25:48]was, I would work with local real estate council in the acquisition or
[25:52]sale of real estate, anything from large acreage branches to islands,
[26:01]to townhouses, to apartments, to homes, any number of parcels of real estate.
[26:11]In connection with some of the real estate that was acquired, there was a
[26:15]lot of construction going on during the course of my representation.
[26:18]And that construction would require architects in design.
[26:22]So I would review AIA architectural and design agreements, again,
[26:26]summarize, critique, evaluate.
[26:30]I would review proposals, just make sure that the proposals for any
[26:36]particular building or design were incorporated, all of what I understood
[26:42]to be the roles or the program for the building that was to be done.
[26:50]There was construction management agreements that had to be reviewed,
[26:54]general contractor agreements that had to be reviewed.
[26:56]Sometimes liens would come up.
[26:58]So all of those things would have to be reviewed.
[27:03]From time to time when a new asset like an aircraft or a helicopter or even a
[27:14]large boat would be acquired, a new entity would be formed for that asset
[27:24]because that asset was a large, tended to be as an aircraft.
[27:29]Aircrafts could fall out of the sky.
[27:31]They could cause serious damage.
[27:32]So it's corporate law 101 to make sure that when you have a liability type asset,
[27:40]you put that asset in a separate entity so other assets held by the person
[27:47]can't be subject to the liability that was created by that asset.
[27:51]The same holds true for, again, it's kind of normal operating procedure,
[27:55]particularly for people in high net worth situations when you would take on a new
[28:01]investment or there would be an investment program,
[28:04]you would form a separate entity for that investment program.
[28:08]For new businesses, because you didn't want to mix a new business with an old
[28:12]business, you would form an entity for that new business.
[28:17]So part of what I did is either if it was some place in the jurisdiction where
[28:25]I was admitted and I knew of a corporate service company to do it,
[28:28]I would have a corporate service company form the entity.
[28:34]If not, I would have the local attorney do the same.
[28:37]So we did those things.
[28:41]Just kind of the types of things sometimes are very, very complex.
[28:47]There was, just to give you an example, there was a project that required
[28:52]connecting one of Epstein's Island's, you know, because you had two,
[28:58]that island to the St. Thomas mainland, and that required the manufacturer of a
[29:04]15 KB cable with fiber optic capabilities by this Italian manufacturer.
[29:09]So I would have to work on that agreement with the manufacturer.
[29:14]And then we'd have to do, I'd have to work on a separate agreement for
[29:20]the installation of that cable across the span from St. Thomas mainland to the island.
[29:28]And then you'd have to work on the local to step down the cable, you know,
[29:33]all the work that the electrical contractors had to do to connect the cable to the island.
[29:39]And then there was also permitting that I had to work with local council who
[29:42]handled the permitting and local environmental consultants to do the
[29:48]permitting to lay the cable on the ocean bedside.
[29:51]So lots of different things like that.
[29:54]It was, yes.
[29:58]I just have a couple of questions related to the number of attorneys.
[30:03]You mentioned there were a number of attorneys working in-house essentially for
[30:08]Mr. Epstein, is that correct?
[30:09]No, it was a number of attorneys that Mr. Epstein engaged.
[30:14]Okay, so how many were actually working in-house?
[30:18]At which time, sir?
[30:20]Give me an example, early on.
[30:22]Early on, three attorneys.
[30:25]And then as time went on?
[30:28]Two attorneys.
[30:29]And then ultimately, nobody was working in-house.
[30:34]Ultimately, he was using outside counsel, including me as outside counsel,
[30:40]and other attorneys as outside counsel.
[30:42]When you had the three attorneys, are you one of those three?
[30:45]I was one of the three attorneys.
[30:46]You got down to two, obviously, you were one of them.
[30:48]I was still, yes, one of the attorneys there.
[30:49]Okay, and then you continued on until?
[30:53]I continued on with the other attorney.
[30:58]I was there, but the other attorney formed an entity to serve Epstein and
[31:09]other clients, and I worked for that entity, and I was a junior member of
[31:13]that entity.
[31:15]And then ultimately, I formed my own law firm.
[31:19]Did you have any associates in that law firm or partners?
[31:22]No.
[31:23]You were a sole provider?
[31:24]I was.
[31:27]Sure.
[31:28]We've had more members and staff join.
[31:30]Can they please announce themselves for the record?
[31:33]Sure.
[31:34]Robert Garcia, I'm the ranking member for Oversight Democrats.
[31:37]Rob Connick, California 17th.
[31:44]Gassman, sorry.
[31:45]Aaron Osberg.
[31:51]I want to stick with asking general questions to start.
[31:54]So during the course of your representing Mr. Epstein, how often did you
[31:59]communicate with him?
[32:02]Towards the beginning, infrequently.
[32:05]I mean, I saw him from time to time.
[32:08]I spoke to him from time to time, but mostly his communications were with
[32:12]the partner that I worked with, and then the partner that I worked with
[32:16]would speak to me about assignments that I had specifically.
[32:20]Over time, I would have some interactions with him.
[32:26]I would get direct assignments from Mr. Epstein.
[32:29]And you mentioned the partner that's the same partner you referenced before.
[32:32]Yeah, it's the partner who kind of asked me to come and join him
[32:36]representing Mr. Epstein.
[32:37]For the record, what was his name?
[32:38]His name was Jeffrey Shantz.
[32:40]And how would you typically communicate with Epstein?
[32:48]At which time?
[32:50]During the course of your relationship.
[32:52]OK, so kind of multifaceted.
[32:58]Sometimes I would get messages.
[33:02]Sometimes I would get a communication through the partner.
[33:11]Sometimes he would be in the office, and I would meet with him for two
[33:16]minutes, not a lot of face time, and get a specific assignment.
[33:23]And then sometimes I would get a message from his assistant saying
[33:28]something that Epstein wanted from me.
[33:31]And towards the later end, I would meet with him when he no longer
[33:38]had an office in New York.
[33:40]Towards the later end, I would meet with him.
[33:47]I would meet with him on the ground floor in the dining room of his residence.
[33:55]How often would you meet with him at the residence?
[33:59]It really depends when.
[34:01]So towards the beginning, not at all.
[34:06]As time went on, once a month, sometimes twice a month.
[34:15]If he was in town and there was a transaction going on,
[34:19]it could have been more, but typically it was about twice a month.
[34:23]How long would your meetings last when you would visit his residence?
[34:30]Typically an hour or so, maybe two most.
[34:35]Who typically would be present?
[34:43]There was no kind of typical thing about who would be present.
[34:49]It really depended on the transaction and the specific matter that was
[34:54]or the matters that I was meeting with him about.
[34:58]And I can hear you just fine, but there's a lot of people in the room that are
[35:02]struggling to hear you, so however much you can speak of, it's very helpful.
[35:07]Yes.
[35:07]But I just want to focus on who was present.
[35:11]There are women that have been identified and deemed as assistants of Mr. Epstein.
[35:15]Do you recall them being present at these meetings?
[35:19]I recall women coming into the meeting, delivering a message to him,
[35:26]sometimes bringing some food to him.
[35:30]But generally, his personal assistants were not in the meetings.
[35:36]And you mentioned that early on you'd have meetings at your office,
[35:42]and then it seemed that it became more common that you'd meet at the residence.
[35:46]When did this shift occur?
[35:48]I think it was 1998 when Mr. Epstein moved his residents,
[35:58]his primary residents, to the U.S. Virgin Islands and his business to the U.S.
[36:03]Virgin Islands.
[36:05]So he no longer maintained an office in New York.
[36:08]And so when he came to New York, the requirement was to meet at his residence.
[36:20]I'm going to ask you a general question here.
[36:23]What were the nature of your communications with Mr. Epstein?
[36:28]Can you rephrase the question?
[36:29]What were the nature of your communications with Mr. Epstein?
[36:37]I'm trying to understand.
[36:38]That's very general, and I don't really know.
[36:41]Were the nature of your communications always related to the furnishing of legal services?
[36:47]Yes.
[36:49]So for the record, did you ever have any communications with Mr. Epstein
[36:53]related to young women or girls?
[36:55]No, absolutely not.
[37:03]How would you characterize your relationship with Mr. Epstein?
[37:08]It was strictly a business relationship, strictly a legal relationship.
[37:12]For the record, at any point, did you consider Mr. Epstein to be a friend?
[37:17]No.
[37:18]Did you ever spend time with Mr. Epstein apart from your duties as his attorney?
[37:23]I never socialized with Mr. Epstein.
[37:25]I never spent any time with Mr. Epstein other than when I was there for a status
[37:30]report or a legal project for Mr. Epstein.
[37:34]Did you ever consider Epstein to be a mentor?
[37:38]I did initially, and I could tell you a little story about that.
[37:43]When I first started working for Epstein, I got this assignment.
[37:51]I can't remember the transaction that I was working on.
[37:55]But I got this agreement, and he told me I needed to get it reviewed and critiqued.
[38:03]And I mark it up.
[38:04]It's the word that they use.
[38:05]Mark it up and give me your comments to it.
[38:09]I think I had 24 hours to do it.
[38:12]So I went back to my office, spent a very long time in my office,
[38:17]probably 11 o'clock, 12 o'clock that night, marking the thing up.
[38:21]And when I gave it to him, it was full of red, completely red.
[38:24]And I thought I had done a fabulous job in marking up an agreement and
[38:27]showing all the ways the agreement was defective.
[38:31]When he looked at it, kind of looked at it and said,
[38:33]well, what am I supposed to do with this?
[38:35]So I have a transaction that I have to get done within the next week.
[38:40]This is never going to, first of all, I don't know what's real,
[38:43]what's not real here, what's important, what's not important here.
[38:46]This, I can never get a transaction done if this is what I have to do.
[38:49]So now take this back and go find me the 10 most important things and
[38:53]rank them in order of importance to me.
[38:57]And I learned a huge lesson from that.
[39:00]And he taught me about being a practical lawyer, not just a lawyer
[39:05]that's finding every possible theoretical kind of loophole in the agreement.
[39:13]So in that respect, I thought he was very helpful.
[39:19]And so that's, and he had other kind of advice to me like that.
[39:24]Those types of things in being a lawyer to, don't guess at things that I don't know.
[39:30]Tell them what I don't know, tell them what I do know.
[39:33]And if I don't know, tell them I don't know.
[39:35]Those are the types of things that he taught me to do as a lawyer,
[39:40]which were helpful to other people that I was working with as a lawyer.
[39:46]Mr. Indy, I mean, that's helpful advice.
[39:50]Don't be just technically proficient to help facilitate the deal by itself.
[39:56]When you were working with him, you never sat down and had a drink.
[40:02]Never sat down and smoked a cigar with him.
[40:05]No, never.
[40:06]Never.
[40:07]Two things, he doesn't drink, doesn't smoke.
[40:10]But that wasn't our relationship.
[40:12]He didn't ever say come along to have a cocktail party after work, come on.
[40:17]Nothing like that.
[40:18]He was never invited to a single dinner party that he hadn't had a few.
[40:22]Thank you.
[40:33]Did you ever ask Mr. Ebsenian for personal favors?
[40:40]Let's see how to answer that question.
[40:42]I asked him for help when I was, I think it's my first year or so.
[40:50]Sorry, my first year or so when I worked for him,
[40:54]I don't remember the exact time period.
[40:58]My wife and I were having fertility issues.
[41:03]And infertility treatments were quite expensive and they weren't covered by insurance.
[41:11]So I had asked him if it was possible for me to forego the insurance.
[41:21]And in lieu of the amount of money that he was paying for insurance at the time,
[41:27]if I could take that money and apply it towards the cost of infertility treatments.
[41:33]And at that time, his response to me was absolutely not.
[41:39]You should keep your medical insurance and I will pay for your infertility.
[41:44]Subsequent to that, it didn't work.
[41:49]And it didn't work, I think, four other times.
[41:54]Subsequent to that, without me having to ask, he would tell me,
[41:57]when are we doing the next one?
[41:59]And so Ebsenian paid for all of our infertility treatments
[42:05]until we were able to conceive.
[42:10]This time I'd like to introduce will be marked as Majority Exhibit 3.
[42:17]And this is a letter sent in 2008 by Mr. Ebsenian's criminal defense lawyers
[42:21]to prosecutors in Florida when Ebsenian was under investigations
[42:25]for crimes committed against minors.
[42:27]This is a compilation of statements from various employees of Mr. Ebsenian,
[42:31]all attesting to his good character.
[42:36]This document is based on EFTA 2857458.
[42:44]And I would like to direct your attention to page 13.
[42:48]We're specifically looking at the bottom and page 14.
[42:51]And I will give you a moment to review.
[42:53]So, page 13.
[43:07]Thank you.
[44:13]Okay.
[44:17]And for the record, we're reviewing the italicized portion.
[44:22]Did you write this, Mr. Indyk?
[44:26]I believe I did.
[44:27]And why did you contribute a statement for this filing?
[44:41]We'll see what this is for.
[44:52]I believe I was asked by defense counsel to contribute a statement for him.
[45:03]So, there's a part where you mentioned that Mr. Ebsenian had provided
[45:06]emotional and financial support.
[45:09]Is that in reference to what you previously described as help
[45:14]for infertility issues?
[45:16]Yes.
[45:18]And for the record, again, why did Jeffrey Ebsenian offer
[45:22]to pay for these services?
[45:26]I can't tell you what was in his own mind.
[45:28]I can tell you my perception was that he was being generous to me.
[45:33]He didn't really know me very long.
[45:35]And there was no kind of obvious benefit to him at that stage
[45:40]in my career with him.
[45:42]So, I guess he was being generous.
[45:48]I will say this, that, you know, in the years that followed,
[45:53]he did this kind of thing for other employees, friends, acquaintances.
[46:01]He appeared to be generous.
[46:04]He appeared to understand that his money could do good things,
[46:08]and he appeared to use his money to do things like that for people.
[46:12]Did he provide you any other support besides the infertility or support?
[46:20]Can you be more specific in terms of a time frame?
[46:23]Well, we're looking at this character reference around this time, 2008.
[46:31]No, but, you know, that was a big deal, obviously.
[46:36]It was a very difficult time for my wife and I,
[46:39]and it was very meaningful to me to have that support.
[46:46]We've had another member of Congress join.
[46:48]Can she please identify herself for the record?
[46:52]And Congresswoman Melanie Sandsbury from New Mexico.
[46:58]Mr. Indyke.
[46:59]Yes.
[47:00]It's a poignant letter that you wrote here.
[47:04]Did you see in the whole packet that was submitted
[47:07]that Mr. Epstein and the court was submitted?
[47:13]I don't recall.
[47:15]Were you aware of what the charges were pending
[47:20]at the time that you wrote your statement?
[47:23]I'm trying to remember when this statement was written.
[47:30]It was kind of fluid at that time.
[47:32]Well, you knew that there was some kind of criminal allegation
[47:36]against him, which is why there was a criminal defense attorney
[47:39]that was asking you to right the left, right?
[47:41]Yes, there were criminal allegations, again.
[47:43]Any other allegations?
[47:48]Again, it depends at what time we're talking about.
[47:53]My understanding...
[47:54]Mr. Indyke, can you please speak up for the mic?
[47:56]I'm sorry.
[47:57]I'm sorry, Mr. Indyke.
[47:57]No, no, my apologies.
[47:59]I'm sorry I'm not speaking well enough.
[48:01]My understanding, basically,
[48:03]that the allegations against him at the time,
[48:06]I think at the time that this was going on,
[48:08]forgive me, it was a while ago,
[48:11]but I think the allegations at that time,
[48:14]this is the state investigation in Palm Beach,
[48:18]were that there were massages at his house.
[48:22]Some of those massages wound up sexual in nature,
[48:28]and that at times it wound up being the case
[48:34]that there were some underage women there in the massages.
[48:40]So you understood that,
[48:42]that those were the allegations
[48:44]or the charges at the time you wrote your letter?
[48:49]I did understand that those were the allegations,
[48:51]but if I could talk a little bit more about that,
[48:54]I'd like to, if that's okay.
[48:56]I'm sure they're gonna get into that.
[48:58]I just wanna ask one other question.
[49:00]You wrote the letter,
[49:02]criminal defense attorney asked you to write the letter.
[49:05]Did you ever discuss the charges with Mr. Epstein
[49:08]before you wrote your statement?
[49:10]No.
[49:12]You never talked to him once
[49:13]about these allegations before,
[49:16]even though you just described somewhat
[49:18]of what you knew about him,
[49:20]you did not discuss that with him at all
[49:22]before you wrote a good character reference for him.
[49:27]To the extent that there were discussions with Epstein,
[49:31]they were always in the presence of defense counsel.
[49:34]There were many lawyers there,
[49:36]and I was a member of that group.
[49:41]So I never had a personal conversation with him
[49:45]like that, like the one that you're suggesting.
[49:48]And during those conversations,
[49:52]I assume that Mr. Epstein wasn't mute.
[49:54]He was speaking perhaps about the charges.
[49:59]So, well, a couple of things.
[50:04]I wanna talk to you about them, but I will say this.
[50:10]I have a balance of privilege here,
[50:12]but I also don't want it to be
[50:14]that I'm trying to withhold anything from you.
[50:17]So at the time that this was going on,
[50:21]what I was learning from the defense people
[50:23]who were investigating it was that the investigation
[50:29]was full of allegations that were, in many ways, untrue,
[50:36]contradicted by recorded transcribed statements
[50:39]from the witnesses.
[50:41]What I understood from the attorneys
[50:45]was that the police investigation was flawed
[50:48]and somehow either biased
[50:50]or the facts of that investigation
[50:54]as described in the police report
[50:56]were inconsistent with recorded statements
[50:59]from the witnesses,
[51:00]omitted information that the witnesses gave them
[51:03]in recorded statements.
[51:04]There was even, if I recall,
[51:06]there was even in the police report
[51:12]reference to a trash poll where the police report
[51:16]indicated that they found a sex toy in the trash poll.
[51:20]And it later turned out that what was identified
[51:22]as a sex toy was, in fact, a broken salad utensil.
[51:26]And so, but when the police use the information
[51:31]from their report in their affidavits
[51:33]and their arrest warrants,
[51:36]they kept the part about it being on sex toys
[51:40]in the garbage bowl, but never mentioned the fact
[51:43]that it was later found to be a salad utensil.
[51:45]There's also no mention in that police report
[51:48]about the fact that Epstein had been adamant
[51:52]that he didn't know that anybody was underage.
[51:55]In fact, there was, as I understood it,
[51:58]because I didn't do it, but as I understood it,
[52:00]there was a lie detector test, a polygraph test,
[52:04]where Epstein, which indicated
[52:06]that Epstein was being truthful
[52:08]when he said he didn't know about the age.
[52:10]So Mr. Indy, let's go back to an earlier question
[52:14]that I asked you about when in context of that charge,
[52:19]when in context to his adjudication of guilt
[52:22]and his sentencing, I assume,
[52:26]and you can correct me if I'm wrong,
[52:28]but you wrote this in connection with the sentencing
[52:32]or the pre-sentencing report on behalf of the defense.
[52:35]Is that accurate?
[52:36]I don't know for a fact,
[52:38]but that's not what I recollect.
[52:41]Okay.
[52:42]I think this was done previously.
[52:46]So before, so what I find intriguing
[52:50]about what you just testified to,
[52:51]you read some of the other lengthy detail
[52:55]about the theory of the defense of Mr. Epstein,
[53:02]which I'm in trouble contextualizing
[53:04]when you wrote this particular document.
[53:06]I find that intriguing and a little bit difficult
[53:09]for me to understand why.
[53:12]May I just say that the doc,
[53:13]I mean, he didn't write the document,
[53:14]he wrote that excerpt, just to be clear.
[53:16]So the rep.
[53:17]No, that's correct.
[53:18]Okay.
[53:20]Well, over the course of,
[53:22]the reason I can provide as much detail
[53:25]about the defense position is because that detail
[53:28]has been argued over and over and over again
[53:30]by the defense counsel.
[53:31]So it's something that has stuck in my mind.
[53:35]When this was written, it was written once,
[53:39]I don't, it was also a very long time ago.
[53:43]And so I can't tell you precisely when it was written.
[53:46]And I can't tell you,
[53:49]I just can't tell you the full context
[53:53]when this was submitted.
[53:56]In your opening, you said that after 2008,
[53:59]after his guilty plea,
[54:00]you thought that he was contrite
[54:01]and that he learned from his mistake.
[54:05]And you said that you were horrified to learn
[54:08]of the crimes he committed after.
[54:11]What crimes are you referencing after 2008?
[54:15]So, now with hindsight.
[54:20]Was he ever charged or, I'm unaware of any charge
[54:24]or referencing times post 2008.
[54:27]Is there, what charges are you referencing?
[54:29]What crimes are you referencing?
[54:30]I'm not referencing any charges after 2008.
[54:34]After he was.
[54:37]What conduct after 2008 was criminal?
[54:41]Because you said that you were horrified
[54:43]to learn of his criminal activity after this.
[54:45]I'm not sure, I don't think I said
[54:48]I was horrified to learn of his criminal.
[54:50]I was horrified that he hurt people.
[54:52]But all of that is in the context of statements
[54:54]that have emerged since his death.
[54:57]What criminal activity occurred post 2008?
[55:04]I don't specifically know what criminal activity
[55:06]occurred post 2008.
[55:07]I wasn't there.
[55:09]I didn't see any criminal activity.
[55:10]But what I've seen now are allegations
[55:13]by a number of women that have come to light
[55:15]after he died where they settled
[55:17]because these things happened.
[55:18]And while I've never seen him do anything that way,
[55:23]nobody's ever reported anything to me that way.
[55:27]Clearly with all of these women saying this happened
[55:30]after the fact, I cannot say that he didn't do
[55:33]a lot of bad things.
[55:35]And so, learning this after his death,
[55:41]I feel horribly.
[55:42]And that's what I said, I do feel horrible.
[55:44]So Mr. Indyk, just go back to the statement
[55:47]you wrote that was inserted in the defense statement.
[55:53]I just, I'm wondering if it's,
[55:57]was it your normal practice to write such a letter
[56:00]of recommendation on behalf of someone
[56:05]without full understanding of the ramifications
[56:09]of what you were saying and the allegations
[56:13]and the context with which you were being asked
[56:15]to write that?
[56:16]I mean, did you know why you were being asked
[56:20]to write that specific statement?
[56:22]I knew that people were saying,
[56:25]were making allegations against him,
[56:27]which were contrary to what I had observed in him.
[56:32]And the truth is that I felt they asked me
[56:38]for what he had done that was generous to me.
[56:41]And I felt like I could be honest about that.
[56:44]And so that's why I did it.
[56:48]So I'm aware that you were a transactional attorney,
[56:51]probably did general ramifications,
[56:53]but you understood, I would guess,
[56:56]as an attorney, somewhere along the pike,
[56:59]I had to understand something about criminal law,
[57:02]that your statement was going to be used
[57:07]to facilitate a reduction in sentence,
[57:11]reduction in charges, or some benefit to Mr. Epstein
[57:16]in light of the substantial charges
[57:19]which you described in some detail that you were aware of.
[57:23]At the time, first of all,
[57:25]this is the first time anything like that
[57:27]ever happened to me.
[57:28]So to some extent, it's all very new to me.
[57:33]I am still representing the person.
[57:37]The person that I represented
[57:39]never exhibited this kind of conduct to me,
[57:43]was very generous to me.
[57:47]And at the time-
[57:48]But even though he was generous to you,
[57:53]you understood this was going to be used
[57:55]to facilitate either reduction in sentence
[57:57]or reduction in charges.
[57:58]But I also understood that the answer is,
[58:02]I understood that it was going,
[58:04]I didn't know it was going to be used
[58:05]for reduction of charges or reduction of sentence.
[58:08]I understood it was going to be used
[58:09]to give Pugge law enforcement
[58:12]as a character reference for him.
[58:15]Okay, I did understand that.
[58:16]And so why would you give a character reference
[58:19]if not for reduction in sentence or reduction in charges?
[58:25]I mean, that's why you give something like that
[58:27]to a special needs agent, is it not?
[58:29]That's not what was going on.
[58:30]That's not what I was thinking at the time.
[58:32]All right.
[58:33]It wasn't.
[58:35]Okay.
[58:37]Mr. Indyk, you referenced attorney-client privilege.
[58:42]I just bore the record.
[58:43]If you wish to assert any privilege,
[58:46]you must say so on the record.
[58:50]So far, there hasn't been a very specific question.
[58:54]If that does arrive, I'll let you know.
[58:57]And we're going to jump around a little bit here,
[58:59]but you had mentioned that the allegations
[59:01]that were made against Mr. Epstein
[59:04]during that 2006, 2008 period,
[59:07]you had mentioned they were untrue.
[59:10]Who, did you make that determination yourself?
[59:13]No, that was communicated to me.
[59:15]Who communicated that to you?
[59:16]And it was communicated through defense counsel.
[59:20]And the reason I can discuss it is it's the same,
[59:22]it's the same statements that defense counsel made
[59:25]in documents they delivered to the,
[59:28]excuse me, to the government.
[59:30]And for the record, who was the defense counsel?
[59:33]Epstein had a lot of defense attorneys at the time.
[59:38]Off the top of my head, Jerry Lefkort was one,
[59:41]Gerald Lefkort was one.
[59:43]I believe Jack Goldberger was one.
[59:46]I believe Mike Teane was one.
[59:54]Dershowitz, Alan Dershowitz, I think I mentioned.
[59:58]Lily Sanchez, I don't, I'm trying to remember
[1:00:02]who was involved at that particular time.
[1:00:08]Sheryl Reich, I believe, was an attorney,
[1:00:11]a criminal defense attorney at the time.
[1:00:16]Guy Lewis also.
[1:00:21]Marty, Martin Weinberg, but I, you know,
[1:00:24]the attorneys came on at different times,
[1:00:26]so I can't tell you exactly who came on when.
[1:00:28]In addition to defense counsel,
[1:00:30]did Mr. Epstein hire private investigators?
[1:00:35]I don't know that Mr. Epstein hired private investigators.
[1:00:38]I believe the defense counsel hired private investigators.
[1:00:41]Why were private investigators?
[1:00:43]Sorry, Roy Black, I wanna add to that.
[1:00:44]Roy Black was part of this as well.
[1:00:46]Why was, were defense or private investigators hired?
[1:00:53]Not being a criminal defense attorney
[1:00:57]and not being, participating at the time
[1:01:01]that they did this, because I came in at,
[1:01:02]I didn't hear anything about the allegations
[1:01:04]until about 2006 or so.
[1:01:07]Many of the attorneys, much of the attorney's work
[1:01:09]had already been done by that time,
[1:01:12]including, I think, the hiring of private investigators.
[1:01:17]So the actual reasons as to why, I don't know,
[1:01:22]but I think my assumption at the time was
[1:01:24]that's kind of what you do as a criminal defense attorney
[1:01:27]is you bring on a private investigator
[1:01:29]to find out information so that you can have
[1:01:32]a full idea of what you're defending.
[1:01:34]For the record, did you ever work
[1:01:37]with these private investigators?
[1:01:39]At some point, I did communicate
[1:01:41]with private investigators, I think, for payment.
[1:01:46]But I, and I'm sure I must have had conversations
[1:01:52]at some point in the process, not early on,
[1:01:54]but I just don't remember.
[1:01:56]But you yourself, as far as the work
[1:01:59]that the private investigators were conducting,
[1:02:00]you didn't direct them?
[1:02:02]For the criminal work that you're talking about,
[1:02:06]absolutely not.
[1:02:09]And earlier you mentioned that you never socialize
[1:02:13]with Mr. Epstein.
[1:02:14]Did Mr. Epstein ever invite you to social events?
[1:02:21]I was invited one time, and it was the only time,
[1:02:26]not a social event with him, frankly,
[1:02:28]but it was a Victoria's Secret fashion show.
[1:02:33]I was invited one time, and that was the only time.
[1:02:36]I think I saw him there once,
[1:02:38]but I certainly didn't socialize with him there.
[1:02:42]And it wasn't just me, it was me,
[1:02:44]Jeff Shands, who I worked with.
[1:02:48]So the attorneys were invited.
[1:02:54]But other than that, no.
[1:02:55]I never was invited to a dinner.
[1:02:57]I never was invited to a show.
[1:02:59]I never invited to any movie or anything with him, no.
[1:03:03]And I want to return back to the statement
[1:03:06]that you provided for Epstein's defense.
[1:03:09]Is it true that you made Mr. Epstein
[1:03:11]a godfather of your children?
[1:03:14]Yes, it was an honorary appellation.
[1:03:19]I had no expectation
[1:03:20]because I didn't have that kind of relationship with him,
[1:03:23]but I wanted to show gratitude,
[1:03:24]do something to show gratitude
[1:03:27]for how he helped my wife and I have our children.
[1:03:30]And so I had asked him, would it be okay?
[1:03:34]And he wouldn't have any obligation to do anything,
[1:03:36]but as a way of honoring him,
[1:03:40]if I could make him honorary godfather, and I did.
[1:03:43]Sorry, based on your testimony,
[1:03:47]your children did not have any relationship
[1:03:49]with Mr. Epstein?
[1:03:49]No, I think in total, they met him twice in the office
[1:03:58]and they were very, very, they were very,
[1:04:00]very young at the time.
[1:04:02]My wife was there, they were in the office,
[1:04:04]I think it was two times.
[1:04:14]Would you have entrusted Mr. Epstein
[1:04:16]to care for your children?
[1:04:19]To care for my children?
[1:04:20]No, I wouldn't have trusted anybody
[1:04:21]to care for my children.
[1:04:24]Who is Ghislaine Maxwell?
[1:04:27]Ghislaine Maxwell was an associate of Jeffrey Epstein.
[1:04:32]When did you first meet Ghislaine Maxwell?
[1:04:36]Sometime after I started working
[1:04:39]representing Epstein in 1996.
[1:04:42]What did you understand her relationship
[1:04:44]to be with Mr. Epstein?
[1:04:49]My understanding in it, at the time,
[1:04:52]my understanding was that she was largely
[1:04:55]kind of an overall household manager.
[1:05:00]Epstein, even then, would travel from different households
[1:05:05]and Ghislaine was responsible for making sure
[1:05:09]that the households were managed properly,
[1:05:12]they were supplied properly,
[1:05:14]that the employees there were doing the cleaning
[1:05:17]and things like that.
[1:05:18]That was my understanding of her role.
[1:05:20]I learned at some point that she had been a girlfriend
[1:05:25]of his, though I do not believe at the time
[1:05:28]that I was there that she was a girlfriend of his.
[1:05:31]And you mentioned that she would manage
[1:05:35]Mr. Epstein's properties.
[1:05:36]Did you ever understand her to have any role
[1:05:38]in arranging or scheduling masseuses for Mr. Epstein?
[1:05:43]No.
[1:05:44]She never talked to you about paying masseuses?
[1:05:48]No.
[1:05:49]How often did you interact with Ghislaine Maxwell?
[1:05:54]When I worked in the office in New York City
[1:06:02]on Madison Avenue, she had an office there.
[1:06:05]So she appeared from time to time.
[1:06:07]She wasn't in my section of the office,
[1:06:09]but she was there.
[1:06:11]So I would see her, I would say hello,
[1:06:13]that kind of thing.
[1:06:15]And it wasn't super frequent, but I saw her.
[1:06:21]I saw her there.
[1:06:22]As far as your day-to-day
[1:06:23]and the legal services you were providing,
[1:06:25]did you have any interactions with her?
[1:06:29]At times I did.
[1:06:30]Again, most of my stuff was very specific.
[1:06:33]It was transactional.
[1:06:35]So there were times I believe
[1:06:37]Maxwell purchased a townhouse.
[1:06:40]So I did work for that townhouse,
[1:06:44]the purchase of that townhouse.
[1:06:47]I believe there were,
[1:06:52]I believe she had me look at an agreement or two.
[1:06:56]I can't recall which agreements off the top of my head,
[1:06:58]but I believe she had me look at agreements or two.
[1:07:01]And sometimes she would convey requests by Epstein
[1:07:06]for me to do some kind of a transactional
[1:07:09]or corporate work for her.
[1:07:11]And you mentioned the acquisition of the property.
[1:07:14]This past week, we had Mr. Kahn testify.
[1:07:16]And he said that there were accounting work
[1:07:18]that he did for Ms. Maxwell.
[1:07:21]And she, I don't want to mischaracterize this testimony,
[1:07:24]but said effectively that she didn't pay.
[1:07:27]Did she pay you for the work that you did for her?
[1:07:31]No, it was done.
[1:07:34]To the extent I did work for her,
[1:07:35]it was at the authorization of Epstein.
[1:07:42]Would you consider Glane Maxwell at any point
[1:07:45]to be a friend of yours?
[1:07:46]No.
[1:07:50]Do you believe that Maxwell facilitated Epstein's access
[1:07:54]to minor victims?
[1:07:56]I don't know.
[1:08:14]Mr. Indyke, I want the record to be clear.
[1:08:16]So I'm going to ask you some questions related
[1:08:19]to the investigation of Mr. Epstein in 2005.
[1:08:25]When did you first become aware that there was
[1:08:28]an investigation into Mr. Epstein's conduct
[1:08:30]in Southern Florida?
[1:08:33]Not entirely certain.
[1:08:35]I believe it was 2006, 2007.
[1:08:38]And for the record, you did not have any knowledge
[1:08:41]of his illegal, the illegal activity by Mr. Epstein
[1:08:45]prior to his arrest.
[1:08:46]I'd worked for him for a decade and I had no knowledge
[1:08:49]of anything, any allegations being made
[1:08:51]against him like that.
[1:08:53]On October 20th of 2005,
[1:08:55]Lise executed a search warrant for Mr. Epstein's
[1:08:57]Palm Beach Florida home.
[1:08:59]Do you recall this occurring?
[1:09:03]Can you tell me the date again?
[1:09:05]October 20th, 2005.
[1:09:13]I don't think I knew contemporaneous.
[1:09:17]Palm Beach detective, Joseph Rappieri,
[1:09:19]spoke out about his belief that Epstein was tipped off
[1:09:21]about the raid since multiple computers expected
[1:09:24]to be at his house were missing
[1:09:25]when the search warrant was executed.
[1:09:28]To your knowledge, did anyone tip off Jeffrey Epstein
[1:09:31]to the October 20th search warrant in Palm Beach?
[1:09:34]I don't know.
[1:09:41]When you visited Mr. Epstein's properties,
[1:09:43]did you notice cameras?
[1:09:50]Did we specify which property?
[1:09:55]Well, you mentioned the Manhattan property at one point.
[1:09:58]Sure.
[1:09:59]So let's break it down, the Manhattan property.
[1:10:03]My understanding about the cameras,
[1:10:05]there were cameras in the Manhattan property.
[1:10:09]My understanding is that they were external cameras.
[1:10:13]There was a security room when you first walked
[1:10:16]into the right that had monitors
[1:10:20]of the external cameras that were all
[1:10:22]around the perimeter, the outside of his townhouse.
[1:10:30]I later found out, and by later I mean,
[1:10:36]I think, even after things start to get conflated,
[1:10:41]but I think I found this out after he got arrested
[1:10:47]the second time, that there was one camera,
[1:10:52]and this was probably even after he died,
[1:10:54]that was one camera, he had a safe room in the house.
[1:10:59]I didn't even know there was a safe room in the house,
[1:11:01]but he had a safe room in the house.
[1:11:03]And there was a camera outside the safe room
[1:11:05]in the house.
[1:11:08]Those are the cameras that I knew about in New York.
[1:11:12]In Florida, there was much made about,
[1:11:17]I think it was in the press,
[1:11:19]again, a lot has gone on,
[1:11:22]and lots of reports have come out since then.
[1:11:24]But I believe in Florida,
[1:11:26]there was a reference to cameras in his house,
[1:11:31]but there were cameras, as I understand it,
[1:11:33]that the police helped put in there,
[1:11:37]because there was concern
[1:11:40]that somebody was stealing from him.
[1:11:42]So they put the cameras, I think,
[1:11:45]in his desk on the ground floor,
[1:11:49]and I wasn't sure if there was maybe one
[1:11:50]in the garage as well.
[1:11:52]But those are the cameras that I knew about.
[1:11:55]There have been allegations
[1:11:57]that Mr. Epstein would record visits
[1:12:00]at various properties,
[1:12:02]as you don't know anything about that.
[1:12:05]I've heard the allegations.
[1:12:08]I know of no recordings.
[1:12:11]I don't know of cameras that would have done that.
[1:12:19]Mr. Indyk, excuse me.
[1:12:23]The majority has about five minutes,
[1:12:25]and I just want to make sure the record is clear.
[1:12:27]I'm going to ask you numerous yes or no questions.
[1:12:32]First, how did Mr. Epstein,
[1:12:35]or this is not a yes or no question,
[1:12:38]how did Mr. Epstein act towards the young women
[1:12:40]or girls that he surrounded himself with?
[1:12:46]The question assumes that I saw him
[1:12:48]surround himself with young women or girls.
[1:12:51]Not sure.
[1:12:52]Did you ever witness Mr. Epstein
[1:12:53]engage in sexual conduct?
[1:12:56]I never witnessed Mr. Epstein
[1:12:57]engage in sexual conduct.
[1:12:59]Did you ever witness Mr. Epstein
[1:13:01]have sexual conduct of any kind
[1:13:02]with young women or girls?
[1:13:04]I never witnessed Mr. Epstein
[1:13:06]have any sexual conduct, period.
[1:13:08]Did you ever witness Mr. Epstein
[1:13:10]sexually abuse or assault young women or girls?
[1:13:13]I never witnessed that, no.
[1:13:16]Did Mr. Epstein ever discuss
[1:13:18]sexual acts of any kind with you?
[1:13:20]No. Was it common for Mr. Epstein or Ms. Maxwell to bring young women or girls to any other place
[1:13:28]where the two of you meet? The only women that were ever in my presence, to my recollection,
[1:13:35]with one exception I'll get to that in a second, were women who were either in their 20s or in
[1:13:41]their 30s who were assistants who I understood to be personal assistants of Epstein. He said
[1:13:48]you had an exception. I'm sorry and the exception the exception is he had a goddaughter and I
[1:13:55]this is a I don't know that I feel comfortable giving her name but he had a goddaughter
[1:14:03]that I believe he had seen from time to time and I had met from time to time.
[1:14:10]A couple of times I think because she would when I was in his when I was in his home
[1:14:16]in his dining room she had come into the dining room. Can I just be clear
[1:14:20]that the exception was that's the only person who you saw as a minor female in the presence?
[1:14:24]Correct. Okay just to be clear. Who are the assistants that you're referencing?
[1:14:29]Um um
[1:14:38]Ratlana Pazadeva um there was a woman by the name of there was um another woman by the name
[1:15:01]if you have some names I could I could tell you if I recall them or not. And we'll have
[1:15:05]more specific questions. Okay. Um did Mr. Epstein have children of his own? To my knowledge
[1:15:12]no. Did Epstein or Maxwell ever ask if you wanted them to bring women or girls to you?
[1:15:24]Never. Did you ever have any sexual contact with young women or girls in the presence
[1:15:31]of Epstein or Maxwell? Absolutely not. Did you ever have sexual contact with any young
[1:15:38]woman or girl introduced to you by Epstein or Maxwell? Absolutely not. Did you ever witness
[1:15:44]Mr. Epstein receive a massage from a young woman or girl? No. Did you ever receive any massages
[1:15:52]from any young woman or girl brought to you by or introduced to you by Mr. Epstein or Ms.
[1:15:58]Maxwell? No. We'll go off the record. You can go on the record. Mr. Renday good morning.
[1:16:27]Good morning. I understand that um Ms. Crockett has a statement. Just briefly um as you go
[1:16:33]through your line of questioning. Yes. When you reference someone if you say the assistant,
[1:16:38]if you say the partner, can you also make sure that you reference their name after you
[1:16:43]label their title for clarity of the record? I'll try to remember that yes. Thank you. Sure.
[1:16:50]Mr. Renday I'm going to revisit some of the areas that you discussed with my majority
[1:16:56]colleagues in the previous round. In doing that I don't want to make you repeat yourself. I
[1:17:00]just want to make sure that we have as clear record as possible. Okay. So going back to the
[1:17:07]time when Mr. Epstein first hired you. Did you have a title? Attorney. Um and if I understood
[1:17:18]your testimony correctly you were the sole proprietor of an entity called Darren Endike
[1:17:24]PLLC. Is that right? Darren K Endike PLLC. And I don't think I did I give that name but that is
[1:17:34]that is. Thank you. And if I also understand correctly Jeffrey Epstein was the sole
[1:17:41]client of Darren K Endike PLLC. Is that right? He was a the primary client um from time to time
[1:17:50]he was the primary client and from time to time I would do things for him and for his clients.
[1:17:58]But he was a primary client and there were times when friends or acquaintances or somebody
[1:18:03]else would come. I wouldn't take on jobs very often because the expectation was that I would be
[1:18:12]that I would be available at all times and that I would get projects
[1:18:20]for Epstein and sometimes it's for Epstein's clients. I would get a project and the
[1:18:25]expectation was as soon as that project came to me that would be the most important thing
[1:18:28]we did and I would get it done very quickly. So it wasn't you know part of
[1:18:36]of what I had to do was be available to make sure that I could respond to those things on
[1:18:42]that basis and if I brought on more clients that would interfere with that. Are you familiar with
[1:18:50]an entity called Jay Epstein and Co? Yes I am familiar with that entity. I believe it's
[1:18:59]called Jay Epstein and Company. And were you associated with it in any way? A long time ago
[1:19:05]but I believe that's the entity that initially employed me. And over what period of time did
[1:19:14]Jay Epstein and Company employ you? I don't remember the exact end date but it was from 1996
[1:19:22]for three or so years. And was there another entity that employed you following Jay Epstein
[1:19:30]and Company? There was another entity called New York Strategy Group which was primarily
[1:19:36]owned by Chance. Why I'm sorry? By Jeffrey Chance, the partner that brought me in there.
[1:19:44]I believe I had a minority ownership of that LLC, was an LLC. And over what period of time
[1:19:50]were you employed through New York Strategy Group? I believe that New York Strategy Group
[1:20:00]was my employer until I want to say 2006 or 7. And at some point I became
[1:20:21]the primary owner of New York Strategy Group. And when did Darren K. Endyke PLLC come into
[1:20:30]existence? That came into existence I believe in 2008. Again it was some time ago but I
[1:20:36]believe it was in 2008. Does Jay Epstein and Company still exist? No. When was it wound down?
[1:20:47]I believe Jay Epstein and Company was wound down when Epstein moved his primary residence
[1:20:54]to the U.S. Virgin Islands and formed a company there. I don't remember the date
[1:21:03]exactly but the company's name was Financial Trust Company Inc. and
[1:21:10]Jay Epstein and Company was discontinued at that point I believe. Did you have any association
[1:21:15]with Financial Trust Company Inc.? I believed I was at some point a corporate secretary,
[1:21:24]may have been a vice president in an administrative sense. You were asked earlier
[1:21:38]about your communications with Jeffrey Epstein. Are you aware of Jeffrey Epstein ever using
[1:21:47]encrypted messaging software or an encrypted messaging app such as Signal? As part of the
[1:21:59]things that I did for Epstein, once he became a registered sex offender, I had to
[1:22:08]report or include in a report to the New York Sex Offender Registry
[1:22:17]apps that he had used or that he had a presence on. I want to say that at some point
[1:22:26]I remember Signal being used and maybe WhatsApp though
[1:22:35]I don't, I can't tell you when. At the time you started working for Jeffrey Epstein,
[1:22:48]what was his net worth to your knowledge and approximate number is fine? I don't know.
[1:22:54]Did you come to know that later in time? Well I certainly I know it when he died
[1:23:02]because I'm the co-executive of the state, I had to know it.
[1:23:10]There were times that I could recall before I became executive hearing
[1:23:17]net worths around half a billion, sometimes less, sometimes 300 million, but accounting for his
[1:23:27]assets and his wealth, that wasn't my role. So if I heard it in passing, not necessarily
[1:23:37]something that I would be kind of investigating or reporting. And whose role was it to keep
[1:23:43]track of that? The accounting department. And specifically who? I think Rich Kahn would do that.
[1:23:53]I think that was part of his role when he joined. And over the period of time during which Mr.
[1:24:02]Epstein employed you, what to your understanding were the sources of his wealth? Primarily they
[1:24:10]were clients that he worked for and investments that he made. He did very well with investment
[1:24:22]funds. I'm not a financial markets kind of person. That wasn't my kind of skill set,
[1:24:33]but my understanding was the reputation that he had was that he was skilled with understanding
[1:24:40]financial markets, currencies, options, securities trading, but that his business wasn't as an
[1:24:50]investment advisor, his business was a more financial consultant. But he did have
[1:24:58]participations in funds. And those funds yielded him pretty solid results. So between the funds
[1:25:08]and the clientele that he had that paid him fees over time, that's where his wealth came
[1:25:14]from, from my understanding. If we could focus on the client servicing piece, how many clients
[1:25:19]did he have during the time that you worked for him? I can name them. I never actually
[1:25:30]thought about how many, but Wes Wexner, clearly, when I first joined, he'd given me
[1:25:39]some kind of an assignment to do for David Rockefeller. I don't know if Rockefeller was
[1:25:44]a paying client. Again, that wasn't my role, but they did work for David Rockefeller.
[1:25:51]I believe Elizabeth Johnson. And I know there was work done for Mort Zuckerman, Leon Black.
[1:26:23]I know the Rothschilds. I'm trying to remember which of them or what entity, but I don't know.
[1:26:31]That'd be Ariana Rothschild. I know the name Ariana Rothschild.
[1:26:36]It's possible that it was for Ariana, but I'm not 100% certain. Glenn Dubin?
[1:26:44]So Glenn Dubin, I don't think Glenn Dubin was a client, like a client in the same sense
[1:26:51]that Wexner was a client. Dubin, as I understand it, there are a couple of different
[1:26:59]ways that he was connected with Dubin. Dubin had funds that he invested in, that he made
[1:27:06]a good deal of money off these funds. I think Dubin, if I recall, he referred Jeffrey
[1:27:15]to invest in a fund called, I think it was DB Zwerne. I don't remember the full name,
[1:27:22]but that's the fund name. And there was a dispute about DB Zwerne that got fairly
[1:27:30]elevated. And as part of the resolution of that dispute, there was a settlement that came about.
[1:27:39]It's part of the resolution of that dispute because it was Glenn Dubin's referral to that
[1:27:46]fund. Dubin had some kind of compensation payment to Epstein to settle that case.
[1:27:56]And the last thing that I recall is Dubin had a company, I can't remember the name of the
[1:28:03]company right now, it's sitting here, but that company was purchased by J.P. Morgan, I believe,
[1:28:10]and I believe Epstein got a finder sheet for that. And that was a one-off thing. It wasn't
[1:28:18]one-off thing. It wasn't like Epstein was kind of representing Dubin all the time.
[1:28:26]What about Stephen Sanofsky?
[1:28:31]I know the name. I don't know, and I believe that there was a payment from Sanofsky.
[1:28:40]I just don't know the nature of that relationship.
[1:28:45]And just going down the roster, to the best of your recollection,
[1:28:51]how much did each of these people pay Epstein for the services he provided to them?
[1:28:56]And I'll start with Les Wexner.
[1:28:58]I really don't know how much Wexner paid him. It was a lot, but I just don't know how much.
[1:29:03]And what was the nature of the work that Epstein did for Les Wexner?
[1:29:07]A variety of things. As I understood it, and his relationship with Wexner predates my
[1:29:14]arrival there, but as I understood it, sometimes people who obtained this ultra-high net worth
[1:29:23]standing get there gradually over time, and they build their offices gradually over time.
[1:29:33]And when they do that, it becomes inefficient. There are people who are not necessarily doing
[1:29:38]things and are getting paid to do things, and there are people doubling up on things.
[1:29:44]Part of the thing that Epstein did, at least for Wexner that I can recall being told about,
[1:29:49]was kind of cleaning house a little bit.
[1:29:53]Also, they would do things for Wexner. For example, even somebody at that level of wealth
[1:30:00]has lots and lots and lots of assets, and all of those things, jewelry, all of that stuff
[1:30:08]require insurance. But unless you're kind of born into it, you don't know how you're
[1:30:15]supposed to deal with that. And how you're supposed to deal with that is photograph it
[1:30:19]and appraise it. So all of that's for record, because if something happens to it,
[1:30:26]you have good records to justify your insurance money. So they helped organize it that way.
[1:30:38]Jeffrey, did tax work, did state planning work?
[1:30:40]Not to interrupt you, I'm receiving another request for you to speak up.
[1:30:42]No, I'm sorry.
[1:30:43]Some of our audience members are having difficulty hearing you.
[1:30:47]Move this closer, would it help?
[1:30:49]Let's try it.
[1:30:49]Yeah, let's do that. Sorry, my voice is not...
[1:30:53]I think it's for the people in the room, just a little...
[1:30:55]Yeah, I don't think the mic's going to...
[1:30:56]So I apologize to everybody. So Epstein also did state planning work, did tax planning
[1:31:07]help people achieve better tax results, more tax-efficient results for themselves?
[1:31:14]I don't know too much of the detail behind this, but it was my understanding that
[1:31:23]with respect to Wexner, Epstein helped him gain greater liquidity with the wealth that he
[1:31:31]did have, because things like that.
[1:31:37]That's a helpful picture, and I appreciate that.
[1:31:40]That's Wexner.
[1:31:41]Yep. Moving down the list, and I think if we could just
[1:31:45]cab in the answers to the amount that each one of these people paid Epstein,
[1:31:50]to the extent you recall, the next name is Leon Black.
[1:31:54]Um, the way I know this is not because I kind of tracked it or reported on it,
[1:32:02]but it's based upon what I kind of read through the papers.
[1:32:05]So, Leon Black, he did work for it, I can confirm that.
[1:32:09]I heard reports that it was something like $158 million,
[1:32:13]and that wouldn't seem unreasonable to me.
[1:32:18]David Rockefeller?
[1:32:20]I don't know.
[1:32:21]Elizabeth Johnson?
[1:32:22]I also don't know.
[1:32:26]A different lawyer by the name of
[1:32:30]Mandy Ellison was the lawyer that worked on her account.
[1:32:34]And Mort Zuckerman?
[1:32:36]I don't know how much money, if any, that he got from Mort.
[1:32:40]And then the Rothschilds?
[1:32:42]Also, I don't know.
[1:32:50]Shifting back to the period in time when Epstein hired you,
[1:32:55]yes.
[1:32:56]Were you aware that he had an affinity for young women?
[1:33:00]No.
[1:33:01]Or for teenage girls?
[1:33:02]No, absolutely not.
[1:33:04]Um, did you become aware of that over time?
[1:33:08]The only way I became aware of the allegation that he had an affinity for teenage girls
[1:33:13]was through, was once I was kind of learned about the investigation in Palm Beach.
[1:33:21]Did you become aware at any point that Epstein sexually abused young
[1:33:26]women and teenage girls?
[1:33:30]I became aware of the allegation in Palm Beach that there were
[1:33:39]massages which at times ended up sexual.
[1:33:45]And that in some cases there were underage people in those massages.
[1:33:51]My understanding at the time was that he was unaware of their age.
[1:33:57]Um, that my understanding is that the statements given by the people who gave
[1:34:03]police statements were that there wasn't force used.
[1:34:09]There wasn't coercion used.
[1:34:11]Those are the statements being made.
[1:34:14]I'm not testifying it to myself as to what I know because I don't.
[1:34:18]But those are the statements.
[1:34:19]No force, no coercion.
[1:34:22]Um, and that, that the, the conduct was voluntary.
[1:34:33]Um, but again, I'm not commenting underage.
[1:34:37]Okay.
[1:34:37]I'm not making any comment, comment, but underage.
[1:34:39]Can I just ask if you were asking if he was ever personally aware for,
[1:34:42]he's talking about allegations, but was your...
[1:34:45]We veered off a bit.
[1:34:46]So yeah, I was, I was focused on the personal knowledge.
[1:34:50]I'm sorry.
[1:34:50]I have no personal knowledge of that.
[1:34:52]We'll come back to that.
[1:34:54]Um, during your employment, Mr. Khan, um, with Jeffrey Epstein, did you ever...
[1:34:59]Mr. Endyke.
[1:35:00]So sorry, Mr. Endyke.
[1:35:02]That's okay.
[1:35:03]I beg your pardon.
[1:35:04]During your employment, Mr. Endyke, with Jeffrey Epstein,
[1:35:07]did you ever discuss with him his sexual activity with young women,
[1:35:10]whether consensual or otherwise?
[1:35:12]No.
[1:35:13]Did you ever discuss that topic with anyone else?
[1:35:19]The topic generally, I'm sure, came up during legal conversations.
[1:35:23]Um, you were speaking during the previous round about Mr. Epstein's arrest in Florida.
[1:35:34]When did you learn about his arrest?
[1:35:38]Again, the timing is a little bit, it's a little bit clouded to me.
[1:35:43]I don't believe I knew about it until 2006.
[1:35:48]How did you become aware of it?
[1:35:58]I believe, trying to remember back, I believe Epstein told me.
[1:36:11]And did that conversation happen in person?
[1:36:13]It was an in-person conversation.
[1:36:15]I, I want to say it was, um, it was, sorry, it was an in-person conversation.
[1:36:24]And I want to say it was in New York.
[1:36:30]I just don't remember where in New York.
[1:36:38]And how long after the arrest did that conversation take place?
[1:36:43]I don't know.
[1:36:45]What did Mr. Epstein tell you during that conversation?
[1:36:48]That he was charged.
[1:36:51]That he didn't really go into the details of the charges.
[1:36:57]This is more substance of it because I don't remember the specific conversation.
[1:37:03]And then he told me that there were lawyers working on it with him,
[1:37:07]and that I should work with him.
[1:37:11]What was your reaction?
[1:37:14]Surprised and shocked, to be honest.
[1:37:16]Did you ask him for any additional details about the arrest or the nature of the charges?
[1:37:21]I think I was so surprised that I didn't think to,
[1:37:24]and also my relationship with him wasn't so that I could get so deeply personal.
[1:37:29]And I had never been involved with anything like that before,
[1:37:31]so I didn't really know what to do.
[1:37:35]Was the rest of Mr. Epstein's staff informed of the arrest at some point?
[1:37:41]Yes, at some point.
[1:37:42]I don't remember when.
[1:37:46]When, to your knowledge, was Mr. Kahn informed of the arrest?
[1:37:58]I don't know.
[1:38:01]Did you ever discuss it with him?
[1:38:04]In passing, but nothing in details.
[1:38:07]What was the conversation in passing?
[1:38:11]Just the arrest.
[1:38:15]I think maybe when he lost banking privileges,
[1:38:17]there must have been about the arrest.
[1:38:20]You know, nothing, Rich Kahn and I did not get into detail about Jeffrey Epstein's arrest.
[1:38:30]What did you discuss with respect to the loss of banking privileges?
[1:38:38]Again, substance, not detail, that the banking privileges at Chase were lost.
[1:38:49]Again, I don't know if,
[1:38:52]actually, other than that the banking privileges lost,
[1:38:55]I don't know that I have enough detail to give you more than that.
[1:38:58]Was it your understanding that the privileges at Chase were lost
[1:39:01]as a result of Mr. Epstein's arrest?
[1:39:05]It was an assumption more than an understanding,
[1:39:08]because I don't know if anybody's experienced this,
[1:39:12]but when banks deny services to you,
[1:39:15]they don't, as a general rule, tell you why.
[1:39:18]They just say no.
[1:39:21]But your assumption was that it was linked to the arrest,
[1:39:25]as opposed to a different cause?
[1:39:27]Yes. There was lots of publicity at the time,
[1:39:31]I think, that this happened.
[1:39:37]I also understand from your testimony during the previous round
[1:39:41]that you ultimately represented Mr. Epstein along with other counsel
[1:39:45]in connection with his arrest and prosecution in Florida.
[1:39:48]I was never the direct defense counsel,
[1:39:51]but I was brought on as a group of people that were.
[1:39:55]So it would be fair to say that you were a member of his defense team?
[1:39:58]Yes. Very loosely, but yes.
[1:40:01]So I think that anticipates my next question.
[1:40:04]Was there an allocation of responsibility among the members of the team?
[1:40:08]Did certain lawyers have responsibilities that differed from others?
[1:40:16]You can't talk about how he allocated responsibility among the lawyers.
[1:40:19]There wasn't a group meeting like, let's, you do this, you do that,
[1:40:24]you do the other thing.
[1:40:25]Based on your observation?
[1:40:26]My observation was that there was a group of lawyers at the time,
[1:40:32]all of whom kind of shared information and did things together.
[1:40:38]My role was kind of specific task, excuse me, task-oriented.
[1:40:43]Sometimes I would, if Epstein would ask me, did so and so do this yet?
[1:40:55]Could you ask them to do this or ask them when they're going to do this?
[1:41:00]But I believe it was more like a group thing.
[1:41:07]Some people were better writers than others.
[1:41:09]Marty Weinberg was a very good writer.
[1:41:13]Jay Lefkowitz, also a very good writer.
[1:41:17]But I think as a rule, everybody kind of worked together.
[1:41:25]And what, to your understanding, were the crimes that Jeffrey Epstein ultimately fled to?
[1:41:34]My understanding was that there were two charges.
[1:41:38]One charge was a solicitation of prostitution.
[1:41:41]And the other charge was procuring prostitution of someone under the age of 18.
[1:41:49]And please correct me if I'm wrong.
[1:41:52]I understand from your testimony earlier that you were aware of the requirement
[1:41:58]that Jeffrey Epstein register as a sex offender in various states as a result of his plea.
[1:42:03]Is that right?
[1:42:04]Yes, I became aware of that fact, yes.
[1:42:07]And that included New York State?
[1:42:09]Yes, there was an initial registration in New York.
[1:42:13]And you were involved in the registration, is that right?
[1:42:17]Yes, I believe I was involved in the registration.
[1:42:21]And did you become aware, in connection with that,
[1:42:24]that Jeffrey Epstein was designated a Level 3 sex offender in New York State?
[1:42:32]The answer to your question, yes.
[1:42:34]But that was after a round of litigation.
[1:42:41]The issue was litigated?
[1:42:42]The issue was litigated, yes.
[1:42:44]And were you part of the legal team that represented him in connection with that litigation?
[1:42:48]Loosely, loosely.
[1:42:51]And was it your understanding at the time that Level 3 under New York State law
[1:42:57]meant that there had been a determination that Epstein posed a high risk of a repeat offense
[1:43:01]and a threat to public safety?
[1:43:04]I understood he had it.
[1:43:07]It was a different designation, but I didn't understand that.
[1:43:13]Broadly speaking, were you troubled by Mr. Epstein's guilty plea at incarceration in Florida?
[1:43:23]Was I troubled?
[1:43:29]I was troubled, I guess the answer is yes, it was troubling.
[1:43:36]The problem I have in kind of tackling the question you have is not really knowing what it is.
[1:43:47]As it's come to pass, clearly, he did something.
[1:43:50]But at the time, what I was struggling with is what it is that he actually did do.
[1:43:59]Previously, I went into how the police reports were inconsistent with recorded statements,
[1:44:04]how there were references to items of sex toys which weren't, were broken salad utensils.
[1:44:10]There was even a statement from, I never heard the statement directly,
[1:44:15]but I was made aware of a statement made by the lead prosecutor in Florida
[1:44:22]who was a female experienced sex crimes prosecutor that uttered a statement to the
[1:44:28]effect that there were no real victims there.
[1:44:30]Now, I'm not saying there weren't, I'm just saying that that's what I heard at the time.
[1:44:34]So I'm struggling with these things and not knowing what allegations are true
[1:44:39]or what allegations aren't true.
[1:44:42]And I know that with respect to his sex offense, the sex offender charge,
[1:44:51]which was required not by the state, it was required by the U.S. Attorney's Office
[1:44:59]after the state had kind of convened a grand jury, the grand jury came back with something that,
[1:45:05]I don't remember the charge, but it wasn't that charge.
[1:45:08]And the consequence for that charge was mandatory PTI,
[1:45:13]which was much less than obviously the police chief line.
[1:45:17]And so what happened during the course of the federal investigation
[1:45:24]is the U.S. Attorney's Office wanted something more than that and wanted him to plea
[1:45:33]to charges that would one, put him in jail, and two,
[1:45:38]plea to charges for which there would be a sex offender registration requirement.
[1:45:45]And the charge that they ultimately said you should go back to the state and make them
[1:45:52]charge you this was a charge that the defense team had been saying that they
[1:45:59]didn't have the factual predicate to actually have that charge, but that will do it
[1:46:03]because that's what you want to get this thing resolved.
[1:46:06]So the troubling part of it, it's hard for me to know for sure what actually happened,
[1:46:15]what was true, what was not true.
[1:46:16]A lot of the allegations turned out not to be true.
[1:46:20]What about now?
[1:46:20]Do you have a belief as to whether girls and women were abused in Florida?
[1:46:25]Well, again, after he was arrested the second time and then died,
[1:46:34]lots of people have come forward, lots of people who didn't come forward before
[1:46:39]who said that they hadn't come forward.
[1:46:40]But since then, as the co-chair executive of the state,
[1:46:44]I've been made aware of many, many claims.
[1:46:48]And so with that number of claims being made,
[1:46:52]it's really hard to say that no, he didn't do anything.
[1:46:54]Obviously, he did a lot of terrible things.
[1:46:56]So my view is I don't know exactly what he did.
[1:47:00]And I'd say this again because I want everybody to be clear about this.
[1:47:03]I didn't see it.
[1:47:04]I didn't see anything and nobody complained to me about anything.
[1:47:08]So I don't know.
[1:47:09]But all these people came forward.
[1:47:11]So obviously there's something there.
[1:47:14]So your question is, what do I believe now?
[1:47:17]I believe he did bad things.
[1:47:21]At any point after you learned about Mr. Epstein's arrest in Florida,
[1:47:28]did you ever consider quitting your job?
[1:47:33]With all of the discussion about how the answer is,
[1:47:38]I don't think I did.
[1:47:39]You know, I'm going back in time.
[1:47:41]I don't think I did.
[1:47:42]And the explanation for that is twofold.
[1:47:45]With all of the discussion about the defects in the investigation,
[1:47:50]and statements from the lead prosecutor, and all this stuff,
[1:47:54]and the lie detector test, and all of these other things.
[1:47:57]I think there was even a psychological evaluation
[1:48:01]that said he wasn't a pedophile.
[1:48:02]So all of these conflicting reports came.
[1:48:04]It sounded to me, it seemed to me,
[1:48:06]who was very inexperienced with this stuff,
[1:48:09]that maybe it wasn't what they were saying.
[1:48:14]When taking into consideration all of that information,
[1:48:17]it sounds like you were weighing the question.
[1:48:20]No, I'm weighing the question now.
[1:48:21]The question then was, I was, you know, I drank the Kool-Aid at the time.
[1:48:30]I think that's the answer, is I drank the Kool-Aid at the time.
[1:48:40]So I think our members have some questions for you.
[1:48:42]Okay, great.
[1:48:43]Serendak, I have a couple questions.
[1:48:45]Before, just to follow up,
[1:48:46]do you personally believe that girls and women
[1:48:48]were abused by Jeffrey Epstein in Palm Beach?
[1:48:52]I do believe that Epstein engaged in bad conduct with women, yes.
[1:48:56]Do you believe that girls and women were abused
[1:48:59]I believe so, yes.
[1:49:00]Raped?
[1:49:01]I don't know.
[1:49:02]Okay, let me get a couple questions.
[1:49:03]Serendak, I want to ask a few questions related to Jane Doe Four
[1:49:07]from the case Doe versus Jeffrey Epstein
[1:49:09]out of the Southern District of New York.
[1:49:12]Now, Jane Doe Four alleged that she met Epstein
[1:49:16]in South Carolina in the 1980s
[1:49:18]and through him was introduced to President Trump,
[1:49:21]who we know the allegation was that he abused her when she was 13
[1:49:26]and these are allegations made by Jane Doe Four.
[1:49:28]Are you aware of Jane Doe Four?
[1:49:32]I'm aware of the case Jane Doe Four.
[1:49:37]You're aware of Jane Doe Four?
[1:49:38]Aware of the case Jane Doe Four.
[1:49:40]I'm not aware of the person.
[1:49:42]Do you know the identity of Jane Doe Four in this case?
[1:49:46]I don't.
[1:49:47]So you do not know the identity of Jane Doe Four?
[1:49:49]I couldn't tell you.
[1:49:50]Okay, have you ever seen a document
[1:49:53]with the identity of Jane Doe Four?
[1:49:55]I'm sure I must have.
[1:49:56]You have seen a document?
[1:49:58]I'm sure I must have.
[1:49:59]Now, last week, Mr. Conn, who's a co-executive of the estate,
[1:50:02]testified that Jane Doe Four had received a settlement
[1:50:06]from the Epstein estate, of which you're a co-executive.
[1:50:09]Now, later in the deposition,
[1:50:10]when oversight staff attorneys asked about the settlement
[1:50:13]involving Jane Doe Four,
[1:50:15]Mr. Conn's attorney clarified on the record,
[1:50:17]according to his team,
[1:50:19]that Mr. Conn's earlier testimony had been mistaken
[1:50:22]and that neither he nor Mr. Conn recognized Jane Doe Four
[1:50:26]as someone who had filed the claim against the Epstein estate.
[1:50:30]Now, since then, there's been additional back and forth
[1:50:33]and confusion about the details of Jane Doe Four
[1:50:35]and her interactions with the estate,
[1:50:37]and there's been back and forth and clarification.
[1:50:39]So I just want for clarity, since you're a co-executive.
[1:50:42]Now, Mr. Conn, and given your position
[1:50:46]as a co-executive of the estate for both,
[1:50:48]did Jane Doe Four receive a settlement from the estate?
[1:50:50]So let me be clear.
[1:50:52]As your position as a co-executive of the estate,
[1:50:53]did Jane Doe Four receive a settlement from the estate?
[1:50:56]So, Congressman McCarthy, I just have to say two things
[1:50:58]about anything with Jane Doe's.
[1:51:01]The first is we're bound by court orders
[1:51:04]not to say anything about the identity.
[1:51:06]To the extent someone has sued under a Jane Doe name,
[1:51:11]we're not permitted by court orders
[1:51:13]to say who the person is at all.
[1:51:16]Secondly, putting aside whether it's someone
[1:51:19]as a Jane Doe or somebody specifically identified,
[1:51:22]we are bound in confidentiality requirements
[1:51:25]in any settlement.
[1:51:26]We are, as the estate and the co-executives,
[1:51:29]to not identify if someone has settled
[1:51:31]or anything about the settlements.
[1:51:33]Having said that, any of those claimants
[1:51:35]who have settled, typically they are not bound by that.
[1:51:38]So, you know, you're free to ask them
[1:51:40]if they want to identify things,
[1:51:41]but we cannot do that.
[1:51:45]Aside from the identity
[1:51:47]and disclosing the identity to us of Jane Doe Four,
[1:51:51]any NDAs or non-disclosure agreements
[1:51:54]as we have made clear in prior cases,
[1:51:57]Congress does not recognize.
[1:51:58]And we have the ability to determine
[1:52:00]whether we do and do not recognize.
[1:52:02]In this case, given that you were under subpoena,
[1:52:04]we would ask that you provide us information
[1:52:06]whether Jane Doe Four perceived to settle.
[1:52:08]And let me continue.
[1:52:11]Yeah, but let me just say to that quickly
[1:52:13]that putting aside whatever order may come out
[1:52:16]requiring them to disclose, I believe,
[1:52:18]but I'd have to look at
[1:52:19]each particular settlement agreement.
[1:52:21]We likely have notice provisions
[1:52:23]to the person settling
[1:52:25]if we were bound to disclose it
[1:52:27]to first notify that person
[1:52:29]because they could probably take...
[1:52:31]To be clear, you're not confirming or denying
[1:52:33]that there's a settlement with Jane Doe Four, is that correct?
[1:52:35]We cannot.
[1:52:36]So, Mr. Indyke, was there a settlement paid
[1:52:39]from the Epstein Victim Compensation Program
[1:52:42]to any Jane Doe or Jane Doe Four?
[1:52:45]We have the same confidentiality restrictions.
[1:52:48]So you're unwilling to answer
[1:52:49]if there was actually a payment
[1:52:51]from the Epstein Victim Compensation?
[1:52:53]It's not a willingness issue.
[1:52:54]It's a bound by confidentiality.
[1:52:57]I'm not going to take that premise,
[1:52:58]but I understand your position.
[1:53:01]Mr. Indyke, do you have any additional information
[1:53:03]on Jane Doe Four that you can provide us?
[1:53:06]No.
[1:53:07]Okay, great.
[1:53:11]Mr. Indyke, the Epstein estate
[1:53:16]has provided documents and productions
[1:53:18]to this committee per subpoena, as you're aware,
[1:53:21]and we have welcomed those, of course,
[1:53:23]and we've gone through those
[1:53:25]and we have continued to go through
[1:53:27]what's been provided.
[1:53:28]Not all the documents have still been provided
[1:53:30]to the committee.
[1:53:31]There's still some documents we believe
[1:53:33]that are in your possession, is that correct?
[1:53:38]In my possession, personally?
[1:53:39]In the possession of your estate.
[1:53:42]In response to the subpoena?
[1:53:43]In response to the subpoena.
[1:53:45]I think based on conversations that council has had
[1:53:48]with both minority and majority staff,
[1:53:50]we've complied with what everyone was expecting.
[1:53:53]If there's more that people were expecting
[1:53:54]that are, let us know.
[1:53:55]Are there additional documents with the estate
[1:53:58]that have not been provided to the committee
[1:54:00]within the bounds of the subpoena?
[1:54:02]Within the bounds of the subpoena?
[1:54:04]Based upon responses, my understanding from council
[1:54:07]is that whatever was agreed upon to be provided
[1:54:10]has been provided.
[1:54:11]Okay, are there additional documents within
[1:54:13]that the estate has outside the dates of the subpoena,
[1:54:17]that the subpoena was given,
[1:54:18]that are in possession of the estate?
[1:54:20]I'm sorry, outside the dates?
[1:54:22]So the subpoena obviously has dates
[1:54:27]of when to produce documents, period of time.
[1:54:29]Are there documents in the possession of the estate,
[1:54:32]outside the period of time, within the subpoena,
[1:54:36]that are in the possession of you and Mr. Cahn
[1:54:38]as the co-executives of the estate?
[1:54:42]I'm a little bit at a loss here because, you know,
[1:54:45]what I did is, what I did in my co-execution.
[1:54:48]So what you're saying is you won't answer the question
[1:54:50]if there's additional documents in possession?
[1:54:52]I'm trying to answer your question, sir.
[1:54:56]The estate essentially gave the documents to council.
[1:55:01]So I'm a little bit of a loss as to how to answer
[1:55:06]that question without conferring with council
[1:55:08]and council telling me what was it.
[1:55:10]I mean, I think the question is pretty simple.
[1:55:12]The subpoena has a period of time
[1:55:15]where you should be producing documents
[1:55:16]within that period of time.
[1:55:18]Specified documents.
[1:55:21]We gave you all the documents that were specified.
[1:55:23]Correct. So my question is,
[1:55:25]are there additional documents related
[1:55:27]to Jeffrey Epstein and communications
[1:55:29]outside the period of time specified in subpoena
[1:55:32]that are in the possession of the Epstein estate?
[1:55:34]That you didn't ask for.
[1:55:36]That we didn't ask for.
[1:55:37]So the subpoena, you're saying,
[1:55:38]gave us all the documents in the estate.
[1:55:40]The question's really clear.
[1:55:41]Are there additional documents outside the period of time
[1:55:44]specified in the subpoena
[1:55:45]that are in possession of the Epstein estate?
[1:55:48]I assume so, yes.
[1:55:48]You assume so, yes.
[1:55:49]Yes, yes.
[1:55:50]Okay, thank you.
[1:55:56]Next is here.
[1:55:58]Thank you for being here.
[1:56:01]My first question.
[1:56:02]During your employment by Jeffrey Epstein,
[1:56:04]did you ever become aware of a relationship
[1:56:06]between Epstein and Donald Trump?
[1:56:10]The answer to that question is yes.
[1:56:13]Aware of a relationship that existed before my time.
[1:56:18]Okay. Did you ever become aware of Donald Trump
[1:56:20]socializing with Epstein during your employment?
[1:56:24]No.
[1:56:25]And again, my relationship with Epstein
[1:56:27]was not a social relationship like that.
[1:56:31]And I don't believe Donald Trump
[1:56:34]was ever in the office when we were there in New York.
[1:56:41]And I don't recall off the top of my head
[1:56:45]whether or not Epstein specifically met with him
[1:56:49]while I was employed as an attorney for Epstein.
[1:56:51]And to confirm, you began your employment
[1:56:54]with Mr. Epstein in 1996?
[1:56:57]1996, yes.
[1:56:58]And you said before your time.
[1:57:00]So you're not aware of any relationship
[1:57:02]between the two men after 1996?
[1:57:06]I am not personally aware of the relationship
[1:57:10]they had between the time that I was there.
[1:57:12]You know, from the time that I was there going forward.
[1:57:14]Do you believe they had a relationship?
[1:57:17]What I recall is that at some point,
[1:57:20]whatever relationship did exist, no longer existed.
[1:57:25]And I recall that it no longer existed
[1:57:27]because of some dispute relating to some property in Palm Beach.
[1:57:33]But I can't tell you what that relationship was
[1:57:35]from the time I was there going forward.
[1:57:38]Because I don't know.
[1:57:40]So you're saying you were not aware of
[1:57:42]Donald Trump socializing with Epstein.
[1:57:44]What about with any women connected to Epstein?
[1:57:50]I believe that I had learned through a subsequent lawsuit
[1:57:56]that there was an allegation that Trump,
[1:58:02]that President Trump and,
[1:58:06]well, not President Trump at the time,
[1:58:07]but Donald Trump at the time,
[1:58:10]had some kind of interaction with the person alleging abuse.
[1:58:18]Some type of interaction.
[1:58:19]I don't recall specific details of it.
[1:58:23]When did you become aware of this allegation?
[1:58:30]I believe that I received a copy of a lawsuit.
[1:58:36]So when that lawsuit was filed, then I became aware.
[1:58:40]Do you have any sense of when that was?
[1:58:42]What year that was?
[1:58:42]It was years ago.
[1:58:44]I really don't.
[1:58:45]It was years ago.
[1:58:48]But you first said you believe that post-1996,
[1:58:51]Donald Trump and Epstein did not have a relationship.
[1:58:54]At some point after that, you became aware of a lawsuit.
[1:58:57]Yes.
[1:58:58]Donald Trump and Dr. Epstein had an allegation.
[1:59:01]I believe the allegation in that lawsuit predated
[1:59:05]the time that I was working for Epstein.
[1:59:09]I believe.
[1:59:10]I mean, if somebody could show me the lawsuit,
[1:59:12]I could read it and see the difference.
[1:59:15]That lawsuit was 2009.
[1:59:17]The lawsuit was in 2009?
[1:59:18]That's when Trump was deposed
[1:59:20]and that's when Epstein was scheduled to be deposed.
[1:59:24]Do you recall the allegation, the date of the allegation?
[1:59:29]Exactly.
[1:59:29]They are 90s.
[1:59:30]Have you ever discussed Donald Trump's connection
[1:59:32]to Epstein with anyone?
[1:59:35]Other than the privilege conversations that I've had.
[1:59:39]Meaning with his lawyers?
[1:59:41]Correct.
[1:59:43]During your employment by Epstein,
[1:59:44]did you ever become aware of Donald Trump
[1:59:46]visiting a property owned by Epstein,
[1:59:48]either in New York, New Mexico, Paris, Ireland?
[1:59:55]During your employment by Epstein,
[1:59:56]did you ever become aware of the relationship
[1:59:57]between Epstein and Howard Lutnick?
[2:00:03]No, I didn't know that there was a relationship
[2:00:08]between Epstein and Howard Lutnick.
[2:00:10]So you weren't aware that Mr. Lutnick
[2:00:12]was Epstein's next-door neighbor in Manhattan?
[2:00:15]Yes, but I was aware that he was a neighbor in Manhattan,
[2:00:17]but I wasn't aware that they actually had a relationship.
[2:00:20]Okay.
[2:00:20]I believe that's my time.
[2:00:23]Thank you.
[2:00:23]I'm going to hand you a copy of an exhibit, exhibit A.
[2:00:30]And this is a consent order issued
[2:00:32]by the New York State Department of Financial Services
[2:00:34]regarding the Deutsche Bank of the Live 2020.
[2:00:37]I'd like you to turn to page 16, paragraph 48.
[2:00:42]And that reads,
[2:00:43]several of Mr. Epstein's employees or agents
[2:00:46]had authority to conduct transactions
[2:00:48]in the accounts on Mr. Epstein's behalf.
[2:00:51]One of them, Mr. Epstein's personal attorney
[2:00:53]was active in withdrawing cash from Mr. Epstein.
[2:00:56]Attorney 1, on behalf of Mr. Epstein,
[2:00:58]made a total of 97 withdrawals
[2:01:00]from the Bank Park Avenue in the New York City branch
[2:01:02]from 2013 to 2017,
[2:01:05]personal accounts belonging to Mr. Epstein's.
[2:01:07]So my first question for you, Mr. Indyke,
[2:01:09]is attorney 1 here listed, is that you?
[2:01:12]I believe that's me, yes.
[2:01:13]And can you explain why you were making these withdrawals?
[2:01:20]At this time, there was a great deal of negative publicity.
[2:01:28]Was this done at the correction of Mr. Epstein?
[2:01:30]I guess I'll start there.
[2:01:33]I would like him to answer the question.
[2:01:34]If the question is asked, I know,
[2:01:36]but he has an answer to a serious allegation.
[2:01:39]No, I'm asking first,
[2:01:40]were these at the direction of Mr. Epstein?
[2:01:41]Okay.
[2:01:44]No, I do not believe that they were
[2:01:45]at the direction of Mr. Epstein.
[2:01:47]Do you know what the cash was used for?
[2:01:50]I don't have a specific knowledge
[2:01:52]of what the cash in each instance was used for,
[2:01:54]but I know generally or believe generally
[2:01:58]that when I made cash withdrawals,
[2:02:00]they were for things or petty cash
[2:02:04]to supply the households for supplies,
[2:02:09]for cleaning supplies, food.
[2:02:13]You gave the cash to who then?
[2:02:15]Just to be clear, I don't think he was done.
[2:02:17]That's okay.
[2:02:17]I just want the record to be clear.
[2:02:19]I know, but you can't,
[2:02:21]but if he's not allowed to answer the questions,
[2:02:23]it doesn't matter.
[2:02:25]Okay, but just to be clear,
[2:02:26]he wasn't done.
[2:02:27]If you want to go on, that's fine.
[2:02:28]I'm asking a follow-up question here,
[2:02:29]which was the cash.
[2:02:30]Who actually received the cash?
[2:02:32]The cash went to the accounting department.
[2:02:34]Accounting department of Mr. Epstein?
[2:02:38]So there was an office down the hall for my office
[2:02:42]where the accounting function for Mr. Epstein
[2:02:46]and his homes was prevalent.
[2:02:50]Somebody from the accounting office
[2:02:52]would ask me to go to the bank
[2:02:54]to get money for the petty cash,
[2:02:56]and the petty cash would service
[2:02:58]the various households.
[2:02:59]There were five different households,
[2:03:02]and I would go to the bank
[2:03:04]with a check drawn on Mr. Epstein's account.
[2:03:08]The bank knew what was from Mr. Epstein's account,
[2:03:11]and I would get the cash
[2:03:12]and give it back to the accounting department.
[2:03:14]This is a lot of cash I just want to note.
[2:03:16]$7,500 per withdrawal,
[2:03:18]and that would be 97 withdrawals.
[2:03:21]That is over the course of 16 months,
[2:03:23]a total of over $725,000 in cash.
[2:03:27]Just to be clear, that paragraph says it's four years,
[2:03:29]not 16 months.
[2:03:30]60, 60.
[2:03:31]I'm sorry, I misheard you.
[2:03:33]Thank you.
[2:03:33]Four years, so 16 months.
[2:03:35]That's a lot of cash, $725,000.
[2:03:38]It's a large amount of cash.
[2:03:39]As a lawyer, did that not concern you
[2:03:41]or raise any red flags?
[2:03:42]Well, if you knew that Mr. Epstein
[2:03:45]had five multi-million dollar residences,
[2:03:47]or six actually with the other island,
[2:03:49]had dozens of staff members,
[2:03:51]didn't have use of credit cards,
[2:03:53]all of those residences had lots of rooms,
[2:03:56]lots of people working there that needed food,
[2:03:58]that needed supplies,
[2:03:59]that needed equipment,
[2:04:00]that needed tools.
[2:04:02]Your knowledge was any of that?
[2:04:03]I'm only saying this, sir,
[2:04:04]because I'm running out of time.
[2:04:05]Was any of that money used to give cash payments
[2:04:08]to women or young girls?
[2:04:10]I just want the record to be clear
[2:04:11]that he had not finished his prior answer,
[2:04:12]but go ahead.
[2:04:13]So I did not believe that any amount of cash
[2:04:17]that I gave to the accounting department
[2:04:21]was going to be used for an improper purpose.
[2:04:24]I believe that there were legitimate reasons
[2:04:26]to bring that cash in, and I did so.
[2:04:30]Now, I want to switch topics here.
[2:04:31]Do you have any kind of written
[2:04:33]representation agreement with Mr. Epstein
[2:04:35]for the scope of your services
[2:04:36]as an attorney, a retainer agreement,
[2:04:38]anything like that?
[2:04:40]I believe at some point I did.
[2:04:42]That's not available in the file,
[2:04:44]so produce those.
[2:04:45]I don't know that I actually have it anymore.
[2:04:47]You don't have it anymore, okay.
[2:04:48]What were the terms of your scope of representation
[2:04:51]and also your payment agreement with Mr. Epstein?
[2:04:54]The payment was decided on an annual basis.
[2:04:57]It wasn't decided.
[2:04:58]Not upfront, not based on hour?
[2:05:00]No.
[2:05:01]Just whatever he decided to pay you,
[2:05:03]that's what you received?
[2:05:06]The answer is yes,
[2:05:08]but he had always been generous with me,
[2:05:10]so I didn't have any reason to doubt.
[2:05:13]He was very generous with you.
[2:05:14]So from 2003 to 2013,
[2:05:16]according to public reports,
[2:05:18]your personal bank account received
[2:05:19]more than $2.4 million from Epstein,
[2:05:22]while your business account received
[2:05:23]over $8.3 million.
[2:05:25]You also received a loan
[2:05:27]that was never repaid of $7 million,
[2:05:31]and a copy of Mr. Epstein's trust showed
[2:05:34]that he planned to leave you $50 million,
[2:05:38]which was matched only by
[2:05:39]his girlfriend, Karina Chuliak.
[2:05:43]What were you doing for him
[2:05:44]that made him so generous to you?
[2:05:46]I think I've already discussed
[2:05:48]all of the things that I did
[2:05:49]for Mr. Epstein,
[2:05:50]which were all legitimate legal tasks.
[2:05:54]I was working for him
[2:05:55]at least six days a week,
[2:05:56]sometimes seven days a week.
[2:05:58]I was on call 24 hours a day with him,
[2:06:01]and I was not at liberty
[2:06:02]to take on other clients
[2:06:04]in a way that other lawyers
[2:06:06]in private practice would want
[2:06:07]to take on clients
[2:06:08]to continue their business.
[2:06:12]Thank you.
[2:06:12]Thank you.
[2:06:13]Congressman Sanford.
[2:06:16]So I represent Albuquerque, New Mexico,
[2:06:19]and Zora Ranch is just north
[2:06:21]of my congressional district,
[2:06:22]and as you're probably aware,
[2:06:25]New Mexico has opened a truth commission
[2:06:27]and reopened the criminal investigations
[2:06:29]into what happened at the ranch.
[2:06:31]So my questions are primarily
[2:06:33]fact-finding less so much
[2:06:35]about your specific role,
[2:06:37]but really about the ranch
[2:06:38]and the investigations
[2:06:39]and why DOJ asked the state
[2:06:42]to drop their case.
[2:06:43]I also have a follow-up question
[2:06:45]about Trump as well as
[2:06:48]your work on the defense team.
[2:06:50]So that's kind of the scope
[2:06:51]of what I want to ask about.
[2:06:53]As I understand it,
[2:06:54]you helped to manage the assets
[2:06:56]at Zora Ranch, is that correct?
[2:06:58]I wouldn't say I helped
[2:06:59]to manage the assets.
[2:07:05]Were you involved in any legal
[2:07:07]or financial matters
[2:07:09]over the course of your employment
[2:07:10]with Jeffrey Epstein and Zora Ranch?
[2:07:12]I was, yes.
[2:07:12]Did you ever travel there?
[2:07:14]I traveled to the ranch
[2:07:17]I want to say two or three times.
[2:07:19]And are you aware
[2:07:21]that there are multiple allegations
[2:07:23]that were taken by the FBI
[2:07:26]of sexual abuse at the ranch?
[2:07:28]I have been made aware
[2:07:30]of those allegations, yes.
[2:07:31]Were you involved in any way
[2:07:33]legal or financial
[2:07:35]in the defense of Mr. Epstein
[2:07:38]either in a state case
[2:07:40]or a federal case at the ranch?
[2:07:41]No.
[2:07:44]A civil case?
[2:07:46]You were involved in a civil case?
[2:07:48]In a civil case,
[2:07:49]and I believe there was a case
[2:07:52]relating to wanting to
[2:07:54]there was a grazing lease
[2:07:56]that was taken away.
[2:07:58]But in any of the sexual abuse cases?
[2:08:01]Do you have any personal knowledge
[2:08:03]and or can you share with us
[2:08:05]why DOJ asks the state of New Mexico
[2:08:07]to drop its investigation
[2:08:09]into sexual abuse?
[2:08:10]I have no personal knowledge of that.
[2:08:12]I want to move on
[2:08:13]to a follow-up question on Trump
[2:08:15]and this suit that was filed
[2:08:19]by a young woman
[2:08:22]against Bo Trump and Epstein
[2:08:24]for abuse at her house.
[2:08:26]As I understand it,
[2:08:27]looking at both the responsive documents
[2:08:29]that the estate sent us
[2:08:31]as well as separately the DOJ's files,
[2:08:34]it appears to me
[2:08:35]that these are two separate cases.
[2:08:37]Is that true?
[2:08:38]Could you repeat the question?
[2:08:39]So it appears to me
[2:08:41]that the Jane Doe four FBI files
[2:08:44]that the federal government is tracking
[2:08:48]in which a young woman
[2:08:49]was interviewed four times
[2:08:51]by the FBI for abuse
[2:08:52]at Jeffrey Epstein's New York estate
[2:08:54]is a separate case
[2:08:56]from the lawsuit
[2:08:57]that was filed in 2009
[2:08:59]against Jeffrey Epstein
[2:09:00]and Donald Trump.
[2:09:01]Is that true?
[2:09:01]I don't know.
[2:09:04]Did you help to process the files
[2:09:06]from the estate
[2:09:06]that were sent to the committee?
[2:09:11]The answer to your question is I did.
[2:09:12]Yes.
[2:09:12]Okay, so you're aware
[2:09:13]that in the files
[2:09:15]that I did not.
[2:09:19]All of the files from the estate
[2:09:20]went over to the lawyers
[2:09:21]with instructions to comply
[2:09:23]with all lawful requests.
[2:09:24]So it was handled by an outside firm
[2:09:26]rather than you?
[2:09:27]It was handled by the law firm.
[2:09:29]Okay.
[2:09:30]Did you review the documents?
[2:09:31]No, not the volume of documents.
[2:09:35]But you are aware
[2:09:36]as was just established
[2:09:37]that there was a lawsuit in 2009
[2:09:39]and there's documentation
[2:09:41]in the files
[2:09:42]that were transmitted
[2:09:43]from the estate
[2:09:44]that actually state
[2:09:47]that Epstein was scheduled
[2:09:48]for a deposition in that case, correct?
[2:09:52]I'm trying.
[2:09:53]I am aware.
[2:09:53]I'm certainly aware now.
[2:09:56]And I was aware generally of the case.
[2:10:01]I think I was aware
[2:10:04]at some point
[2:10:04]that there was a request
[2:10:06]for a deposition.
[2:10:09]These are scheduling documents
[2:10:11]that came from the estate.
[2:10:12]Was he deposed in that case?
[2:10:13]I don't believe he was, no.
[2:10:14]Do you know why?
[2:10:15]I don't.
[2:10:16]Okay.
[2:10:16]So that goes to my final set of questions,
[2:10:19]which is,
[2:10:20]did you personally
[2:10:21]or anyone that you worked with
[2:10:24]make any payments
[2:10:26]or financial transfers
[2:10:27]to any lawyers,
[2:10:29]law enforcement officers, DOJ,
[2:10:31]or state attorneys
[2:10:33]involved in cases
[2:10:34]against Jeffrey Epstein
[2:10:35]for sexual abuse?
[2:10:38]Say that one more time
[2:10:39]because that's a lot to unpack.
[2:10:41]So I think just to be clear
[2:10:43]because you asked lawyers.
[2:10:44]Do you mean lawyers
[2:10:45]for some government in that question?
[2:10:47]Yeah.
[2:10:47]Okay.
[2:10:48]Okay.
[2:10:49]I'll ask it slightly slower
[2:10:51]because we are in a time constraint here.
[2:10:53]I apologize.
[2:10:53]Really what I'm trying to establish,
[2:10:56]if I may have a moment to establish it
[2:10:58]because it's an important piece
[2:10:59]of the question here,
[2:11:00]that we're trying to get to the bottom.
[2:11:02]The overall point here is
[2:11:05]why did DOJ and state entities
[2:11:08]not prosecute these crimes
[2:11:09]in a more timely manner?
[2:11:11]And it has been alleged by survivors
[2:11:13]that they received some sort of payment.
[2:11:16]Maybe there were transfers of money involved.
[2:11:19]And so let me ask specifics.
[2:11:21]Did Alex Acosta,
[2:11:22]as the U.S. Attorney
[2:11:24]for the Department of Justice
[2:11:26]ever receive any money
[2:11:27]from Jeffrey Epstein
[2:11:29]as a state
[2:11:30]or any of its business entities?
[2:11:33]My knowledge?
[2:11:34]No.
[2:11:36]To your personal knowledge,
[2:11:37]you're saying no,
[2:11:38]but is it possible that he did?
[2:11:40]I don't know.
[2:11:40]Did any other law enforcement agents,
[2:11:43]to your knowledge?
[2:11:44]I don't believe so,
[2:11:45]but I don't think.
[2:11:46]But you don't know.
[2:11:47]Okay.
[2:11:48]Thank you.
[2:11:48]Thank you.
[2:11:49]Representative Walkinshaw.
[2:11:50]Thank you, Mr. Indike.
[2:11:51]I want to go back to compensation.
[2:11:53]So when you started working for Mr. Epstein,
[2:11:57]what was your compensation?
[2:11:59]It was an annual salary.
[2:12:01]You were going to roughly be amounts
[2:12:03]or was it hourly?
[2:12:04]No, when I started,
[2:12:05]it was around,
[2:12:07]I want to say 450 or 400 or so.
[2:12:11]$450,000 a year.
[2:12:13]Yes.
[2:12:14]Okay.
[2:12:15]And did you,
[2:12:16]in addition to that,
[2:12:17]receive any kind of
[2:12:18]bonus compensation
[2:12:19]or incentive structure?
[2:12:23]I don't recall on a year-to-year basis.
[2:12:30]When I went back to think about it,
[2:12:32]what I remember at the beginning
[2:12:33]was about $450,000.
[2:12:36]And that salary,
[2:12:37]I presume increased over time
[2:12:39]over the course of 23 years?
[2:12:40]It did.
[2:12:41]Okay.
[2:12:42]And from the time
[2:12:43]that you were hired
[2:12:45]until Epstein's death,
[2:12:48]could you tell us roughly
[2:12:50]ballpark how much you were paid?
[2:12:53]Total ballpark between
[2:12:55]27 to 30 million dollars
[2:12:58]for 23 years.
[2:13:01]Roughly comes out to about
[2:13:02]a million and a few years.
[2:13:05]And there's been reference already
[2:13:07]to one loan you received
[2:13:09]from Mr. Epstein.
[2:13:11]It was a series of loans
[2:13:12]for that one.
[2:13:13]How many?
[2:13:16]Total, I think, 7 million.
[2:13:18]I believe that's...
[2:13:19]Okay.
[2:13:19]7 million.
[2:13:20]And what was the purpose of the loans?
[2:13:23]Why did you need the loans?
[2:13:24]Why did they give you the funds?
[2:13:28]Ultimately, the idea was that
[2:13:29]I was going to do investing
[2:13:31]on my loans.
[2:13:33]Did you end up doing investing?
[2:13:34]I invested in one thing.
[2:13:36]What did you do with the rest?
[2:13:38]7 million dollars.
[2:13:39]I wanted to use it.
[2:13:41]You spent it?
[2:13:41]I spent it, yes.
[2:13:42]Okay.
[2:13:43]And can you give us roughly
[2:13:44]the years that you received
[2:13:46]these loans?
[2:13:52]2013 to 2018.
[2:14:00]So 7 million dollars
[2:14:02]in 5 years you made
[2:14:05]some minimal investment
[2:14:07]and you spent the rest.
[2:14:08]I mean, what did you spend it on?
[2:14:11]I support a lot of people
[2:14:12]in my household.
[2:14:13]I support both mothers,
[2:14:15]all of their health expenses.
[2:14:17]I support my sister-in-law
[2:14:18]who's got a granddaughter
[2:14:20]that she also takes care of.
[2:14:22]I support her as well.
[2:14:26]You needed the money.
[2:14:27]You needed all of it.
[2:14:28]I used the money.
[2:14:33]And how many of these loans
[2:14:35]or how much
[2:14:36]of the total loan amount
[2:14:38]was ultimately forgiven
[2:14:39]by Mr. Epstein?
[2:14:41]Before we get there,
[2:14:43]I've been paying interest
[2:14:45]all the way through him
[2:14:45]by the time that he died.
[2:14:47]That's actually one of my next questions.
[2:14:51]And the answer to your question
[2:14:53]is that according to the estate plan,
[2:14:57]all of the loans
[2:14:58]were to be forgiven.
[2:15:02]Upon his death
[2:15:03]or when the estate is?
[2:15:06]Well, right now
[2:15:08]it's up in the air
[2:15:09]because there has to be enough
[2:15:11]money in the estate
[2:15:12]to cover it.
[2:15:13]Okay.
[2:15:14]Did Epstein ever pay you
[2:15:15]for anything beyond
[2:15:16]the legal services
[2:15:17]you've described here today?
[2:15:19]No, he never did.
[2:15:20]Did he give you anything else of value?
[2:15:22]Gifts?
[2:15:22]Real estate?
[2:15:23]We already talked about the IVF.
[2:15:25]Anything else?
[2:15:26]He helped me purchase a house
[2:15:27]the first time
[2:15:28]that money was paid back.
[2:15:31]The second time
[2:15:32]he helped me purchase a home
[2:15:35]by putting a
[2:15:37]purchasing my home in New Jersey,
[2:15:41]putting, going to contract
[2:15:42]the home in New Jersey.
[2:15:43]Did he ever make any payments
[2:15:44]directly to your wife
[2:15:46]or other family members?
[2:15:49]As part of the discussion
[2:15:51]that we were just having, yes.
[2:15:52]As part of this?
[2:15:53]Part of this money.
[2:15:54]Seven million?
[2:15:55]Some of that seven million
[2:15:56]went directly to your wife?
[2:15:58]The house.
[2:15:59]For the house.
[2:16:00]Ah, for the house.
[2:16:03]And you were asked earlier
[2:16:06]shared the IVF treatment funding?
[2:16:09]Yes, I'm sorry, yes.
[2:16:11]I definitely did that.
[2:16:12]I don't think you gave an amount
[2:16:14]roughly in terms of what he
[2:16:16]paid for the IVF treatment.
[2:16:18]It was five times.
[2:16:20]I know, I know.
[2:16:22]I recall
[2:16:24]that at the time
[2:16:25]the treatments,
[2:16:26]the medical portion of the treatments
[2:16:28]was something like $10,000.
[2:16:31]And there were,
[2:16:32]there's also the hormones
[2:16:34]that required to be purchased as well.
[2:16:37]I don't remember what they called.
[2:16:38]Okay, so 10,000 times five
[2:16:41]is what you can remember.
[2:16:42]I believe so, yes.
[2:16:44]Thank you.
[2:16:46]We're going to,
[2:16:47]our time here is done,
[2:16:48]but I have just one thing
[2:16:49]just to put into the record
[2:16:50]and just want to just be clear.
[2:16:51]Yes.
[2:16:51]It's our,
[2:16:52]it's our committee's
[2:16:54]opinion and understanding
[2:16:55]that within the subpoena
[2:16:57]that the Upton State
[2:16:58]has to actually provide us documents.
[2:17:01]There are actually two sections,
[2:17:03]section 15
[2:17:04]and section 16,
[2:17:06]but we have not received
[2:17:07]those documents.
[2:17:08]Now the majority may have
[2:17:11]directly dismissed
[2:17:13]those sections
[2:17:14]with all of you directly.
[2:17:15]We understand that perhaps
[2:17:16]the majority feels that
[2:17:18]the state has been
[2:17:19]fully responsive in the subpoena,
[2:17:21]but it's our understanding
[2:17:22]that we are still waiting
[2:17:23]for sections 15 and 16
[2:17:26]in the subpoena,
[2:17:27]and we,
[2:17:28]the minority still wants access
[2:17:30]to those documents.
[2:17:31]We believe that they're important.
[2:17:32]So I want to be sure
[2:17:32]I say that for the record.
[2:17:33]We don't believe the subpoena
[2:17:35]has actually been fully complied with yet.
[2:17:37]Thank you.
[2:17:37]I suggest,
[2:17:38]Congressman,
[2:17:39]that you talk to the majority
[2:17:40]because they know
[2:17:40]the answer to the question.
[2:17:42]We are awaiting instruction
[2:17:43]from the majority
[2:17:44]on those two sections.
[2:17:45]We are prepared
[2:17:46]to respond to them fully.
[2:17:47]We have responded fully
[2:17:48]to every request
[2:17:50]from the majority
[2:17:51]and the minority.
[2:17:51]We are awaiting instruction
[2:17:53]from the majority,
[2:17:53]which has been promised to us
[2:17:55]and not yet delivered.
[2:17:56]We look forward to the majority
[2:17:58]providing their response
[2:17:59]when we get those
[2:18:00]final sets of documents.
[2:18:01]Thank you.
[2:18:01]We'll offer it.
[2:18:16]We will go back on the record.
[2:18:19]Chairman Comer.
[2:18:20]Thank you.
[2:18:21]I have a couple of questions.
[2:18:22]You had mentioned earlier
[2:18:23]you in your legal capacity
[2:18:25]helped work some deals
[2:18:29]on stock transactions.
[2:18:32]Do you know anything
[2:18:33]about how he determined
[2:18:34]his investment strategy?
[2:18:35]Maybe not necessarily
[2:18:37]just with stocks
[2:18:37]but with real estate.
[2:18:39]Did he just come to you
[2:18:40]or did he or in conversations,
[2:18:42]did he say how he decided
[2:18:48]to purchase this property
[2:18:49]in Europe or this property
[2:18:52]in the United States?
[2:18:52]I mean, it's strange to me
[2:18:55]that a guy that went
[2:18:56]from being a substitute teacher
[2:18:58]to advising the richest
[2:19:01]and most powerful people
[2:19:02]in the world
[2:19:03]on their finances and taxes.
[2:19:06]Do you know or recall
[2:19:09]any conversations he had
[2:19:10]about how he determined
[2:19:12]which investments he would make?
[2:19:15]Jeffrey Epstein was somebody
[2:19:18]who made all of the decisions
[2:19:21]he made on his own without...
[2:19:22]He would consult individual people
[2:19:26]like for his attorneys
[2:19:26]he pulled pretty much
[2:19:28]every time he had an issue
[2:19:30]all the issues that were
[2:19:31]working on a project
[2:19:32]he would ask them questions
[2:19:34]specific questions
[2:19:35]that he wanted answers to.
[2:19:36]But then he would go out
[2:19:37]make his own decisions.
[2:19:38]He never discussed strategies.
[2:19:39]In fact, that was decidedly
[2:19:43]not something that he ever wanted
[2:19:45]to hear from me about
[2:19:47]and not something
[2:19:47]he ever discussed with me.
[2:19:48]I would take direction
[2:19:49]after decisions were made
[2:19:51]after conversations
[2:19:52]he had with his clients
[2:19:53]directly with his clients.
[2:19:55]I would take direction
[2:19:56]after that fact
[2:19:57]and not be part of their
[2:19:58]kind of thought processes
[2:20:00]to get there.
[2:20:01]So the answer to your question
[2:20:03]is no.
[2:20:04]Okay, so you mentioned
[2:20:08]he consulted with other people.
[2:20:09]Do you know which other people
[2:20:11]he consulted with?
[2:20:13]Did he ever say
[2:20:14]Bill Gates told me
[2:20:15]to buy Microsoft
[2:20:17]and fix it and split
[2:20:19]or anything like that?
[2:20:23]This is over a long period of time
[2:20:25]and there's not a conversation
[2:20:26]that I would say
[2:20:28]stood out in my mind
[2:20:29]where that's where he got
[2:20:30]the information for something.
[2:20:32]Most people who interacted with them
[2:20:36]it's my impression
[2:20:37]that they thought
[2:20:38]he was very, very smart.
[2:20:39]They thought he knew a lot of stuff
[2:20:41]that he was very knowledgeable
[2:20:43]about tax law
[2:20:44]barely knowledgeable
[2:20:45]about estate planning
[2:20:46]and people and currencies
[2:20:48]and people went to him for advice.
[2:20:51]Did he just pick that up on his own?
[2:20:53]I mean, he obviously
[2:20:54]didn't study it in school.
[2:20:56]I don't know.
[2:20:57]You don't know?
[2:20:58]But I know that he worked
[2:20:59]at Bear Stearns
[2:20:59]for a period of time
[2:21:02]and did, as I understand it
[2:21:06]because that's kind of anecdotal to me
[2:21:11]learned option trading
[2:21:12]or became very, very successful
[2:21:15]at option trading there
[2:21:16]at a time when option trading
[2:21:17]wasn't such a well-known thing.
[2:21:21]So he had a head for this stuff.
[2:21:24]Okay.
[2:21:24]At least that's the understanding
[2:21:26]that I have.
[2:21:29]And I don't think
[2:21:30]I don't think
[2:21:31]Pretty sophisticated
[2:21:33]in your own time clock there
[2:21:36]like Miss Pelosi is the
[2:21:39]most recent offender
[2:21:42]in my opinion of stock trading.
[2:21:43]That's a big issue in Congress
[2:21:45]and Pelosi does stock options
[2:21:46]and most people in Congress
[2:21:47]don't know what stock options are.
[2:21:49]But the concern
[2:21:52]about members of Congress
[2:21:54]or I would include Epstein
[2:21:56]trading options is
[2:21:59]you almost have to
[2:22:02]have a great deal of confidence
[2:22:04]that that stock's going to move
[2:22:06]in one direction or the other
[2:22:07]very soon.
[2:22:08]And that's where a lot of
[2:22:10]obviously insiders
[2:22:12]trade naked options
[2:22:13]and things like that.
[2:22:14]You don't ever recall
[2:22:16]Epstein saying
[2:22:17]I'm purchasing this stock option
[2:22:19]because I know it's fixing
[2:22:20]to crash in a week.
[2:22:23]No, I'm sorry.
[2:22:24]That's not the thing.
[2:22:25]That's not something
[2:22:26]he would ever discuss with me.
[2:22:28]You had mentioned you set up
[2:22:29]a bunch of the LLCs
[2:22:31]and I understand what you're saying
[2:22:32]to protect liability
[2:22:34]and things like that.
[2:22:34]Did he ever say why he needed to have
[2:22:37]so many LLCs to protect
[2:22:39]for liability?
[2:22:41]I don't think he
[2:22:43]one the answer to your question is
[2:22:45]no there was never conversation
[2:22:46]I need LLCs to protect liability.
[2:22:49]It was just it was
[2:22:51]for the clients that he had
[2:22:53]for example
[2:22:54]like Wexner had a bunch of LLCs
[2:22:56]a bunch of corporations set up
[2:22:58]and that was
[2:22:59]it was just considered
[2:23:00]that's what you do.
[2:23:01]You have a new business
[2:23:02]you set up a company for it.
[2:23:04]You have a new asset like a plane
[2:23:05]you set up a company for it.
[2:23:07]Never appeared to me
[2:23:10]to be anything other than
[2:23:11]a legitimate reason to
[2:23:13]to set up an entity
[2:23:14]and for somebody who has a lot of money
[2:23:16]and a lot of assets
[2:23:17]and a lot of business ventures
[2:23:20]if you're setting up separate entities
[2:23:21]for each
[2:23:21]there's just going to be a lot of them.
[2:23:23]I don't it was never meant
[2:23:25]to be a kind of a veil
[2:23:26]and the truth of the matter is that
[2:23:28]that anybody who interacted
[2:23:30]with any of these entities
[2:23:31]always knew that it was him
[2:23:32]that they were interacting with
[2:23:34]or at least my understanding was
[2:23:36]to my recollection they knew
[2:23:38]that they were interacting with him
[2:23:40]as the beneficial owner
[2:23:41]of the entity.
[2:23:42]The banks did certainly after 9-11
[2:23:43]the banks definitely knew
[2:23:45]so that it was him.
[2:23:46]How many LLCs would you estimate
[2:23:49]Epstein had?
[2:23:50]I don't think like
[2:23:51]I don't think I could tell you
[2:23:53]that more than 50.
[2:24:00]Maybe I don't know.
[2:24:01]I don't know.
[2:24:02]Some people would suspect
[2:24:03]he had a lot of LLCs
[2:24:05]and you know every property
[2:24:07]was a different LLC
[2:24:09]to protect himself from liability
[2:24:11]and this is a guy that now we know
[2:24:13]and you say you didn't know
[2:24:14]at the time but was you know
[2:24:16]potentially abusing women
[2:24:19]maybe underage women
[2:24:21]and obviously that would be
[2:24:24]an obvious reason to form a LLC
[2:24:27]on each separate property.
[2:24:30]I can respond to that if you like.
[2:24:31]I don't think that really works
[2:24:35]because it's a personal tort.
[2:24:37]If he engages in a personal tort
[2:24:38]for which he is simply liable
[2:24:40]it doesn't matter which entity
[2:24:43]that owned the property
[2:24:44]that it happened on
[2:24:46]you can go after him
[2:24:47]for engaging in the personal tort.
[2:24:48]Very nice.
[2:24:49]Okay.
[2:24:51]Go back.
[2:24:54]Just a couple of questions.
[2:24:57]He pled guilty in 2007
[2:25:01]and received an 18-month sentence.
[2:25:04]You wrote a letter for his
[2:25:07]plea for a new sentence
[2:25:08]but you wrote a part of the letter.
[2:25:11]Who were his attorneys
[2:25:12]that represented him
[2:25:13]during that time?
[2:25:17]It's a lot of the people
[2:25:18]and I gave you a list
[2:25:20]and I'll list them again.
[2:25:21]Did you know them?
[2:25:22]Did you recommend them?
[2:25:22]No.
[2:25:24]They came.
[2:25:24]They were in place
[2:25:26]and newly ones came into place.
[2:25:28]Did they predate you?
[2:25:29]You've obviously been there
[2:25:30]for close to 20 years.
[2:25:35]I don't know that they predated me.
[2:25:37]I don't know.
[2:25:39]I know that they were there.
[2:25:43]You said that there were three lawyers
[2:25:44]and there were two lawyers
[2:25:44]and then you were the first lawyer.
[2:25:46]Yeah.
[2:25:47]In 2007 were there
[2:25:49]just you or were there two or three?
[2:25:51]2007 I think it was just
[2:25:55]Jeff Shanson was no longer
[2:25:57]associated with him.
[2:25:59]So it was just me
[2:26:02]and I think the other attorney
[2:26:03]that was handling it.
[2:26:04]Were you involved in
[2:26:05]whatever the situation you had
[2:26:07]that allowed him to leave
[2:26:09]jail six days a week
[2:26:10]for 12 hours a day?
[2:26:11]That would have been
[2:26:14]his defense team,
[2:26:15]Jack Goldberg.
[2:26:16]That's pretty impressive.
[2:26:17]I mean not a lot of people
[2:26:19]get to go to jail for 18 months
[2:26:21]only serve 13 and get out
[2:26:22]12 hours a day six days a week.
[2:26:24]So my understanding
[2:26:25]and again this is not something I do
[2:26:28]but my understanding at the time.
[2:26:30]Yes but it's but you know
[2:26:33]criminal defense versus
[2:26:35]transactional work on a
[2:26:36]on a stock purchase agreement
[2:26:38]and different things.
[2:26:39]Oh wait you were going to explain.
[2:26:41]I am going to explain that.
[2:26:43]My understanding from the defense
[2:26:46]lawyer was that
[2:26:48]they were asking
[2:26:49]and they said it.
[2:26:51]I said it in response to
[2:26:53]I think claims I even by
[2:26:54]even by the assistant U.S. attorney
[2:26:56]that they were
[2:26:57]that this was not appropriate
[2:26:59]and my understanding
[2:27:00]from the defense lawyers
[2:27:01]is they requested and received
[2:27:03]only that which any other
[2:27:05]similarly situated person in jail
[2:27:08]would be entitled to at the time.
[2:27:10]That's that was my understanding
[2:27:13]and that's how East County
[2:27:14]had a very interesting
[2:27:15]system for work release.
[2:27:17]Okay that's just something
[2:27:18]I think the American people are like
[2:27:19]that's kind of strange but
[2:27:22]moving on.
[2:27:23]This morning there was a
[2:27:25]CBS news article that published
[2:27:29]that you I'll read it
[2:27:33]and like Tom recently said
[2:27:34]with a lawsuit accusing them
[2:27:35]of facilitating sham marriages
[2:27:37]in which foreign born
[2:27:38]victims married Americans
[2:27:39]who have been abused
[2:27:41]for immigration purposes.
[2:27:42]Can you tell us anything about the
[2:27:46]settlement?
[2:27:47]Who was it with?
[2:27:50]This settlement was in this
[2:27:52]it was just a
[2:27:53]fugitive class action lawsuit
[2:27:57]that in the settlement
[2:27:59]was by the estate
[2:28:01]as well as us.
[2:28:02]It was upwards of 35 million dollars
[2:28:07]to be paid to those
[2:28:08]who were abused by Mr. Epstein.
[2:28:11]How many plaintiffs were there?
[2:28:12]Can you tell us that?
[2:28:13]How many how many plaintiffs?
[2:28:16]There was one initially
[2:28:19]that plaintiff was dismissed
[2:28:21]out of the case
[2:28:23]another plaintiff came on
[2:28:25]and then the second
[2:28:26]plaintiff after that came up.
[2:28:28]Is this settlement public
[2:28:29]or is it private?
[2:28:31]It's I mean I believe
[2:28:33]that they filed a
[2:28:35]notice of the settlement
[2:28:37]in the court
[2:28:37]and I think the documents.
[2:28:38]What were the allegations
[2:28:39]underlined?
[2:28:42]Can I just make one thing clear
[2:28:43]because he made about
[2:28:44]the number of plaintiffs
[2:28:45]so that's the named plaintiffs
[2:28:46]but it's a class action
[2:28:47]so it's supposedly on behalf of
[2:28:49]some unknown number.
[2:28:50]Right and that class
[2:28:51]hasn't been certified.
[2:28:52]What were the allegations
[2:28:53]underlying the claim?
[2:28:58]I would refer you
[2:28:58]to the document itself
[2:29:00]but in substance
[2:29:02]it seemed to me
[2:29:04]that what was being said
[2:29:06]was that in in providing
[2:29:08]accounting services
[2:29:09]and in providing legal services
[2:29:11]that we did for Mr. Epstein
[2:29:13]that we facilitated his conduct
[2:29:16]of a sex trafficking enterprise.
[2:29:19]So it seems that
[2:29:20]there were foreign born women
[2:29:23]that their visa was going to expire
[2:29:28]and they were going to have to leave
[2:29:29]or they were going to be
[2:29:30]overstaying their visa
[2:29:31]and the scheme was
[2:29:35]to get the woman
[2:29:38]to marry an American.
[2:29:40]I mean I guess
[2:29:40]there's a lot of documentation
[2:29:41]associated with that
[2:29:42]and the allegations that you
[2:29:45]and Khan facilitated
[2:29:46]the underlying documents for that.
[2:29:48]Is that what the allegations were?
[2:29:51]I don't think that's accurate
[2:29:52]and again I tell you to go look
[2:29:54]please read the complaints
[2:29:55]and see what they were
[2:29:58]and again I can tell you that
[2:30:01]I never arranged
[2:30:03]I never facilitated
[2:30:05]I didn't even know about the marriage.
[2:30:06]What's your relationship
[2:30:07]with OSA properties?
[2:30:09]What's that?
[2:30:09]What's your relationship
[2:30:10]with OSA properties?
[2:30:12]I don't have a direct relationship
[2:30:14]with OSA.
[2:30:15]I don't have any relationship
[2:30:15]with OSA properties.
[2:30:16]Did you ever do any legal work
[2:30:17]associated with OSA properties?
[2:30:20]For example creating leases
[2:30:22]for individuals of a living name?
[2:30:25]I obtained a lease
[2:30:26]from OSA properties.
[2:30:28]You were a tenant of 301 East 66th Street?
[2:30:31]At one point I was a tenant, yes.
[2:30:32]Okay I'll ask the rest
[2:30:43]of my questions later.
[2:30:46]Thank you.
[2:30:47]Yeah Mr. Indige
[2:30:48]Yes.
[2:30:49]We appreciate your patience.
[2:30:50]We're going to be jumping around.
[2:30:52]Obviously we have the minority
[2:30:53]and majority asking questions
[2:30:55]and we would like to avoid repeat questions
[2:30:59]but I want to follow up first
[2:31:01]on Chairman Comer's questions
[2:31:03]as it related to the LLC.
[2:31:05]From your testimony
[2:31:07]it sounds like a lot of the time
[2:31:09]when Mr. Epsi would solicit opinions
[2:31:12]he would it be fair to say
[2:31:14]he already had his mind up
[2:31:15]of how he would want to proceed
[2:31:17]whether it was a particular transaction
[2:31:19]or the creation of an entity?
[2:31:22]I don't know that that's true
[2:31:23]or not true and I think
[2:31:25]it would depend on each circumstance.
[2:31:28]Did Mr. Epsi ever create LLCs
[2:31:31]or any other entities himself
[2:31:33]and then later inform you?
[2:31:37]I have no recollection of him
[2:31:39]ever doing so.
[2:31:41]Did you ever create LLCs
[2:31:43]for people that were employees of Epstein?
[2:31:46]Did I ever create an LLC
[2:31:48]for people that were employees of Epstein?
[2:31:51]There was an LLC called Lin and Jojo LLC.
[2:31:55]That was an LLC that acquired a home
[2:31:59]that Lin and Jojo
[2:32:02]who were staff members of his resided in.
[2:32:07]I believe I had something to do
[2:32:08]with the creation of
[2:32:09]I don't know if I actually did it
[2:32:11]or there was a corporate service company
[2:32:12]that did it but I believe
[2:32:14]I had something to do with creating
[2:32:15]the entity that owned that house.
[2:32:17]Is that the only LLC that was created?
[2:32:23]I think if that's an LLC
[2:32:27]I think HBRK was an LLC for RidgeCon.
[2:32:31]It seems the post-2009 scheme
[2:32:33]was to entrap women
[2:32:34]and create a complicated financial,
[2:32:38]legal, emotional web
[2:32:41]that they couldn't get out of
[2:32:42]and there's allegations
[2:32:44]that you created LLCs
[2:32:46]for some of those women which then
[2:32:50]have you ever operated someone's LLC
[2:32:51]without their knowledge?
[2:32:54]Well, can I address this idea of this scheme?
[2:32:58]I know nothing about a scheme.
[2:33:01]If I was asked to form an LLC
[2:33:02]I formed an LLC
[2:33:05]and if I was asked to form an LLC
[2:33:09]I would have been told
[2:33:10]like in the case of Jojo
[2:33:12]I'll say this is for the purchase of a house
[2:33:15]and I would have been told
[2:33:15]this is for the purchase of a house.
[2:33:18]Would it surprise you to know
[2:33:19]that Epstein was operating LLCs
[2:33:21]for people that he ostensibly employed
[2:33:24]without their knowledge?
[2:33:28]Yes, that would surprise me.
[2:33:30]And it would you agree
[2:33:31]that it would be illegal
[2:33:32]if we do things like file taxes
[2:33:33]and operate that LLC
[2:33:35]without the individual's knowledge
[2:33:37]and if that person that asked
[2:33:39]for information surrounding that
[2:33:40]withholding that would also be problematic.
[2:33:45]I wouldn't want to express
[2:33:46]in the coming on something like that
[2:33:47]unless I actually saw what you're talking.
[2:33:49]But during our previous hour
[2:33:55]we talked about whether Epstein
[2:33:58]may have been tipped off
[2:34:00]to assert a search warrant
[2:34:01]as his residence.
[2:34:02]You had said that you did not know.
[2:34:06]Is that a fair characterization
[2:34:08]of your testimony?
[2:34:09]That's a fair characterization
[2:34:10]of my testimony.
[2:34:11]Do you think he was tipped off?
[2:34:15]I really don't know.
[2:34:24]Did you understand Mr. Epstein
[2:34:26]to have close relationships
[2:34:28]with government officials
[2:34:30]in southern Florida?
[2:34:33]No.
[2:34:36]Did Jeffrey Epstein ever inform
[2:34:39]or represent to you
[2:34:40]that he was working
[2:34:41]with any intelligence service
[2:34:43]of any nation
[2:34:44]including the United States?
[2:34:46]No.
[2:34:47]Did Glane Maxwell ever inform
[2:34:48]or represent to you
[2:34:50]that she was working
[2:34:51]with any intelligence service
[2:34:52]of any nation
[2:34:53]including the United States?
[2:34:55]No.
[2:34:56]During your relationship
[2:34:58]did you ever suspect
[2:34:59]Epstein or Maxwell
[2:35:01]of being affiliated
[2:35:02]with any intelligence agency?
[2:35:05]I never suspected either of them.
[2:35:08]No.
[2:35:09]At any time have you had
[2:35:11]any affiliation
[2:35:12]with any intelligence agency?
[2:35:14]No.
[2:35:15]You've never...
[2:35:16]Did Ehud Barak live
[2:35:18]at 301 East 66th Street
[2:35:20]while you were there?
[2:35:27]I recall, though I'm not
[2:35:28]100% certain,
[2:35:29]but I recall that Ehud Barak
[2:35:32]may have stayed
[2:35:33]at an apartment
[2:35:35]in 301 East 66th Street.
[2:35:37]There were several apartments there
[2:35:39]that guests would come into town,
[2:35:42]people that he knew,
[2:35:43]that he would make available
[2:35:45]for people to stay at
[2:35:46]for a short period of time.
[2:35:48]It is possible,
[2:35:50]and I'm not 100% certain
[2:35:52]that Ehud Barak
[2:35:53]did, in fact, stay at the apartment
[2:35:55]at one time or another.
[2:35:58]Would it surprise you
[2:35:58]to know that the property
[2:35:59]records show that Ehud Barak's wife
[2:36:01]lives there from 2019 to today?
[2:36:04]It would surprise me, yes.
[2:36:06]Okay.
[2:36:09]And just because Ehud Barak
[2:36:11]was brought up,
[2:36:12]did you have any relationship
[2:36:14]with that individual?
[2:36:17]I believe that one...
[2:36:19]On one of those occasions
[2:36:20]when I was visiting Epstein...
[2:36:24]Sorry, not one,
[2:36:25]I think two, maybe three,
[2:36:26]but a limited number of occasions
[2:36:29]when I was doing work at Epstein
[2:36:32]when I was going over status
[2:36:34]or going over an assignment with him
[2:36:35]in his dining room
[2:36:36]on the ground floor of his townhouse,
[2:36:39]Barak had come to the townhouse
[2:36:41]or was just leaving,
[2:36:43]and I believe I said hello
[2:36:46]or I was introduced once,
[2:36:48]maybe twice.
[2:36:50]What was your understanding
[2:36:51]of Mr. Barak's relationship
[2:36:52]with Mr. Epstein?
[2:36:55]I didn't really have an understanding
[2:36:56]of their relationship.
[2:36:58]I knew that there was a relationship,
[2:36:59]but I didn't really have an understanding
[2:37:01]about what it was.
[2:37:02]Did you ever have any understanding
[2:37:04]that Mr. Ehud Barak
[2:37:07]had ties to intelligence?
[2:37:13]From what, you know,
[2:37:14]as a general matter,
[2:37:15]what one reads in the news,
[2:37:17]I thought as a former Prime Minister
[2:37:20]of Israel probably,
[2:37:22]I didn't know more than that.
[2:37:25]And outside of Mr. Ehud Barak,
[2:37:28]is there anyone that you know
[2:37:31]affiliated with Mr. Epstein
[2:37:33]or Maxwell that you suspected
[2:37:34]to have ties to intelligence?
[2:37:39]No, the answer is no.
[2:37:41]And again, for the record,
[2:37:42]you have never had any relationship
[2:37:45]with any intelligence service?
[2:37:46]I have not, no.
[2:37:47]You have never visited CIA headquarters
[2:37:50]in Langley, Virginia?
[2:37:51]No.
[2:37:57]During the previous hour,
[2:37:58]the minority asked you questions
[2:38:02]related to your role
[2:38:04]as Mr. Epstein's attorney.
[2:38:05]I believe that they discussed at length
[2:38:07]the compensation structure.
[2:38:10]I just want to focus on your hiring.
[2:38:13]And again, recognizing,
[2:38:15]I'll probably make you repeat yourself.
[2:38:18]Is our understanding that
[2:38:20]you were working with this partner
[2:38:22]on Mr. Epstein's accounts
[2:38:24]and subsequent to that,
[2:38:25]you and that partner
[2:38:26]went to J. Epstein and Company?
[2:38:29]Is that a fair characterization?
[2:38:30]No, it didn't happen that way.
[2:38:33]I worked first as a paralegal,
[2:38:35]then as a clerk,
[2:38:37]and then as an associate
[2:38:40]at a law firm by the name of Golden Wachtel,
[2:38:42]at which that partner was a partner
[2:38:45]by the time he left.
[2:38:47]He left Golden Wachtel
[2:38:49]before I left Golden Wachtel.
[2:38:52]After he left Golden Wachtel,
[2:38:53]I then went to Greenberg Trarig
[2:38:56]for about a year or so.
[2:38:59]And when I was at Greenberg Trarig
[2:39:01]for about a year,
[2:39:02]I received a call from that partner
[2:39:06]to consider come working for him within
[2:39:12]or representing Mr. Epstein.
[2:39:15]And initially,
[2:39:18]what was your compensation for Mr. Epstein
[2:39:20]with Mr. Epstein?
[2:39:22]It's a long time ago,
[2:39:24]but I believe it was around $450,000.
[2:39:30]What were you making at the law firm
[2:39:33]prior to moving to working with Mr. Epstein?
[2:39:36]A little bit less than that,
[2:39:37]but probably in the 300s.
[2:39:42]It's a guess.
[2:39:43]I don't recall a hundred cents,
[2:39:44]but it was less.
[2:39:59]How were you compensated by Mr. Epstein?
[2:40:04]Well, it depended.
[2:40:05]If I was working as an employee,
[2:40:09]like I was for J. Epstein and Company,
[2:40:11]then I was compensated directly
[2:40:13]by the company J. Epstein and Company.
[2:40:15]When I was working for the company
[2:40:17]New York Strategy Group,
[2:40:18]New York Strategy Group would get paid by Epstein,
[2:40:20]and then New York Strategy Group would pay me
[2:40:24]or whatever it paid me at the time.
[2:40:26]And when I was working with my home law firm,
[2:40:31]I received the funds directly from Epstein.
[2:40:37]Or Epstein or it could have been
[2:40:40]one of his entities like
[2:40:41]the Southern Trust Company.
[2:40:46]And you mentioned previously
[2:40:48]that you started around $450,000 a year.
[2:40:52]What was your compensation by the time
[2:40:53]that you finished representing
[2:40:57]Mr. Epstein during his life?
[2:40:59]My last compensation that I received for him
[2:41:02]before he died was,
[2:41:04]or maybe it was just after he died,
[2:41:05]he was pursuing an employment agreement
[2:41:06]that he signed, was
[2:41:11]the payment was $200 million.
[2:41:13]I'm sorry, $2 million, not too much.
[2:41:16]$2 million, sorry.
[2:41:18]Did you find your compensation
[2:41:21]to be commensurate with your experience?
[2:41:24]I did.
[2:41:26]I remember, so I went to Cornell Law School.
[2:41:30]I had a background in corporate and securities law.
[2:41:32]I worked for an AmLaw 100 law firm.
[2:41:34]I was on call 24-7 for seven days a week.
[2:41:38]And I was expected to get things done
[2:41:41]very quickly and very carefully.
[2:41:44]Transactions were very complicated.
[2:41:45]They involved high dollar amounts.
[2:41:47]So given all of that, yes,
[2:41:51]I believe I was compensated commensurate
[2:41:52]with my experience and with
[2:41:53]the skill level that I exercised.
[2:41:56]Did you receive equity interest
[2:41:58]as part of your compensation?
[2:42:00]No.
[2:42:04]Did you ever receive gifts
[2:42:05]outside of your base pay?
[2:42:06]No.
[2:42:09]I received loans, as we've discussed,
[2:42:11]and he helped me purchase
[2:42:16]my house in New Jersey,
[2:42:18]which ultimately got paid back.
[2:42:20]And then when I went to purchase
[2:42:22]the house in Florida,
[2:42:24]he agreed to purchase my house
[2:42:27]in New Jersey on a deferred basis,
[2:42:30]gave me the money in advance,
[2:42:34]which was used then to purchase
[2:42:36]the house in Florida.
[2:42:39]And that ultimately, because he died,
[2:42:41]that never came to pass.
[2:42:43]And according to the estate plan,
[2:42:46]that contract was basically null.
[2:42:51]Obviously, if there's no money
[2:42:52]in the estate, there will be
[2:42:53]an accounting that has to happen.
[2:42:58]Plus the IVF treatment.
[2:42:59]What's that?
[2:43:00]Plus the IVF treatment.
[2:43:01]Oh, plus the IVF treatment.
[2:43:02]Sorry. Yes.
[2:43:04]That wasn't good. Yes.
[2:43:10]And during the minority's hour,
[2:43:12]I recognize that they talked to you
[2:43:14]at length about the loan.
[2:43:17]Was the $7 million provided
[2:43:19]at one time or was it...
[2:43:20]Overtime.
[2:43:21]Okay.
[2:43:22]And between 2013 to 2017
[2:43:25]is what I believe you testified to.
[2:43:26]17 or 18.
[2:43:29]And did you approach Mr. Epsing
[2:43:32]and ask him for these loans?
[2:43:34]I did. Yes.
[2:43:35]What did that look like?
[2:43:37]I told him that I'd like some more money
[2:43:40]and I'd like to do it.
[2:43:42]I was thinking about doing investments
[2:43:44]and he would tell me,
[2:43:46]okay, I'll loan you this amount.
[2:43:49]And it was very definitely a loan.
[2:43:53]And Chairman Comer had discussed
[2:43:58]Mr. Epsing's investments.
[2:44:00]Did he have an opinion
[2:44:01]on the specific investment
[2:44:02]that you were looking to make?
[2:44:04]No. He never discussed investments.
[2:44:11]Did you receive any other
[2:44:13]remuneration we did not cover?
[2:44:18]I don't think I did.
[2:44:31]In performing your roles
[2:44:32]and responsibilities for Mr. Epsing,
[2:44:35]I'm going to ask you
[2:44:36]if you communicate with
[2:44:37]the following individuals.
[2:44:38]Okay.
[2:44:40]First, Mr. Richard Kahn?
[2:44:43]Yes.
[2:44:45]Mr. Harry Beller?
[2:44:47]Yes.
[2:44:49]Ms. Leslie Groff?
[2:44:51]Yes.
[2:44:52]Ms. Sarah Kellan?
[2:44:55]Yes.
[2:44:57]Ms. Nadia Mersinkova?
[2:45:00]Yes.
[2:45:02]Ms. Karina Schuliak?
[2:45:04]Yes.
[2:45:06]Ms. Bella Klein?
[2:45:08]Yes.
[2:45:10]Mr. Emad Hana?
[2:45:14]Yes.
[2:45:20]In regards to all of these individuals,
[2:45:26]how would you typically
[2:45:26]communicate with them?
[2:45:30]Sometimes personally.
[2:45:33]For example, Emad,
[2:45:36]at one point Emad and
[2:45:38]Richard Kahn and Bella
[2:45:40]and I were in the same office
[2:45:41]in New York City.
[2:45:45]Harry too, Harry Beller.
[2:45:50]And I believe
[2:45:50]Leslie was also there.
[2:45:53]And is that the 301 address?
[2:45:56]No. Originally there was
[2:45:58]an address on Madison Avenue.
[2:46:05]And then there was an address
[2:46:11]when Epsing was in jail.
[2:46:20]Each of us moved to
[2:46:21]different offices in 301 E 66
[2:46:25]Street for a period of time.
[2:46:28]And then after he came out of jail,
[2:46:30]each of us moved to offices
[2:46:32]in an executive office space
[2:46:35]on Lexington Avenue.
[2:46:37]What was Mr. Kahn's role?
[2:46:40]He was an accountant.
[2:46:44]I don't know if he actually
[2:46:45]had an official title.
[2:46:46]But I have heard him
[2:46:50]referred to as a CFO.
[2:46:52]But I don't know if he
[2:46:52]actually had an official title.
[2:46:58]How closely did you work
[2:46:59]with Mr. Kahn?
[2:47:02]We had offices near each other.
[2:47:04]We talked about there was
[2:47:07]a specific job that required
[2:47:10]me telling him something
[2:47:11]or him telling me something.
[2:47:13]We communicated that way.
[2:47:15]But, you know, we weren't close.
[2:47:18]I think there's at least
[2:47:22]a few occasions where we socialized.
[2:47:25]I think he went to my kids
[2:47:26]about Mitzvah.
[2:47:28]And I think when
[2:47:31]one of the office people was leaving,
[2:47:34]we had a dinner we went to together.
[2:47:38]That was the relationship.
[2:47:41]What role did Harry Beller play?
[2:47:44]Harry Beller was,
[2:47:46]as I understand it, a bookkeeper.
[2:47:52]And he was in the accounting department.
[2:47:54]Again, my role was more legal,
[2:47:56]accounting.
[2:47:58]So the specifics of what was done
[2:48:00]in the accounting department
[2:48:00]was not something that I knew as much about.
[2:48:04]But you mentioned Mr. Kahn.
[2:48:06]You'd worked in close proximity to him.
[2:48:10]Was that true for Mr. Beller as well?
[2:48:12]Mr. Beller worked in the same office.
[2:48:15]Again, not in the same office office,
[2:48:18]but in the same floor.
[2:48:20]We had offices on the same floor.
[2:48:22]So we saw each other from time to time.
[2:48:24]I didn't sit with him.
[2:48:26]And if he had a question about something,
[2:48:28]I would answer his question.
[2:48:30]If I had a question about something
[2:48:31]and I can't tell you specifically
[2:48:32]what the question would be about,
[2:48:34]I would ask him the question.
[2:48:37]Outside of work,
[2:48:38]did you socialize with Mr. Beller?
[2:48:43]I'm trying to remember if Mr. Beller
[2:48:44]was invited to my
[2:48:46]and attended my daughter's botanist or
[2:48:48]he may have.
[2:48:49]But other than that, no.
[2:48:52]What was Bella Klein's role?
[2:48:54]She was also in the accounting office.
[2:48:56]Also a bookkeeper,
[2:48:58]but the specifics of what her job was,
[2:49:00]I don't know.
[2:49:02]Did you socialize with Ms. Klein?
[2:49:05]Also, I went to one wedding with her
[2:49:10]and I believe she was invited
[2:49:11]to the botanist, my kid's botanist.
[2:49:14]What about Emad Hanna?
[2:49:17]Emad Hanna.
[2:49:19]He was a purchasing person.
[2:49:22]I purchased a lot of equipment and tools,
[2:49:26]heavy machinery,
[2:49:28]particularly for the,
[2:49:30]if I recall, for the
[2:49:32]Island Little St. James
[2:49:33]when there was a lot of construction
[2:49:34]projects going on.
[2:49:37]Did you socialize with him?
[2:49:41]He may have gone to the botanist,
[2:49:43]so I don't remember.
[2:49:45]I think he did.
[2:49:48]While working with these individuals,
[2:49:50]did you ever discuss
[2:49:52]anything related to Mr. Epstein's
[2:49:54]personal life?
[2:49:55]No.
[2:50:02]During litigation with J.P. Morgan,
[2:50:05]there's been documents
[2:50:07]that have shown J.P. Morgan staff
[2:50:12]making comments
[2:50:14]that tend to show
[2:50:16]they may have had some awareness
[2:50:18]into Mr. Epstein's personal life.
[2:50:20]One in particular was referencing
[2:50:24]him hanging out with Miley Cyrus.
[2:50:26]Is it your testimony today
[2:50:27]that you do not recall
[2:50:28]ever having any conversations
[2:50:31]with the people you worked with
[2:50:33]that related to Mr. Epstein's affinity
[2:50:35]with young women or girls?
[2:50:40]My recollection is I never had
[2:50:41]a conversation with anybody
[2:50:47]in the accounting office about
[2:50:50]Epstein's affinity for younger girls.
[2:50:53]I don't know that he had
[2:50:54]an affinity for younger girls.
[2:50:56]I don't recall ever having
[2:50:58]any kind of conversation like that.
[2:51:00]Do you remember how to name
[2:51:01]Arta Viscardis?
[2:51:04]Arta Viscardis was an immigration lawyer.
[2:51:07]What degree and frequency
[2:51:08]did you interact with him?
[2:51:10]I interacted with him
[2:51:12]a number of times.
[2:51:14]How many separate instances
[2:51:17]are we talking?
[2:51:18]A dozen?
[2:51:19]Maybe a dozen.
[2:51:20]Maybe a little bit more.
[2:51:21]Was that surrounding
[2:51:25]immigration cases for his assistants
[2:51:27]or other group, other individuals?
[2:51:32]Assistants?
[2:51:33]It may have been for
[2:51:36]some of the island managers
[2:51:38]who were from South Africa.
[2:51:40]It may have been for them.
[2:51:43]So that would have been
[2:51:46]a couple from South Africa.
[2:51:50]What percent of the immigration cases
[2:51:51]that you worked on
[2:51:52]were young attractive women?
[2:51:56]I don't think it's appropriate
[2:51:58]to comment on attractive women.
[2:51:59]Women between the ages of 15 and 30?
[2:52:05]I would say
[2:52:08]That's a wide range.
[2:52:13]I don't recall there being
[2:52:14]any underage women ever
[2:52:17]that I did work for.
[2:52:19]How many women between the ages of 18 and 30
[2:52:21]did you work with Arta Viscardis
[2:52:22]to facilitate immigration and paperwork?
[2:52:26]Range?
[2:52:27]I think the
[2:52:28]Less than 10, more than 10?
[2:52:29]First, I think the verb
[2:52:32]facilitate immigration paperwork.
[2:52:34]To the extent that I did anything,
[2:52:36]it was to look over a document
[2:52:39]or to add a request from a person
[2:52:42]to provide a document.
[2:52:45]But I wasn't facilitating immigration.
[2:52:49]That's not an appropriate word.
[2:52:51]I'm sorry.
[2:52:51]If Arta Viscardis asks you for documents
[2:52:54]to beef up an immigration application,
[2:52:58]I would use the word facilitate, but okay.
[2:53:02]Just to be clear,
[2:53:02]that wasn't a question, right?
[2:53:04]So he's not going to answer,
[2:53:04]but I think he would have
[2:53:06]take an issue with that statement.
[2:53:09]Keep your voice up.
[2:53:12]Yes, sorry.
[2:53:14]Continuing on the list
[2:53:15]I previously brought up,
[2:53:17]Leslie Groff, what was her role?
[2:53:19]She was Mr. Epstein's assistant
[2:53:22]for a while when he was in jail.
[2:53:24]She also helped me with some of my legal work.
[2:53:27]Can you elaborate on that legal work?
[2:53:32]Nothing sticks out in my head today,
[2:53:35]but to the extent I needed documents copied
[2:53:38]or I wanted to send an email to somebody,
[2:53:47]I would tell her to please send an email to somebody.
[2:53:49]So you're just referring to administrative work.
[2:53:51]Correct.
[2:53:53]Did you socialize with Ms. Groff outside of work?
[2:53:56]Ms. Groff also was invited to my kids' spot MISVA
[2:54:01]and I believe that Ms. Groff went to that dinner,
[2:54:05]that one dinner when one of the workers
[2:54:09]in my office was leaving.
[2:54:12]But beyond that now,
[2:54:14]so that's the extent of my socialization.
[2:54:18]Who is Sarah Kellan?
[2:54:20]Sarah Kellan, to my knowledge,
[2:54:24]was one of Jeffrey Epstein's assistants.
[2:54:29]And what were your interactions with Ms. Kellan?
[2:54:35]From time to time, Sarah Kellan would relate a request.
[2:54:39]Nothing comes to my mind about what request that Jeffrey had
[2:54:43]relating to some legal issue.
[2:54:49]Sarah Kellan also, as I understand it,
[2:54:52]was doing interior design work for Epstein.
[2:54:55]Epstein had a lot of properties, as we know,
[2:54:58]and was constantly redecorating and changing them.
[2:55:06]And Sarah was doing a lot of the procuring
[2:55:11]and for the decorating that he was doing on those properties.
[2:55:15]And I believe the entity that she did it through
[2:55:18]was an entity, sort of business with Sarah,
[2:55:22]SLK Designs, I think it's something like that it was called.
[2:55:26]Did you create that entity?
[2:55:28]I don't recall, but it is possible.
[2:55:30]Did you socialize with Ms. Kellan outside of work?
[2:55:34]No.
[2:55:36]Who is Corina Shuliyak?
[2:55:39]I have come to know Corina, ultimately,
[2:55:43]as somebody who was a girlfriend of Mr. Epstein.
[2:55:48]But I did not have that realization until,
[2:55:52]I want to say 2015, 2016, around there.
[2:55:59]And we discussed her in the context of one of the alleged sham marriages.
[2:56:06]I was not aware that it was a sham marriage.
[2:56:08]I'm still not sure that it's a sham marriage,
[2:56:13]but she was one of the people that was married, yes.
[2:56:17]But you came to learn that Mr. Epstein
[2:56:20]had a romantic relationship with Corina after this marriage.
[2:56:27]So the word romantic is, for me, it's kind of loaded.
[2:56:31]I understood her to be his girlfriend, whatever that meant,
[2:56:34]and I didn't know what that meant.
[2:56:36]I don't know what his actual intimate relationship with her was.
[2:56:43]Did you socialize with Ms. Shuliyak outside of your official role?
[2:56:46]No.
[2:56:47]We talked about Ms. Groff, Ms. Kellan, and Ms. Shuliyak.
[2:56:55]You understood all of them to be assistants of Mr. Epstein.
[2:56:58]Ms. Groff, Ms. Kellan, and Ms. Shuliyak.
[2:57:01]You're right.
[2:57:05]Yes, and Sarah, as I explained,
[2:57:08]Sarah also did decorating and design work for me.
[2:57:12]Was Nadia Marsinkova an assistant?
[2:57:16]To the extent that I, the same extent that I don't know what that meant,
[2:57:23]I understood at some point I became aware that Nadia was a girlfriend.
[2:57:27]I understood at some point I became aware that Nadia was a girlfriend of his, of Epstein's,
[2:57:33]but she was also an assistant.
[2:57:36]When did you meet Nadia Marsinkova?
[2:57:40]You had something to show me, I can tell you, but I don't recall when I met her.
[2:57:51]You may not recall when you met her,
[2:57:53]but do you know how old she may have been when you met her?
[2:57:56]She was well above age, well above the age of 18.
[2:58:00]I guess I should take this point.
[2:58:03]I have heard stories referred to her as a child sex slave or something like that,
[2:58:09]and I will tell you that I do not believe that to be true.
[2:58:15]I don't think that was true, and as part of the defense council's kind of
[2:58:21]disclosures to federal and state governments in connection with the Epstein investigation,
[2:58:28]they made it clear that that wasn't true.
[2:58:32]In his 2019 indictment, you're familiar with the allegations?
[2:58:39]If you have a specific allegation?
[2:58:41]In 2005, he was accused of engaging in sex trafficking, human trafficking.
[2:58:46]If you were on the jury and that had gone to trial,
[2:58:49]would you vote to convict him, given all of your information you have?
[2:58:55]I'm sorry, can you repeat the question?
[2:58:56]If you were on the jury and it had gone to trial,
[2:58:58]I'm sorry, for which?
[2:58:59]For 2002, 2005, the indictment that you probably have read, if that went to trial
[2:59:05]and you were on the jury, would you have been in favor of convicting him for the charges with
[2:59:10]which he was alleged to have committed?
[2:59:14]Based upon what I knew then, the answer would have been no.
[2:59:18]What about now?
[2:59:19]I don't know.
[2:59:23]$750 million had been paid in settlements, close, and you don't know whether
[2:59:30]$750 million had been paid in settlements, close, and you don't know whether
[2:59:32]it was bank of America.
[2:59:42]I want to return back to, I characterize those women as assistants.
[2:59:51]I'm about to ask more questions related to Mr. Epstein's various assistants.
[2:59:56]Do you disagree with the committee's characterization of some of these women?
[3:00:02]Assistants?
[3:00:06]To the extent that I knew what their role was, they appeared to me to be assistants.
[3:00:11]They appeared to be taking messages for him, making travel plans for him,
[3:00:16]running errands for him, so they appeared to me to be assistants.
[3:00:21]In the time that you worked for Mr. Epstein, roughly how many assistants did he have?
[3:00:30]I don't know.
[3:00:42]10, 15, it's a guess.
[3:00:44]I don't know.
[3:00:45]We could go through them if you want.
[3:00:47]As his corporate attorney, did you advise him on employment matters related to their hiring?
[3:00:58]Typically no.
[3:01:02]Were all of his assistants female?
[3:01:09]Office assistants, I would say yes, but he did employ
[3:01:13]people through a system of architectural stuff.
[3:01:18]I can think of at least one person that was a man.
[3:01:22]His chefs were largely men.
[3:01:29]Household staff, there were men as well as women, so I think the answer is no.
[3:01:37]Personal assistants, in the sense of taking messages and getting coffee
[3:01:46]and things like that, I would say yes, except that there was overlap with household functions,
[3:01:53]like bringing meals and things like that.
[3:01:57]What percent of the women lived at 301 East 66th Street?
[3:02:01]I don't know.
[3:02:03]I don't know.
[3:02:08]Your office was there for a while and you don't know what percent of his assistants
[3:02:13]lived at 301 East 66th Street?
[3:02:15]So my office was in one apartment in a 150-unit building.
[3:02:19]I was not in the accounting office.
[3:02:22]To the extent that Epstein provided apartments to those people, that's not something I did.
[3:02:28]So the answer is no.
[3:02:31]The answer is you don't know.
[3:02:33]Yeah, right.
[3:02:34]The answer is I don't.
[3:02:34]Well, I was answering the other question.
[3:02:36]The answer is I don't know.
[3:02:37]Correct.
[3:02:40]Did you find it suspicious that his personal assistants were women?
[3:02:47]No.
[3:02:49]In my experience, in my exposure to other men in the business world,
[3:03:00]oftentimes the assistants were women.
[3:03:02]Even in the lawyers, the assistants were women.
[3:03:05]You didn't find it suspicious that the guy that just went to prison for
[3:03:09]prostitution of a liar had seven different female assistants
[3:03:14]and had very strange situations around all of them?
[3:03:18]That's not suspicious?
[3:03:19]There's a lot to unpack there.
[3:03:22]The guy that just went to prison for…
[3:03:25]If I can answer the question, I'd like to answer the question.
[3:03:28]The guy that just went to prison was registered as a sex offender.
[3:03:32]He was under intense scrutiny.
[3:03:35]So no, I didn't think that if he had women,
[3:03:37]also he was under intense scrutiny and it was publicly about him.
[3:03:40]So no, I never made the assumption that women were working for him,
[3:03:43]were engaged in a sexual relationship with him,
[3:03:46]and I never believed that he would be engaging in conduct,
[3:03:51]which with all the scrutiny on him,
[3:03:52]could put him back in the place where he said he was never going to go to.
[3:04:00]How were these assistants compensated?
[3:04:08]I assume they were paid by check or
[3:04:13]you know, either as independent contractors or as
[3:04:17]salaried employees or various entities.
[3:04:20]To be clear, did you ever provide cash payments to Epstein's assistants?
[3:04:26]Not that I recall, no.
[3:04:27]Did you ever witness Mr. Epstein giving cash to his assistants?
[3:04:36]For their personal payment?
[3:04:40]The answer is no, not that I recall.
[3:04:43]Is it possible that I was in a room where he handed cash to them in order to
[3:04:47]pay tip somebody who showed up
[3:04:50]or to pay for a particular thing that he asked them to get?
[3:04:54]That's possible.
[3:04:54]I don't have a specific recollection, but it's certainly possible.
[3:04:58]Did you ever witness Mr. Epstein pay women for massages?
[3:05:02]No.
[3:05:02]During the previous hour, I believe you testified that you visited Zorro Ranch, is that correct?
[3:05:24]That's correct.
[3:05:25]And how many times did you visit Zorro Ranch?
[3:05:30]Two or three times.
[3:05:31]What were the nature of your visits to the ranch?
[3:05:36]Usually, if I'm visiting a property, and I believe in this instance,
[3:05:41]it had to do with some kind of either construction project
[3:05:44]taking place on the property.
[3:05:50]Oh, and there was one other time, now that I'm thinking about it,
[3:05:54]when my family and I took a vacation out in New Mexico,
[3:05:59]Epstein wasn't there at the time,
[3:06:01]but my family and I visited the ranch just to see it.
[3:06:11]Did you visit the Palm Beach residence?
[3:06:15]I did.
[3:06:16]How many times did you visit that residence?
[3:06:19]Well, after he was in jail, when I went to see him in jail,
[3:06:24]I actually stayed at the Palm Beach residence in one of the rooms, one of the bedrooms.
[3:06:28]And how long did you reside at that residence?
[3:06:31]I didn't reside at the residence, I stayed in the residence.
[3:06:35]When I would go visit him, I would go there for a day,
[3:06:38]stay overnight, and come back to New York, New Jersey.
[3:06:46]Did you visit his residence in Paris?
[3:06:51]I visited the residence in Paris once when I was on a family trip, when he wasn't there.
[3:07:04]Once when he was there for, I don't remember,
[3:07:09]it was a business-related trip and I don't remember the nature of the business,
[3:07:12]it was quite some time ago.
[3:07:14]Was Mr. Epstein present?
[3:07:15]He was there, yes.
[3:07:16]Who else was present?
[3:07:18]Valveson is ballet and one personal assistant, I don't remember,
[3:07:30]but it was somebody who was his personal assistant at the time.
[3:07:33]Recognizing that you just testified, you don't recall
[3:07:37]why you visited Paris with Mr. Epstein.
[3:07:41]Is it possible that it may have been related to meeting with Jean-Luc Brunel?
[3:07:46]No.
[3:07:47]And for the record, do you know Jean-Luc Brunel?
[3:07:52]I did interact with Jean-Luc Brunel on probably a handful of occasions, yes.
[3:07:59]What were the nature of your interactions with Mr. Brunel?
[3:08:03]Brunel had traveled to the office one or two times.
[3:08:11]I understand that he and Epstein were social acquaintances,
[3:08:13]so when I was visiting Epstein, for whatever reasons I was visiting Epstein, I would see him.
[3:08:21]As it relates to MC squared had some kind of a payroll tax issue, if I recall.
[3:08:31]And in connection with that payroll tax issue,
[3:08:34]there was some kind of a letter of credit that was required for it.
[3:08:38]I interacted, I think, with him and with his
[3:08:42]his staff. I think it was an accountant or a controller with respect to that
[3:08:50]issue and Epstein providing science security for the letter of credit.
[3:08:56]Did you socialize with Mr. Brunel outside of?
[3:08:59]I did not socialize with Mr. Brunel outside.
[3:09:03]Period. Not outside of. I didn't socialize with him.
[3:09:05]You mentioned the entity, and I do not have my notes in front of me,
[3:09:10]but what was that entity?
[3:09:14]MC squared.
[3:09:15]MC squared was a modeling agency, and to my knowledge was a legitimate modeling agency
[3:09:22]with workers and employees. That was an agency that I believe he was a principal of.
[3:09:31]Did you have any role in organizing that modeling agency?
[3:09:35]I recall that I did the, I don't know if it was the corporation or the LLC,
[3:09:44]the incorporation work, or had something to do with the incorporation work.
[3:09:48]What was Mr. Epstein's role in with the agency?
[3:09:55]I don't know that he had a role. I don't know that he was a,
[3:09:59]I'm pretty sure he wasn't a principal of MC squared.
[3:10:03]During the time that you knew Mr. Epstein, did he ever represent himself to be a talent scout
[3:10:10]for models? Not in my presence, no.
[3:10:13]Did you ever subsequently learn that he represented himself to be a Victoria's Secret
[3:10:18]model scout? Through allegations in legal papers.
[3:10:22]What did you think of those allegations? I didn't know what to think.
[3:10:42]As far as the resident or the properties that Mr. Epstein owned that you said he visited,
[3:10:49]and you can correct me if I'm wrong, Palm Beach, Manhattan, New Mexico, and Paris,
[3:10:55]did you have keys or security access to any of these properties?
[3:10:59]No. At any time,
[3:11:02]did you have office space inside any of these properties?
[3:11:06]No. Did you observe any
[3:11:09]massage tables? After he died, when we did a tour of
[3:11:19]the New York, I think it was the co-executive and I, Rachy Collin, we did a tour of that
[3:11:27]property and I believe I saw a massage table there.
[3:11:31]So then just for the record, can you be clear that before he died?
[3:11:34]Before he died, I did not see any massage tables.
[3:11:38]You never, during your representation, were you ever a part of any purchases of massage
[3:11:50]tables or equipment? No.
[3:11:57]It's been reported and we've seen from the Epstein Files Transparency Act that Mr. Epstein
[3:12:06]had weird taste in artwork and many of his properties had betrayed nudity.
[3:12:15]Did you notice any unusual artwork when you visited the properties?
[3:12:20]I saw, you know, there's the blue dress that everybody refers to in the press.
[3:12:25]I've seen that in the New York property in the control room where the security person was
[3:12:32]located. I've seen that in that room. I remember seeing eyeballs, glass eyeballs.
[3:12:42]I forget which house that was in, but it was glass eyeballs.
[3:12:45]It was hung in a frame and hung up, but that was kind of an odd thing.
[3:12:50]I remember in the New York, the New York townhouse, when you walked in on your way
[3:12:58]to go to the dining room, there was a rope with, I think, like an acrobatic
[3:13:04]woman dangling from the rope. So that struck me as kind of an odd piece of art.
[3:13:15]He also had an American flag on the dining room table at some point.
[3:13:20]I think that was odd. I don't know.
[3:13:23]Did you ever discuss any of those choices with Mr. Epstein?
[3:13:30]No. My relationship with Mr. Epstein was not such where I would have a conversation, but artistic places.
[3:13:37]Have you heard the phrase, if you can speak it, don't write it, and if you can read it, don't speak it?
[3:13:49]No.
[3:13:50]Okay. It's a DC phrase people always talk about, knock it. But you get the general gist.
[3:13:56]I think so.
[3:14:01]Epstein has a very documented history of putting things in writing that people would generally
[3:14:09]not want put in writing. It seems intentional. It seems systematic even. Have you followed that
[3:14:15]at all? Do you realize that the Epstein Transparency Act shows us all these emails
[3:14:19]and the way that he documents things really intentionally to create, it seems like he's
[3:14:24]spreading leverage. Do you have any insight into that practice?
[3:14:29]I don't have any insight into that practice. I've never seen his emails.
[3:14:34]Why do you think he would document so many things that the people that he was
[3:14:39]communicating would clearly probably not want that stuff in writing?
[3:14:43]I wouldn't speculate. I don't know.
[3:14:49]To be clear on the artwork, did you ever see nude photos displayed at Mr. Epstein's
[3:14:55]properties?
[3:14:59]In inventorying the estate, I've seen there's naked paintings, naked women in paintings.
[3:15:09]I believe there was a book of nudes, a photographic book, one of those big coffee
[3:15:16]table books. I saw something like that. I'm trying to remember if it's only because I
[3:15:29]hurtel of it after the fact, after he died. I don't think I saw anything else.
[3:15:36]Did you ever travel on Mr. Epstein's plane?
[3:15:40]I've traveled on planes that were owned by Mr. Epstein beneficially, yes.
[3:15:45]How many times?
[3:15:48]Over the course of 23 years, maybe one a year, maybe less than that, maybe a
[3:15:56]dozen. I'm not sure, but it was not frequent.
[3:16:01]Was Mr. Epstein always present?
[3:16:06]Every trip that I went, I think he was present with the exception of one.
[3:16:11]When I had gone to, I'm not sure if it was D.C. or Boston, I'm sorry.
[3:16:22]I had gone either to Boston or D.C. with Mr. Epstein on a day when I had told him that I was
[3:16:33]celebrating my anniversary with my wife and he asked me to go nevertheless.
[3:16:40]When we came back to Teterboro for that trip, he said I should take my life
[3:16:44]to Atlantic City and take the plane. That was the one time that I did not travel with him.
[3:16:50]What was the nature? Was it business related? You were always traveling on his plane?
[3:16:55]Every trip that I took with Mr. Epstein was business related on his plane.
[3:17:02]It's been alleged that Mr. Epstein would conduct sex parties on his plane.
[3:17:07]You never witnessed or heard anything related to sex parties on his plane?
[3:17:12]I never witnessed any kind of sexual conduct on his plane.
[3:17:16]We're coming to the end of our hour, so I'm going to ask you some questions to close.
[3:17:27]Have you ever declined to provide legal services for legal or ethical reasons?
[3:17:37]No, I don't think that occasion came up.
[3:17:44]Have you ever declined to participate in a transaction for legal or ethical reasons?
[3:17:49]While I was employed with Epstein, he declined to participate in transactions that he thought
[3:18:00]were inappropriate for either legal reasons or that he thought could potentially be scams or
[3:18:05]frauds. In that respect, yes. Personally, I never had occasion to make that call.
[3:18:14]Have you ever advised a client to not tell you something?
[3:18:18]No.
[3:18:20]Have you ever advised clients about human trafficking statutes?
[3:18:30]In connection with the legal defense team,
[3:18:43]the team and I certainly reviewed the sex trafficking statutes.
[3:18:55]Mr. Indyk or your lawyers, you discussed this committee's subpoena of documents of
[3:19:01]the Epstein estate last hour with the ranking member. I believe it was stated that the subpoena
[3:19:06]is closed out except for items 15 and 16 in the subpoena schedule. Is that correct?
[3:19:13]15 has subparts A and B, so one of them is closed out and one of them is not.
[3:19:18]I will enter the subpoena and schedule as Majority Exhibit 4.
[3:19:35]The subpoena is addressed to the estate of Jeffrey Epstein,
[3:19:39]heir of Darren Indyk and Richard Kahn and it was sent on August 25th of 2025.
[3:19:55]Item 15, and I will read it into the record, it requests all documents and communications to
[3:20:01]or from and or referring or relating to the following individuals. A is numbers 1 through 92
[3:20:10]defined by Joufray v. Maxwell, Plaintiff Virginia Joufray's 4th Revised Disclosure
[3:20:17]pursuant to the Federal Rules of Civil Procedure in the Southern District of New York on January
[3:20:22]5th of 2024, and B, all Presidents and Vice Presidents of the United States not otherwise
[3:20:29]listed in Request 10A from January 1st, 1990 through August 10th, 2019.
[3:20:40]Number 16 says all documents and communications referring or relating to the following entities.
[3:20:47]A COUQ Foundation, B NES LLC, C New York Strategy Group, D JEGE LLC, E JEGE Inc, and F LSJ LLC.
[3:21:10]My understanding is that the Committee Council discussed with the estate lawyers the need to
[3:21:15]further clarify items 15A and 16. I want to be very clear, the Committee does not consider
[3:21:22]15A or 16 to be closed out, as additional clarification was sought by the estate.
[3:21:30]The Committee intends to provide that clarification, but is first continuing
[3:21:34]its investigation and review of materials produced by banks and DOJ which relate to
[3:21:39]these requests and assist the Committee's clarification. And again, to be clear,
[3:21:44]the estate communicated to us that item 15B is completely closed out and the estate possesses
[3:21:51]no additional documents responsive to that request. We can go off the record.
[3:22:11]We can go back on the record. Good afternoon, Mr. Indick.
[3:22:16]Good afternoon.
[3:22:17]Are you familiar with the Florida Science Foundation?
[3:22:22]Yes, I know the Florida Science Foundation.
[3:22:25]Were you involved in setting it up?
[3:22:28]The Florida Science Foundation is a trade name, for lack of a better term,
[3:22:36]of the COUQ Foundation, which was an existing foundation that predated
[3:22:42]Mr. Epstein's conviction in 2008.
[3:22:50]Super.
[3:22:52]Was there a separate incorporation of the entity that subsequently was known as the
[3:22:58]Florida Science Foundation, as you just explained it?
[3:23:02]I believe that initially, and I'm not sure why it was done, but one of the Florida attorneys
[3:23:11]formed a separately Florida Science Foundation, but I believe that one was never used.
[3:23:22]I believe the foundation that was in existence was the one that they used.
[3:23:28]You don't have an understanding as to why the Florida Science Foundation was incorporated?
[3:23:35]As I'm sitting here today, I think somebody just did it quickly because they knew there
[3:23:39]was something going to be called the Florida Science Foundation.
[3:23:43]I don't think that they got direction from anybody, and they just did it.
[3:23:48]I can represent to you that I've seen articles of incorporation for the Florida Science
[3:23:54]Foundation that were filed on November 1st of 2007. Does that sound right to you?
[3:24:00]Sounds about right, yes.
[3:24:02]And that, to my chronological understanding, was after Jeffrey Epstein was arrested and
[3:24:08]during his plea negotiations with the U.S. Attorney's Office in Florida. Is that right?
[3:24:18]November 2007 would have been after he was arrested,
[3:24:22]and what was the second part of the question?
[3:24:24]During his plea negotiations with the U.S. Attorney's Office.
[3:24:29]I think so, yes.
[3:24:31]To your understanding, was the foundation created, whether in whole or in part,
[3:24:37]to give Jeffrey Epstein a place to perform his work release?
[3:24:42]I think the answer to that question is I believe that Epstein wanted work release.
[3:24:51]I believe that he wanted during his work release to do the scientific work that he was
[3:24:57]doing. He was an avid supporter of scientific research and academic research, and I believe
[3:25:05]that he wanted to continue that work if he were to get work release. And so I think in anticipation
[3:25:16]of that, I think it was a Florida law firm that, I think it was a Florida entity.
[3:25:23]The one that was incorporated was a Florida entity, is that right?
[3:25:25]That is my understanding.
[3:25:27]I believe the Florida law firm just set it up without kind of discussing that with
[3:25:35]in detail. And then once the conversation ensued further, I believe that it was determined
[3:25:47]that the foundation that was already doing that kind of work, like the COU Foundation was,
[3:25:53]should be the foundation that's doing it in Florida.
[3:25:58]I understand that the foundation had offices at 250 Australian Avenue in West Palm Beach.
[3:26:04]Is that accurate?
[3:26:06]That sounds right, yes.
[3:26:08]Were you ever present in those offices?
[3:26:10]I was in those offices. I wasn't stationed in those offices. My office was up north,
[3:26:19]but from time to time, when Epstein was on work release, and I would come down and
[3:26:27]have kind of the status conversation as to what's going on with the transactions that
[3:26:32]I'd been working on, it would be at that office.
[3:26:36]How often did that happen?
[3:26:42]I don't recall sitting here today.
[3:26:47]More than 10?
[3:26:49]It was there for, yeah, that's probably true.
[3:26:55]During any of those visits, did you see any women present in the offices?
[3:27:00]I believe there was a personal assistant present. I don't remember which one.
[3:27:07]Did you ever become aware of Epstein sexually abusing women in those offices?
[3:27:15]I became aware. I'm not sure if the allegation happened after he died,
[3:27:23]but I became aware of the allegation after the fact that he did.
[3:27:30]Did any woman ever tell you that she had been sexually abused by Epstein
[3:27:34]while he was on work release?
[3:27:36]No.
[3:27:38]Did any woman ever ask for your help in connection with sexual abuse by Epstein?
[3:27:42]No.
[3:27:45]Just the idea that that was taking place. I'm not saying it didn't,
[3:27:50]but it would have surprised me because when Epstein was on work release,
[3:27:56]there was a deputy sitting in the front desk, and the office wasn't that big, so
[3:28:03]that would have surprised me if that was going on.
[3:28:06]When you say deputy, you mean law enforcement?
[3:28:08]Like a law enforcement deputy sheriff.
[3:28:12]Did you at any time ever tell any woman making allegations about Epstein
[3:28:18]not to communicate with law enforcement?
[3:28:20]I would never have told them not to communicate with law enforcement.
[3:28:26]Did you visit Epstein in prison in Florida?
[3:28:28]I did.
[3:28:31]What was the reason for those visits?
[3:28:34]The reasons for those visits is that while he was in jail,
[3:28:38]there were five properties, there was construction going on on properties,
[3:28:43]there were investments that were outstanding at the time,
[3:28:45]there were things going on that required me to get instruction on,
[3:28:52]me to talk to him about, to give him status updates on,
[3:28:55]and that was the basis of the conversation.
[3:28:59]You were asked by the majority earlier today about
[3:29:08]tip off to Mr. Epstein of an FBI search.
[3:29:13]I don't want to belabor the point, but I'm just going to ask the question in
[3:29:16]a slightly different way for clarity of the record.
[3:29:19]Do you have any reason to believe that Epstein was tipped off about an FBI search?
[3:29:27]I don't have a specific reason to believe that.
[3:29:30]I've heard the allegation a bunch of times,
[3:29:33]and having learned things after he died about him,
[3:29:37]I would be less certain that it didn't happen.
[3:29:44]Do you have any knowledge of the removal of video equipment from any of Mr.
[3:29:50]Epstein's properties prior to execution of an FBI warrant?
[3:29:55]I need to speak to you about this.
[3:30:01]Preventive?
[3:30:02]Yes.
[3:30:03]Can't do it here.
[3:30:04]We can go off the record.
[3:30:05]Okay.
[3:30:06]Back on the record.
[3:30:18]Mr. Endicke, I'll repeat the question.
[3:30:22]Do you have any knowledge of the removal of any video equipment from any of Mr.
[3:30:28]Epstein's properties prior to the execution of an FBI warrant?
[3:30:33]A video equipment?
[3:30:34]Video equipment.
[3:30:38]No.
[3:30:40]So my next question is, do you have any knowledge of the removal of any
[3:30:44]computer equipment from any of Mr. Epstein's properties prior to the
[3:30:48]execution of an FBI search warrant?
[3:30:50]So just before we get to that,
[3:30:52]can we, you're the one asking the questions, not me, but can we first ask if
[3:30:55]he has any personal knowledge and then if you want to follow up, we can.
[3:31:00]Can you just qualify the question by adding the word personal?
[3:31:03]Well, that'd be helpful.
[3:31:05]Sure.
[3:31:08]Mr. Endicke, do you have any personal knowledge of the removal of any
[3:31:11]computer equipment from any of Jeffrey Epstein's properties prior to
[3:31:15]the execution of an FBI search warrant?
[3:31:17]I don't know if we can, if we can talk about a waiver here.
[3:31:22]All right.
[3:31:22]So I think he's prepared to tell you what he, well, that's why I asked for
[3:31:28]personal knowledge.
[3:31:28]I want to be clear about, did you have personal knowledge or anything
[3:31:33]that could have happened?
[3:31:34]I don't have personal knowledge of the removal of computer equipment.
[3:31:39]It wasn't part of anything like that at the time.
[3:31:41]I have no knowledge that it was done.
[3:31:44]And by personal knowledge, you mean firsthand knowledge?
[3:31:47]Do you have knowledge from another source?
[3:31:50]Okay.
[3:31:50]So now if I can, I think he's happy to answer the question.
[3:31:57]It may implicate a privilege, but to the extent that it's not going
[3:32:00]to be deemed as some broader waiver of privileges, he's ready to
[3:32:04]answer the question.
[3:32:04]So unless someone's going to claim that that is a waiver of any
[3:32:08]privilege that might exist.
[3:32:10]So I think for clarity, I'll just read for the record, the minority's
[3:32:15]position as to privilege assertions today.
[3:32:20]That is, as a general matter, Congress does not recognize common
[3:32:23]law privileges, including the attorney-client privilege.
[3:32:26]I will further note that the elements of the attorney-client
[3:32:29]privilege do not appear to be present as to the entirety of Mr.
[3:32:33]Endyke's communications with Mr. Epstein, among other reasons,
[3:32:37]Jeffrey Epstein was a serial sexual offender and abuser.
[3:32:43]As such, many, if not most of his communications with Mr.
[3:32:46]Endyke were utilized to further his crimes.
[3:32:49]Such communications are subject to the crime fraud exception to
[3:32:53]the attorney-client privilege.
[3:32:55]Moreover, the attorney-client privilege is, in essence, a
[3:32:58]policy choice.
[3:33:00]The minority does not believe that this policy supports
[3:33:03]maintaining any privilege that may exist with respect to a
[3:33:06]former client, such as Jeffrey Epstein, who is both deceased and
[3:33:11]perpetrated horrific crimes against numerous victims.
[3:33:14]Okay, so look, I respect the minority's views.
[3:33:18]I think the Supreme Court differs with the minority's views on
[3:33:21]attorney-client privilege.
[3:33:22]Having said that, one, I don't believe he's going to be
[3:33:27]talking about conversations with Mr. Epstein.
[3:33:30]That's not the privilege he'd be asserting.
[3:33:31]It's in the context of doing defense communications.
[3:33:36]And as I said, he's actually prepared to give you the answer.
[3:33:40]So it's not that we're now asserting privilege over it.
[3:33:44]But we, I'm stating for the record, this is not, in our
[3:33:49]view, redeemed as some broader waiver of privilege, regardless
[3:33:52]of whether you may recognize privilege.
[3:33:55]If you do, then we may have a different response.
[3:34:02]Sorry, just so we're clear on your position.
[3:34:05]Are you willing to answer, or is your client willing to answer
[3:34:09]the question on condition that we accept your premise that the
[3:34:15]privilege applies, but that his communication is not subject to it?
[3:34:19]Or just let me-
[3:34:20]No, I'm not asking you to accept that.
[3:34:23]Okay.
[3:34:24]Does or doesn't apply, because I understand your view to be it
[3:34:26]doesn't.
[3:34:26]In this context, we disagree.
[3:34:29]I'm asking you whether or not a privilege applies.
[3:34:32]Are you going to take a position that if he answers this question, and
[3:34:35]he does have privileges to assert, that by answering the question, he
[3:34:39]has more broadly waived any potential privilege in his communications
[3:34:44]with Mr. Epstein or anyone else on subjects related to Mr. Epstein?
[3:34:48]I think-
[3:34:49]Go on.
[3:34:51]Off the record for a second, please.
[3:35:03]On the record?
[3:35:05]We have consulted with counsel from the majority, who is going to
[3:35:09]articulate the committee's position on this question.
[3:35:11]Yeah, just to make clear, all objections are reviewed on an
[3:35:16]individualized basis based on the assertion of privilege at a given
[3:35:21]time, and the chairman makes those determinations, the minority or
[3:35:28]even majority staff.
[3:35:30]In this situation, the chair redirects the witness to answer the
[3:35:36]question and understands the issue raised by counsel as to assert that
[3:35:42]they don't view this as a blanket waiver and has stated all responses
[3:35:48]from the chairman related to objections or assertions of privilege
[3:35:52]are done on an individualized basis.
[3:36:02]Yeah, if I may ask just to be clear, and I understand that the
[3:36:08]decisions are made on a case-by-case basis, I think the
[3:36:11]issue we're raising is whether people can say that because he
[3:36:18]answers a question in the context of the one that was asked, putting
[3:36:24]aside what people's positions are on privilege generally, that
[3:36:29]the answer to this particular question, which is a pretty limited
[3:36:32]scope question, will not be deemed by Chairman Comer or the
[3:36:37]majority to be a broader waiver with respect to attorney client
[3:36:42]privilege that might apply to other issues.
[3:36:44]Given that each individual issue raised is done so on an
[3:36:48]individualized basis, and in this case, the decision here is specific
[3:36:58]to the question that has been asked.
[3:37:01]And so that the chairman will review all further objections should
[3:37:18]they be raised regarding any privilege that is asserted solely
[3:37:23]on the basis of the facts raised in that objection and will
[3:37:29]not hold facts related to other objections raised.
[3:37:37]Including the surface.
[3:37:42]We'll go off the record.
[3:37:56]Okay, so we will permit Mr. Indyk to answer the question with
[3:38:02]the understanding that we have that his answering that question
[3:38:06]will not be deemed a broader attorney client privilege waiver
[3:38:10]with respect to other topics, even if they relate to Mr.
[3:38:13]Epstein.
[3:38:14]And on that basis, he can answer the question.
[3:38:17]Thank you.
[3:38:19]So, during the course of some after Epstein's conviction, after
[3:38:28]he's after he served jail time, through conversations with
[3:38:33]defense counsel, I became aware that there were computer
[3:38:37]hard drives in the possession of private investigators.
[3:38:41]Not having done them, not having been participated in that
[3:38:45]in any way, I don't know when they were when they were
[3:38:48]removed, when they came in their possession, if they were
[3:38:51]removed, I just don't know how they came into possession,
[3:38:53]but I knew of the existence of hard drives.
[3:38:59]And did you come to know what was contained on those
[3:39:02]hard drives?
[3:39:03]No.
[3:39:12]Mr. Indyk, up until now, we've been talking about the
[3:39:14]investigation and prosecution of Jeffrey Epstein that
[3:39:17]were conducted in Florida.
[3:39:20]As you know, Mr. Epstein was subsequently investigated
[3:39:23]and executed in the Southern District of New York.
[3:39:26]Were you ever contacted by the Department of Justice or
[3:39:29]the FBI in connection with that investigation?
[3:39:32]No.
[3:39:34]Were you ever contacted by the Department of Justice or
[3:39:37]the FBI in connection with the investigation or
[3:39:40]prosecution of Ghislaine Maxwell in the Southern
[3:39:43]District of New York?
[3:39:45]I was not personally contacted.
[3:39:48]I can't recall if the estate's counsel was
[3:39:51]contacted.
[3:39:56]Do you have reason to believe that the estate's
[3:39:59]counsel may have been?
[3:40:05]Sitting here today would be a guess, and I don't
[3:40:07]really want to guess.
[3:40:07]I don't recall.
[3:40:13]And I don't recall any conversation subsequent to
[3:40:15]that.
[3:40:19]Mr. Indyk, I'm going to shift gears a bit.
[3:40:21]As we go forward, I'm going to ask you some
[3:40:24]questions about interactions with women linked to
[3:40:26]Jeffrey Epstein.
[3:40:28]Before I do that, I'm going to request of the
[3:40:31]majority that prior to any public release of the
[3:40:34]transcript or video of today's deposition, that
[3:40:37]the names of any actual or potential Epstein
[3:40:40]survivors that appear in any of the questions I
[3:40:42]pose or any of the answers to those questions as
[3:40:46]well as any other information in the record
[3:40:48]today from which a survivor could be identified
[3:40:51]be fully redacted.
[3:40:53]And with that, you spoke during the previous
[3:40:58]round about...
[3:41:00]So just so I'm clear, so I can be comfortable
[3:41:01]that if we're using the names of a potential
[3:41:05]victim, and I use the names here, that will be
[3:41:09]redacted and I don't have to worry about.
[3:41:10]So this is a request I'm making to the
[3:41:12]majority which controls redactions of the
[3:41:16]transcript prior to its public release.
[3:41:20]So 301 East 66th Street.
[3:41:27]There were, as I understood from your
[3:41:29]previous testimony, women connected to Jeffrey
[3:41:32]Epstein living in that building.
[3:41:33]Is that right?
[3:41:34]That's my understanding, yes.
[3:41:37]How many?
[3:41:38]I don't know.
[3:41:41]Did you ever interact with those women?
[3:41:45]Never in the building, to my recollection.
[3:41:48]Elsewhere?
[3:41:50]If they were in his office, yes.
[3:41:53]And who were those women?
[3:42:01]It's happened a while ago and I'm having
[3:42:04]trouble recalling who lived in the building,
[3:42:06]which is why I can't answer your question
[3:42:07]about how many.
[3:42:09]I'm having trouble recalling.
[3:42:11]I think Sue Hamlin may have lived in the
[3:42:14]building and I interacted with her
[3:42:19]when in the office, and at times when I
[3:42:25]visited at Mr. Epstein's home in New
[3:42:27]York in the dining rooms on the ground
[3:42:31]floor, I believe I saw her there and
[3:42:34]interacted with her there.
[3:42:37]Sorry, I believe I saw her there and
[3:42:39]interacted with her there.
[3:42:42]I'm trying to think if there are other
[3:42:44]people.
[3:42:50]I don't know.
[3:42:52]This is very hard because I don't know
[3:42:54]who's living there.
[3:42:56]And if you had names that you could
[3:42:59]give me, it would be helpful.
[3:43:01]We can put that aside for the moment.
[3:43:06]Did Jeffrey Epstein own the apartments
[3:43:08]at 301-866 that these women were
[3:43:10]living in?
[3:43:13]I'm not 100% certain about the
[3:43:15]relationship because it was a
[3:43:16]little vague.
[3:43:20]Jeffrey had a relationship with
[3:43:23]Osiris Properties, which owned the
[3:43:26]apartments.
[3:43:27]I think his brother was an owner of
[3:43:29]Osiris Properties in some form.
[3:43:35]I don't know if I believe.
[3:43:38]I'm not 100% certain because this is
[3:43:40]not something that I did, but I
[3:43:44]believe that Epstein was leasing a
[3:43:51]certain number of the apartments.
[3:43:54]Was Epstein paying rent for these
[3:43:58]women?
[3:44:00]I believe Epstein was paying rent for
[3:44:02]the apartments.
[3:44:04]The apartments where these women were
[3:44:06]living?
[3:44:07]Assuming there were women living
[3:44:09]there, yes, but again, I can't tell
[3:44:12]you who was living there.
[3:44:14]Don't recall, as I said, I do recall
[3:44:16]Sue Hamlin there.
[3:44:18]I don't recall who else was living
[3:44:21]there, but I also think because I
[3:44:27]remember there were leases for who
[3:44:33]was there, now that I'm thinking it
[3:44:36]through, was there as well.
[3:44:41]And those were in apartments, but I
[3:44:56]don't know if they were leasing
[3:44:57]directly.
[3:45:00]I remember getting a copy of the
[3:45:01]lease, but I don't know who was
[3:45:03]paying for the lease.
[3:45:07]What was your understanding as to how
[3:45:08]these women came to know Epstein?
[3:45:11]They don't have an understanding as
[3:45:12]to how they came to know Epstein.
[3:45:13]Did you ever discuss that with him?
[3:45:15]No.
[3:45:16]Did you ever see Epstein in the
[3:45:18]building?
[3:45:22]I'm trying to remember when I was
[3:45:23]living there, or when I was working
[3:45:26]there, Epstein wouldn't have been
[3:45:27]in the building, but when I was
[3:45:29]living there, I don't think I ever
[3:45:33]saw him in the building.
[3:45:40]Do you know Lana Pozhdayeva?
[3:45:44]I think that name refers to
[3:45:46]Svetlana Pozhdayeva.
[3:45:49]I do know, or did know, Svetlana
[3:45:52]Pozhdayeva.
[3:45:53]And who is Ms. Pozhdayeva, is how
[3:45:56]I'm pronouncing it.
[3:45:59]I believe she worked as an
[3:46:02]assistant for Mr. Epstein.
[3:46:05]I believe she was somebody who did
[3:46:10]marketing work for one of the
[3:46:11]foundations, one of the
[3:46:15]scientific foundations.
[3:46:19]I don't know of the
[3:46:21]relationship beyond that.
[3:46:25]What was your understanding of her
[3:46:26]relationship to Jeffrey Epstein?
[3:46:30]What I just told you was my
[3:46:31]understanding of the relationship.
[3:46:33]Did you ever understand it to be
[3:46:34]sexual?
[3:46:35]No.
[3:46:37]It's my understanding that Ms.
[3:46:38]Pozhdayeva had a business, is
[3:46:41]that correct?
[3:46:45]It was a woman empowerment
[3:46:46]business with that W-E
[3:46:49]something or other.
[3:46:50]It would be We Talks?
[3:46:52]W-E Talks?
[3:46:53]Yeah, I think that's what it
[3:46:54]was about.
[3:46:55]And I believe that she was, I
[3:46:58]think that business was doing
[3:47:03]presentations, conferences, things
[3:47:05]like that.
[3:47:06]And at some point later on Ms.
[3:47:10]Pozhdayeva had asked me to do
[3:47:12]some trademark work for that
[3:47:14]business.
[3:47:15]Did you do that work?
[3:47:16]I think I did, yes.
[3:47:17]Did she pay you for that work?
[3:47:19]No.
[3:47:22]Did Ms. Pozhdayeva ask you to
[3:47:24]do that work directly or did
[3:47:25]that request come from
[3:47:27]Epstein?
[3:47:28]She asked me to do the work
[3:47:29]directly.
[3:47:31]What about?
[3:47:36]I know the name and I think I
[3:47:38]know the person.
[3:47:39]I think I know that person as
[3:47:40]an assistant.
[3:47:44]Have you met her?
[3:47:47]I believe, yes, I believe I
[3:47:49]met her probably a handful
[3:47:51]of times.
[3:47:52]And again, did you ever
[3:47:54]understand that she was in a
[3:47:55]romantic or sexual relationship
[3:47:57]with Jeffrey Epstein?
[3:47:58]I had no understanding of any
[3:48:00]romantic or sexual
[3:48:01]relationship with Mr.
[3:48:02]Epstein.
[3:48:03]I'm going to ask the court
[3:48:09]reporter to mark as
[3:48:11]Exhibit A.
[3:48:13]B, I apologize, B.
[3:48:22]A check dated March 14, 2019
[3:48:28]appears to be drawn on
[3:48:30]Jeffrey Epstein's Deutsche
[3:48:32]Bank account in the amount of
[3:48:35]$375 made payable to
[3:48:39]Wynn's Health of Manhattan.
[3:48:44]All right.
[3:48:45]Mr.
[3:48:45]Randolph, have you seen this
[3:48:46]check before?
[3:48:50]I don't specifically remember
[3:48:51]this check.
[3:48:53]Is that your signature?
[3:48:55]It appeared to be my signature,
[3:48:56]yes.
[3:48:57]Do you recall ever writing a
[3:48:58]check on behalf of Jeffrey
[3:49:00]Epstein to Wynn's Health of
[3:49:01]Manhattan?
[3:49:02]I have no specific recollection
[3:49:04]of writing a check to Wynn's
[3:49:05]Health of Manhattan.
[3:49:06]Do you have an understanding
[3:49:08]as to what Wynn's Health of
[3:49:09]Manhattan is?
[3:49:12]No, other than what seems to
[3:49:14]be implied by its name.
[3:49:16]Which is?
[3:49:17]Some kind of a health service.
[3:49:20]As you sit here today, do you
[3:49:22]have any recollection or
[3:49:24]understanding as to why you
[3:49:25]would have been writing this
[3:49:27]check to Wynn's Health of
[3:49:28]Manhattan with the name
[3:49:32]appearing on the memo line?
[3:49:38]Again, I don't have any
[3:49:38]specific recollection as to
[3:49:40]why, but I can tell you
[3:49:42]that it was not uncommon for
[3:49:45]Epstein to pay for medical
[3:49:49]visits, tuition payments for
[3:49:53]people, both men and women who
[3:49:54]worked for him, who he knew,
[3:49:56]who were acquainted with him.
[3:50:00]So a check for $3.75.
[3:50:05]The likelihood that this check
[3:50:06]came to me by itself is
[3:50:09]probably very limited.
[3:50:11]The likelihood is probably in
[3:50:12]a stack of checks.
[3:50:13]If I was signing checks at
[3:50:15]that time, I would have gotten
[3:50:16]a stack of checks and there
[3:50:17]would have been something on
[3:50:18]there and if the person that
[3:50:20]provided to me had authority to
[3:50:23]request the check, then I
[3:50:24]simply would have signed the
[3:50:25]check.
[3:50:26]So this was not a big part of
[3:50:30]my role.
[3:50:31]It was a role that I had as an
[3:50:36]administrative function.
[3:50:39]So that's the best I can give.
[3:50:43]To your knowledge, were any of
[3:50:44]the payments that Jeffrey
[3:50:47]Epstein made to Women's Health
[3:50:49]of Manhattan in connection with
[3:50:51]the productive health services?
[3:50:54]I have no idea.
[3:50:56]No further questions.
[3:51:08]15 years again.
[3:51:09]In November of 2018, the Miami
[3:51:13]Herald published a series of
[3:51:15]articles about Epstein's crimes
[3:51:18]and allegations by additional
[3:51:20]women.
[3:51:21]Were you aware of that series?
[3:51:23]I became aware of the series,
[3:51:25]sure.
[3:51:26]And it's been reported that in
[3:51:27]the wake of the Miami Herald
[3:51:29]series, additional banks,
[3:51:31]including Deutsche Bank, dropped
[3:51:33]Jeffrey Epstein as a client.
[3:51:36]Is that consistent with your
[3:51:37]understanding?
[3:51:41]The time frame of that story
[3:51:44]makes sense.
[3:51:46]In the wake of that, I don't
[3:51:47]know if that's the correct
[3:51:48]characterization.
[3:51:51]I know that the articles came
[3:51:53]out and I know that
[3:51:54]subsequently the bank dropped
[3:51:56]Epstein as a client.
[3:51:59]It's also my understanding that
[3:52:01]after that happened, Jeffrey
[3:52:04]Epstein started transferring
[3:52:05]money to you and to Mr.
[3:52:07]Khan.
[3:52:08]Is that correct?
[3:52:09]Transferring money to me?
[3:52:10]Yes.
[3:52:18]Or either you or to your
[3:52:21]entity, Darren Endyke, PLLC.
[3:52:24]So there was a moment, and I
[3:52:26]think the moment that money
[3:52:27]was transferred to my entity,
[3:52:30]if I'm remembering this
[3:52:31]correctly, is after he was
[3:52:33]arrested again and in jail and
[3:52:37]money needed to come to my
[3:52:39]entity because that was the
[3:52:40]entity that was paying the
[3:52:42]law firms that were defending
[3:52:43]him.
[3:52:44]I believe that's what happened.
[3:52:49]Were there any other reasons
[3:52:50]for financial transfers from
[3:52:51]Mr. Epstein, either to you
[3:52:53]or to entities that you
[3:52:54]owned?
[3:52:58]This, other than to pay
[3:53:04]compensation to me, none that
[3:53:08]I'm aware of.
[3:53:13]Mr. Endyke, I'm going to shift
[3:53:15]gears once again and ask you
[3:53:16]some follow-up questions
[3:53:17]regarding Les Wexner.
[3:53:19]Okay.
[3:53:22]To begin with, do you ever
[3:53:24]meet Mr. Wexner in person?
[3:53:27]I've met Mr. Wexner on a
[3:53:28]couple of occasions.
[3:53:29]Yeah.
[3:53:30]What about Abigail Wexner?
[3:53:32]Met Abigail Wexner on a
[3:53:34]couple of occasions.
[3:53:35]Abigail Wexner is Les
[3:53:36]Wexner's wife?
[3:53:38]Yes, she is Les Wexner's
[3:53:40]wife.
[3:53:41]To your understanding, when
[3:53:42]did Jeffrey Epstein come to
[3:53:44]know Les Wexner?
[3:53:46]Pre-dated my arrival, so I
[3:53:48]don't know him.
[3:53:52]We spoke earlier about the
[3:53:53]work that Jeffrey Epstein
[3:53:55]did for Les Wexner.
[3:53:58]To your knowledge, apart
[3:53:59]from their business
[3:54:00]relationship, did Jeffrey
[3:54:01]Epstein also have a social
[3:54:03]relationship with Mr. Wexner?
[3:54:05]I'm not having a social
[3:54:07]relationship either with Mr.
[3:54:09]Epstein or with Mr. Wexner.
[3:54:12]I don't know the nature of
[3:54:13]their relationship.
[3:54:15]I know that from a business
[3:54:18]standpoint, they communicated
[3:54:19]frequently and on an isolated
[3:54:26]occasion, a rare occasion,
[3:54:28]I may have overheard the
[3:54:31]conversation, though not the
[3:54:32]detail of it, but it seemed
[3:54:34]like a friendly tone, but I
[3:54:38]don't have a full understanding
[3:54:39]of their kind of interactions
[3:54:41]outside of the business.
[3:54:43]Did there come a time when
[3:54:46]Epstein and Wexner had a
[3:54:47]falling out?
[3:54:48]Yes.
[3:54:49]When did that happen?
[3:54:53]My understanding at the time
[3:54:54]that it was happening, which
[3:54:55]is about the time that he
[3:54:56]was dealing with the negotiation
[3:55:01]with the U.S. Attorney's
[3:55:02]Office and looking that it
[3:55:05]was likely he was going to go
[3:55:08]to jail, and it may have been
[3:55:11]a little bit before then.
[3:55:12]And my understanding at the
[3:55:13]time as expressed to me was
[3:55:16]that because of Wexner's
[3:55:18]relationship as a principal of
[3:55:21]Victoria's Secret, it would
[3:55:23]be inappropriate for him to
[3:55:25]continue a relationship with
[3:55:26]Epstein.
[3:55:28]And as a result of that,
[3:55:30]there was going to be an
[3:55:31]unwind.
[3:55:33]Who told you that?
[3:55:39]I believe it was Epstein.
[3:55:44]I believe it was Epstein.
[3:55:47]Did you tell you anything
[3:55:48]else about their falling out?
[3:55:51]At the time that it was
[3:55:51]communicated to me, it
[3:55:52]wasn't a falling out.
[3:55:55]Subsequent to that time,
[3:55:58]I came to understand that
[3:56:02]there was, I don't know if
[3:56:05]that allegation may be too
[3:56:06]strong a word, but there was
[3:56:07]a concern about some of the
[3:56:09]tax planning that Epstein was
[3:56:12]doing for Wexner in the
[3:56:15]context of how certain
[3:56:18]properties Wexner was applying
[3:56:20]were to be held.
[3:56:24]I believe that
[3:56:28]Abigail Wexner didn't like or
[3:56:31]understand what it was,
[3:56:32]thought it was improper.
[3:56:35]My understanding at the time
[3:56:37]was that everything, at least
[3:56:40]as it was explained to me by
[3:56:41]Epstein, everything that
[3:56:43]Epstein did was with
[3:56:45]knowledge and consent of
[3:56:47]Mr. Wexner.
[3:56:48]But, you know,
[3:56:49]subsequent to that, it's
[3:56:51]now come out that Mr. Wexner
[3:56:55]has said that there was
[3:56:56]fraud involved.
[3:56:57]And at the time, what I
[3:56:59]understood to be was unwind
[3:57:02]because of the
[3:57:04]associational problem because
[3:57:06]of Epstein's, the tenor of
[3:57:09]Epstein's offenses that he
[3:57:11]was going to plead to.
[3:57:15]And Wexner's relationship with
[3:57:18]Victoria's Secret, and then
[3:57:20]subsequently there was this
[3:57:22]notion that some of the ways
[3:57:24]the properties were kind of
[3:57:25]were held were improper.
[3:57:28]And then that became a
[3:57:31]bigger deal.
[3:57:32]And then there was this
[3:57:33]unwinding.
[3:57:34]So that's that's what I
[3:57:36]recalled for me.
[3:57:37]Are you familiar with the
[3:57:38]Wexner Foundation?
[3:57:40]I'm familiar, to an extent,
[3:57:42]the Wexner Foundation, yes.
[3:57:44]It's my understanding that
[3:57:46]you served as secretary of
[3:57:48]the Wexner Foundation.
[3:57:50]In an administrative
[3:57:51]capacity, yes.
[3:57:52]For the purpose of signing
[3:57:55]signing documents, you
[3:57:56]know, secretary certificates,
[3:57:57]things like that.
[3:57:58]How did you come to take
[3:57:59]on that role?
[3:58:01]As part of my work for Mr.
[3:58:03]Epstein, I did take on work
[3:58:05]for Mr. Wexner.
[3:58:07]Was that at Epstein's request?
[3:58:09]Yes, with Wexner's knowledge,
[3:58:13]to be honest.
[3:58:16]It's also been reported that
[3:58:18]Abigail Wexner gave you
[3:58:19]power of attorney in
[3:58:21]connection with her condominium
[3:58:23]on the west side of Manhattan.
[3:58:24]Is that correct?
[3:58:27]At some point, I was asked
[3:58:29]to represent the Wexner's
[3:58:34]in connection with the
[3:58:35]acquisition of that property.
[3:58:38]This is what I'm thinking.
[3:58:40]I think that's what it was,
[3:58:41]and in connection with
[3:58:42]that transaction, I was
[3:58:43]given power of attorney.
[3:58:45]I don't specifically recall
[3:58:47]being given power of attorney,
[3:58:48]but it would have made sense
[3:58:50]because I would have had
[3:58:51]to sign documents because
[3:58:52]the Wexner's wouldn't be
[3:58:54]troubled to sign documents.
[3:58:55]They would have given me
[3:58:55]power of attorney so that I
[3:58:56]could sign the documents
[3:58:58]and do the closing.
[3:59:02]Did you become aware of
[3:59:06]Les Wexner sexually
[3:59:07]abusing any women?
[3:59:12]I'm going to ask you
[3:59:13]another question, and this
[3:59:14]may have been the conflict
[3:59:16]that you were describing earlier
[3:59:18]with respect to the
[3:59:19]Wexner's assets.
[3:59:22]Public reporting has suggested
[3:59:23]that Jeffrey Epstein
[3:59:25]stole significant sums,
[3:59:27]possibly hundreds of millions
[3:59:28]of dollars from Les Wexner
[3:59:30]by selling stock of Wexner's
[3:59:32]limited company through
[3:59:34]Wexner affiliated trusts
[3:59:36]and then misappropriating
[3:59:37]the proceeds for personal use.
[3:59:40]Are you familiar with that?
[3:59:42]I'm not familiar with that.
[3:59:44]Is that the situation
[3:59:45]that you were describing
[3:59:46]a few minutes ago?
[3:59:49]My level of this particular split
[3:59:55]was not at that high level.
[3:59:59]Like other things
[4:00:00]with Mr. Epstein
[4:00:01]and his clientele,
[4:00:02]the conversations he would have
[4:00:03]with the clientele
[4:00:05]would be between him
[4:00:06]and the clientele,
[4:00:07]and then I would get direction
[4:00:09]subsequent to that.
[4:00:10]So what Abigail Wexner
[4:00:15]thought Epstein did
[4:00:16]or didn't do
[4:00:16]was not something
[4:00:17]that I had personal knowledge of.
[4:00:20]I knew that there was
[4:00:22]an elevated tenor at the time
[4:00:25]and I knew that there was
[4:00:26]a need to unwind
[4:00:30]and that it became more
[4:00:33]I want to say urgent
[4:00:36]because of that elevated
[4:00:37]sense of things.
[4:00:40]Are you familiar with
[4:00:41]a friend or neighbor
[4:00:42]of Wes Wexner named
[4:00:44]Jack Kessler?
[4:00:47]I'm familiar with the name.
[4:00:48]I don't know Jack Kessler.
[4:00:52]We understand that
[4:00:54]Jeffrey Epstein
[4:00:56]at one point bought a house
[4:00:58]in New Albany, Ohio
[4:00:59]from Mr. Kessler.
[4:01:02]Are you aware of that transaction?
[4:01:05]No, the likelihood
[4:01:07]is that predatedly.
[4:01:10]Have you ever visited New Albany?
[4:01:13]When I first started
[4:01:14]working for Epstein
[4:01:15]and also started doing work
[4:01:16]for the Wexner family,
[4:01:18]I did, yes.
[4:01:19]How many times?
[4:01:23]A handful.
[4:01:25]I don't know exactly.
[4:01:27]It's a guess.
[4:01:31]Moving on from Mr. Wexner,
[4:01:33]you were asked about
[4:01:34]Gillian Maxwell earlier.
[4:01:36]I just had a few follow-up questions
[4:01:38]with respect to her.
[4:01:40]It's been reported
[4:01:42]that at one point
[4:01:43]Ms. Maxwell offered
[4:01:44]to look into the possibility
[4:01:45]of adoption for you
[4:01:47]and your wife.
[4:01:47]Is that correct?
[4:01:49]It was more of a jester.
[4:01:51]Now looking back on it,
[4:01:52]it was more of a jester that
[4:01:55]I was very upset at the time
[4:01:58]and visibly upset
[4:01:59]by the whole process.
[4:02:00]We had gone through it
[4:02:01]a bunch of times.
[4:02:02]We lost a child in the interim
[4:02:04]and every time when we'd go
[4:02:05]through a subsequent treatment,
[4:02:08]it failed.
[4:02:09]So at some point,
[4:02:11]what I perceived to be sensitivity
[4:02:15]to the plight
[4:02:15]that I was going through,
[4:02:19]Epstein had asked Gillian
[4:02:22]to kind of, again,
[4:02:24]as I perceived that she was
[4:02:25]good at organizing things
[4:02:28]because she was organizing
[4:02:29]his household,
[4:02:30]he asked her to kind of meet
[4:02:34]with me and Michelle,
[4:02:36]my wife, and talk to us
[4:02:39]about what we were looking at,
[4:02:41]what kind of options we had
[4:02:42]and is there something
[4:02:43]that could be done
[4:02:45]to help with any adoptions?
[4:02:48]I don't think she had
[4:02:49]any specific knowledge
[4:02:51]of adoptions
[4:02:52]or anything like that,
[4:02:53]but it was meant to be
[4:02:54]a gesture of sympathy.
[4:02:57]At least that's how I perceived.
[4:03:04]Did you ever discuss
[4:03:06]with Ms. Maxwell
[4:03:08]Epstein's relationships with women?
[4:03:10]No.
[4:03:18]It's been reported
[4:03:20]that you served as a trustee
[4:03:22]of a foundation that Maxwell ran.
[4:03:24]Is that accurate?
[4:03:26]In an administrative capacity,
[4:03:28]there's typically foundations
[4:03:32]required, a number of trustees.
[4:03:36]Would that be the Max Foundation?
[4:03:40]It was some time ago,
[4:03:41]but that sounds familiar.
[4:03:43]And how did you come
[4:03:43]to take on that role?
[4:03:45]I believe I was requested
[4:03:48]to do so by Ms. Maxwell.
[4:03:56]When did you become
[4:03:57]of Ms. Maxwell's arrest?
[4:04:01]Sorry, could you repeat
[4:04:02]the question, sir?
[4:04:03]When did you become aware
[4:04:04]of Ms. Maxwell's arrest?
[4:04:06]When it was reported
[4:04:07]in the paper or on the media.
[4:04:10]Did you ever speak to her
[4:04:12]about the charges against her?
[4:04:13]No.
[4:04:15]Did you ever speak
[4:04:16]to anyone else about them?
[4:04:19]In the context of conversations
[4:04:21]with counsel, I had conversations.
[4:04:25]When was the last time
[4:04:26]you communicated
[4:04:26]with Gillian Maxwell?
[4:04:31]I want to say
[4:04:35]before Epstein's death, I think.
[4:04:43]I don't remember exactly when.
[4:04:51]That's okay.
[4:04:56]Is this loud enough?
[4:04:56]Yes.
[4:04:59]I understood from your prior testimony,
[4:05:03]just to make sure
[4:05:04]I have a correct understanding
[4:05:06]your communications
[4:05:07]with Jeffrey Epstein
[4:05:09]were related either
[4:05:12]to corporate or securities work
[4:05:14]or the real estate matters
[4:05:16]that you described earlier today.
[4:05:18]Is that right?
[4:05:18]Or aircraft or business acquisitions
[4:05:23]or investment acquisitions
[4:05:26]and funds and summarizing the funds.
[4:05:32]But it was legal advice
[4:05:33]relating to other transactions
[4:05:35]or subsequently some discussions
[4:05:42]with counsel
[4:05:45]regarding the issues
[4:05:46]that he was facing
[4:05:47]because of his charges.
[4:05:49]And what about social matters?
[4:05:52]Sorry.
[4:05:55]I never spoke to Mr. Epstein
[4:05:56]about his social relationships
[4:06:00]and social activity.
[4:06:02]It wasn't my place.
[4:06:03]It wasn't my role.
[4:06:04]I'm going to ask the reporter
[4:06:06]to mark as Exhibit C
[4:06:10]an email that we obtained
[4:06:12]from the website J-Mail.
[4:06:16]It's dated, it's a thread
[4:06:18]dated May 25th of 2007.
[4:06:22]Please take the opportunity
[4:06:24]to review this document
[4:06:26]in its entirety.
[4:06:26]I'm only going to be asking you
[4:06:28]about the emails at the top
[4:06:35]and the one right below it
[4:06:36]on the first page.
[4:06:42]Sorry.
[4:06:43]Tell me again what I'm
[4:06:44]what you want me to focus on.
[4:06:45]Yep.
[4:06:46]I'm just going to ask you
[4:06:46]about the email at the top
[4:06:48]and the one right below it.
[4:06:50]So 3.36 p.m.
[4:06:52]and previous 10.27 a.m.
[4:06:58]Do you mind if I read the whole chain?
[4:06:59]Not at all.
[4:07:00]Do you have a sense of it?
[4:07:02]Can you read from back to front?
[4:07:15]Sorry, the back.
[4:07:16]I'll just front to back.
[4:07:18]No, back to front.
[4:07:19]I'll just, that's what it is.
[4:07:20]Okay.
[4:07:21]That's what we do.
[4:07:22]Thank you.
[4:07:24]There'll be no moment.
[4:07:25]Please.
[4:07:27]Sure.
[4:08:07]What little I remember about this.
[4:08:11]I don't think there's a question.
[4:08:13]Sorry.
[4:08:15]Go ahead.
[4:08:18]I'll start with the second email
[4:08:21]10.47 a.m.
[4:08:24]in which you write to Mr. Epstein
[4:08:27]regarding the issue
[4:08:28]of your close friends
[4:08:30]being in Palm Beach.
[4:08:32]So my first question is
[4:08:33]what was that issue?
[4:08:37]I think this, I think this related to
[4:08:41]when I think this related to
[4:08:46]putting together a list of friends
[4:08:48]for the defense counts.
[4:08:53]And I believe I was asked to go find,
[4:08:57]to get that list.
[4:08:59]And how did you determine
[4:09:01]which names to include in this list?
[4:09:03]I don't recall how I did it
[4:09:05]but my guess would have been
[4:09:07]my guess is that I would have
[4:09:09]told his assistant at the time.
[4:09:12]And who asked you to compile the list?
[4:09:20]I really don't remember.
[4:09:22]I don't remember if it was him
[4:09:23]or his defense counsel.
[4:09:26]And what use was this list
[4:09:33]intended to be put to?
[4:09:38]I don't think I ever got that far.
[4:09:51]No further questions on this document.
[4:09:53]Thank you.
[4:09:53]Thank you.
[4:09:55]Have you ever met
[4:09:56]Andrew Mountbatten-Windsor
[4:09:58]formerly Prince Andrew?
[4:10:00]Yes.
[4:10:02]When?
[4:10:06]It's difficult for me to say
[4:10:08]it was obviously before he died
[4:10:11]and it was also in the context
[4:10:12]of me going to the New York townhouse.
[4:10:16]Before Mr. Epstein died?
[4:10:17]Before Mr. Epstein died.
[4:10:18]Yes, sorry, not Andrew Windsor.
[4:10:20]Oh, also in the context of me
[4:10:24]going to Mr. Epstein's house
[4:10:27]for status updates on the matters
[4:10:29]that I was working on for him.
[4:10:35]I guess no longer Prince Andrew.
[4:10:37]That person was either
[4:10:40]then coming after a meeting
[4:10:42]or just leaving prior to a meeting.
[4:10:46]And either I was introduced
[4:10:49]once or twice to that person.
[4:10:53]The former Prince Andrew?
[4:10:55]Correct.
[4:10:56]So sorry, are we talking about
[4:10:57]more than one occasion?
[4:10:59]Twice.
[4:11:01]And were both of these encounters
[4:11:04]in Mr. Epstein's home?
[4:11:07]Yes, in the New York townhouse
[4:11:08]and they were passing encounters.
[4:11:11]Was the former Prince Andrew
[4:11:14]in the company of women
[4:11:15]when you met him?
[4:11:17]No.
[4:11:20]Did you ever become aware of
[4:11:23]the former Prince Andrew
[4:11:24]having a sexual relationship
[4:11:25]with any women connected to Jeffrey Epstein?
[4:11:28]I became aware of allegations
[4:11:30]made against Prince Andrew's subsequent.
[4:11:32]At what point in time?
[4:11:42]I don't even know how to triangulate that.
[4:11:45]Before Jeffrey Epstein's death?
[4:11:48]Yes.
[4:11:53]Before his Florida arrest?
[4:11:57]No.
[4:12:00]Have you ever met?
[4:12:02]I mean, that's helpful for me.
[4:12:05]Not before the arrest,
[4:12:07]not before the conviction either.
[4:12:11]I think it was subsequent to the jail time.
[4:12:15]Have you ever met Jess Staley?
[4:12:18]I met Jess Staley also
[4:12:20]about two times, maybe three times.
[4:12:22]Also once in passing
[4:12:24]and once I was delivering a document,
[4:12:28]a trust document to him.
[4:12:31]To Mr. Staley?
[4:12:32]To Mr. Staley, yes.
[4:12:33]Why was that?
[4:12:34]Mr. Staley was a signatory on a trust
[4:12:39]for Mr. Epstein.
[4:12:40]Do you recall which trust?
[4:12:42]It was a prior iteration
[4:12:43]of a state planning trust.
[4:12:47]Did you ever become aware of Mr. Staley
[4:12:49]having a sexual relationship
[4:12:51]with any women connected to Jeffrey Epstein?
[4:12:54]I have no personal knowledge of that,
[4:12:56]never observed anything like that.
[4:13:00]After Epstein's death,
[4:13:02]I became aware of their allegations,
[4:13:04]I think in the bank litigation
[4:13:06]that Staley had a relationship.
[4:13:08]Mr. Staley had a relationship
[4:13:10]and no way of knowing
[4:13:12]whether that's true or not.
[4:13:17]Mr. Embig, if I could return
[4:13:19]to the topic of private investigators.
[4:13:30]Sorry, I'm going to table this one
[4:13:31]for the moment and come back to it.
[4:13:43]Skipping ahead to Mr. Epstein's
[4:13:47]death and subsequent developments,
[4:13:51]when was the last time
[4:13:52]you spoke with Jeffrey Epstein?
[4:13:54]A couple of days before he died.
[4:13:56]What did you talk about?
[4:14:01]The-
[4:14:02]Just to be clear on that.
[4:14:04]It's privilege, it was not personal,
[4:14:06]it was privileged,
[4:14:07]it was based upon his being
[4:14:09]in the jail at the time.
[4:14:13]And it was regarding
[4:14:14]subjects that one would talk about,
[4:14:18]like bail and things like that.
[4:14:20]So I am going to ask the witness
[4:14:22]for the substance of those conversations.
[4:14:26]Those are subject to
[4:14:28]attorney Klein privilege, I think.
[4:14:29]Yeah, I think that-
[4:14:30]He's not going to be able to answer
[4:14:31]the details on that.
[4:14:33]Okay, so I'm going to refer
[4:14:35]that one to the majority for a ruling
[4:14:38]and for the record, the question is,
[4:14:40]what did Jeffrey Epstein say to you
[4:14:42]during your last conversation?
[4:14:45]What did you say to him
[4:14:46]during your last conversation with him
[4:14:47]those two days before he died?
[4:14:53]And you have a generic description
[4:14:57]of him already for the witness.
[4:14:59]The will, as we discussed earlier today,
[4:15:04]Mr. Endyke named you and Mr.
[4:15:06]Kahn as co-executors, correct?
[4:15:08]Correct.
[4:15:12]It also provides, as I understand,
[4:15:14]for Jeffrey Epstein's assets
[4:15:16]to ultimately be transferred
[4:15:17]is that correct?
[4:15:18]That's also correct.
[4:15:21]Let's take a moment on that.
[4:15:23]That's only after the will
[4:15:26]and the estate is fully probated,
[4:15:28]which means that all claims are paid.
[4:15:31]All of those issues have to be resolved
[4:15:33]before any assets, if there are any remaining,
[4:15:36]go to that trust and then are subject
[4:15:39]to the terms of that trust.
[4:15:42]And it's also my understanding
[4:15:44]that you and Karina Szuljak
[4:15:47]are the largest beneficiaries
[4:15:50]under the trust with bequests
[4:15:52]of $50 million, respectively.
[4:15:54]Is that right?
[4:15:56]Not exactly right.
[4:15:58]I believe that Karina has several bequests
[4:16:02]under that will, including the properties,
[4:16:05]including annuity,
[4:16:07]and including another disposition.
[4:16:11]The total amount of the dollar amounts
[4:16:15]I believe are like $100 million to her,
[4:16:17]plus all of the properties were to go to her.
[4:16:21]But obviously that didn't happen.
[4:16:24]But I am correct that the trust
[4:16:26]includes a bequest to you of $50 million.
[4:16:29]Trust includes a bequest to me
[4:16:31]for $50 million.
[4:16:33]Yes, but that, again,
[4:16:35]that only comes to play
[4:16:38]if any money is distributed to that trust.
[4:16:42]And then, and as it stands right now,
[4:16:45]certainly that amount's not coming
[4:16:47]to the trust of anything.
[4:16:49]Did you discuss with Jeffrey Epstein
[4:16:53]the subject of his making you
[4:16:55]a beneficiary of the trust?
[4:16:57]Just briefly, other than that
[4:16:58]he was doing it,
[4:16:59]and I should give direction
[4:17:00]to the attorney that was working on it
[4:17:02]to make the changes.
[4:17:05]Do you have an understanding
[4:17:06]as to why he named you as a beneficiary?
[4:17:08]No, I can't tell you what was in his mind.
[4:17:14]Did it surprise you?
[4:17:15]No, I was a beneficiary
[4:17:18]in previous iterations.
[4:17:19]But I, like many people,
[4:17:22]many of the professionals,
[4:17:26]assistants, colleagues,
[4:17:28]many people were in the document.
[4:17:32]Well, I think to come at it another way,
[4:17:35]the question I'm sure you can understand
[4:17:38]arises given, as you've testified earlier,
[4:17:42]that your relationship with Mr. Epstein
[4:17:45]was professional rather than social.
[4:17:50]Why would he include you
[4:17:53]as a beneficiary in his estate
[4:17:55]to the tune of $50 million?
[4:17:59]I can only speculate,
[4:18:00]and I don't want to speculate
[4:18:01]too far into it.
[4:18:03]A couple of things.
[4:18:05]Epstein had a brother
[4:18:07]who didn't have a lot of friends
[4:18:09]that he communicated with regularly,
[4:18:11]which is why the assets in his estate,
[4:18:13]it seemed to me,
[4:18:14]were distributed to people
[4:18:16]that were associated with him
[4:18:17]on a professional level.
[4:18:22]I think that the bequest to me
[4:18:26]as well as to Mr. Kahn
[4:18:28]were large bequests
[4:18:32]because there was a lot of work to be done
[4:18:34]in this very complex state.
[4:18:37]A lot of work,
[4:18:37]and the estate planning documents
[4:18:40]didn't provide for payment to us.
[4:18:43]And I think the idea
[4:18:46]was for the bequest to be payment.
[4:18:50]And for estates of this size,
[4:18:54]typically the more direct route for this
[4:18:58]is paying the trust,
[4:19:02]the administrators
[4:19:04]a percentage of the assets,
[4:19:05]in this case,
[4:19:06]well over $600 million
[4:19:07]for the assets in this estate
[4:19:11]and paid over time.
[4:19:14]In addition,
[4:19:17]it's anticipated in many instances
[4:19:19]that both the executors
[4:19:22]will also be doing other services,
[4:19:24]sometimes accounting work
[4:19:25]and legal work and things like that.
[4:19:28]So I believe that part of this
[4:19:32]was an understanding
[4:19:34]that Mr. Kahn and I
[4:19:36]would be providing substantial services
[4:19:38]for a very, very complex document,
[4:19:40]a very complex estate.
[4:19:43]And services, again,
[4:19:46]I don't mean to imply
[4:19:48]that's not a lot of money,
[4:19:49]but other folks
[4:19:51]who would have gotten paid
[4:19:52]for managing a state of this size
[4:19:54]would have gotten,
[4:19:55]given the complexity of the estate
[4:19:57]and given the amount
[4:19:57]we've been working on this for seven years.
[4:20:01]Seven years is probably another three to go,
[4:20:03]maybe more,
[4:20:04]by the time all the claims are resolved.
[4:20:08]I think even the complexity
[4:20:10]and the size,
[4:20:10]the compensation is a lot,
[4:20:12]but in that context,
[4:20:14]you have a different view.
[4:20:17]I think we will end our hour there
[4:20:19]as we go off the record.
[4:20:35]We'll go back on the record.
[4:20:40]Oh, the minority wishes
[4:20:42]to make a statement.
[4:20:46]Yeah, just to clarify
[4:20:48]for the record,
[4:20:49]it's probably with counsel
[4:20:51]over the assertion of privilege
[4:20:54]as to the question,
[4:20:56]what did Jeffrey Epstein
[4:20:57]tell you during your conversation with him
[4:21:00]two days prior to his death?
[4:21:03]We would like to refer
[4:21:04]that question to the chairman
[4:21:07]of the committee as to the applicability.
[4:21:12]Thank you.
[4:21:13]Mr. Timmons.
[4:21:14]Thank you.
[4:21:17]In the case
[4:21:19]that was recently settled,
[4:21:21]shamed of three,
[4:21:23]the indict can con.
[4:21:25]It's my understanding that
[4:21:27]you all sought to
[4:21:30]not disclose communications
[4:21:32]under attorney-client privilege
[4:21:34]and the judge ruled
[4:21:36]that those communications
[4:21:39]were not protected
[4:21:40]because of the crime fraud,
[4:21:42]the crime fraud exception.
[4:21:43]Incorrect.
[4:21:44]What's your next question?
[4:21:49]So the judge never
[4:21:52]ordered you all to turn over
[4:21:54]any documents
[4:21:56]because he deemed them
[4:21:57]not protected
[4:21:58]because of the crime fraud exception?
[4:22:00]Correct.
[4:22:01]Okay.
[4:22:09]Mr. Indyk, I would like
[4:22:11]to briefly return to the loans
[4:22:13]that Mr. Epstein extended
[4:22:15]to yourself and other employees.
[4:22:20]Is it fair to say
[4:22:21]that it was customary
[4:22:22]that he would provide these loans
[4:22:24]to employees?
[4:22:25]He was generous
[4:22:26]to many of his employees
[4:22:28]and, yes, did loan money
[4:22:30]to his employees.
[4:22:32]Would you have drafted
[4:22:34]the loan agreements?
[4:22:35]It would have been
[4:22:36]a promissory note, yes,
[4:22:40]but there was a form
[4:22:41]promissory note
[4:22:42]that was circulating
[4:22:43]around the office.
[4:22:46]Sorry, there was a form
[4:22:47]promissory note
[4:22:47]that was circulating around.
[4:22:50]As far as the loans themselves,
[4:22:54]were the loans ever used
[4:22:55]to justify large movements
[4:22:57]of money?
[4:22:58]No.
[4:22:59]Were loan agreements ever used
[4:23:01]to make illicit funds
[4:23:03]appear legitimate?
[4:23:05]No.
[4:23:14]Mr. Indyk, have you ever
[4:23:15]advised clients
[4:23:17]to destroy documents?
[4:23:18]No.
[4:23:22]Have you ever been instructed
[4:23:25]to destroy documents?
[4:23:29]No, I've never been instructed
[4:23:31]to destroy documents.
[4:23:32]There are, in the context
[4:23:34]of corporate law,
[4:23:36]there are document
[4:23:37]retention programs
[4:23:39]after a certain number of years.
[4:23:40]You can feel comfortable
[4:23:43]destroying documents,
[4:23:44]but no, never instructed
[4:23:47]and never received
[4:23:47]instructions to destroy this.
[4:23:51]So I want to return
[4:23:53]to the discussion
[4:23:55]during the previous hour
[4:23:58]as it related to computers
[4:23:59]that were removed.
[4:24:01]It was your testimony
[4:24:02]you had no personal knowledge of that
[4:24:04]and you learned subsequently,
[4:24:05]is that correct?
[4:24:06]That's correct.
[4:24:10]And during our first hour
[4:24:12]I asked you if you had
[4:24:16]if you had any knowledge
[4:24:19]that anyone would have tipped off
[4:24:21]Mr. Epstein to the October 20th
[4:24:23]search warrant in Palm Beach,
[4:24:24]I believe that you testified
[4:24:27]now, is that right?
[4:24:28]That's correct.
[4:24:29]Did you subsequently learn
[4:24:32]that Mr. Epstein was tipped off
[4:24:34]to the search warrant?
[4:24:36]No.
[4:24:42]Were you aware that Mr. Epstein
[4:24:44]had storage units?
[4:24:51]I don't, I don't.
[4:24:52]Can you tell me when
[4:24:54]and which storage units
[4:24:55]you're referring to?
[4:24:56]Because I have storage units,
[4:24:59]but not for Mr. Epstein.
[4:25:01]So I'm just,
[4:25:02]I want to make sure
[4:25:03]we're talking about the same thing.
[4:25:05]Mr. Indyte,
[4:25:06]it has been reported
[4:25:07]that Mr. Epstein
[4:25:08]directed private detectives
[4:25:10]to hide secret files
[4:25:11]and storage units across the U.S.
[4:25:14]Do you have any knowledge of that?
[4:25:15]I have no knowledge of that.
[4:25:17]And you haven't subsequently learned
[4:25:19]that he had any such
[4:25:23]process for hiding or concealing?
[4:25:25]Correct. I have not learned that.
[4:25:36]Earlier you testified
[4:25:38]that Mr. Epstein
[4:25:39]maintained a safe room.
[4:25:42]Can you elaborate
[4:25:43]on what the safe room was?
[4:25:47]I was not in the safe room.
[4:25:49]I actually never went inside it,
[4:25:51]but it was pointed out to me
[4:25:53]that it was a safe room
[4:25:54]and by safe room,
[4:25:56]what that means is if
[4:25:58]as I understand it,
[4:25:59]what that means is that
[4:26:00]if somebody is coming
[4:26:01]into your house to do you harm,
[4:26:03]you go into this room
[4:26:04]and they can't get in the room
[4:26:05]and you are there locked in
[4:26:07]and protected in the safe room.
[4:26:09]That's what I meant by safe room.
[4:26:12]And as I understand it,
[4:26:14]it is fairly typical
[4:26:16]on the outside of the safe room
[4:26:18]to have a camera pointing down
[4:26:20]so that you can see
[4:26:21]if people are trying to get
[4:26:22]into the safe room.
[4:26:31]Did you advise him
[4:26:33]to get a safe room?
[4:26:35]No, I had no idea
[4:26:36]he had a safe room
[4:26:39]until after he died
[4:26:40]and I took the residence.
[4:26:45]Now during the previous hours
[4:26:47]it's come up numerous times
[4:26:49]Mr. Epstein hired private
[4:26:51]investigators as a result
[4:26:53]of the 2006 investigation,
[4:26:55]is that right?
[4:26:57]My understanding is that
[4:26:58]his defense counsel
[4:27:00]hired private investigators.
[4:27:01]Who were the private investigators?
[4:27:11]I believe Riley Corrali
[4:27:14]was a private investigator.
[4:27:18]Did you have any interactions
[4:27:20]with the investigators
[4:27:22]or Mr. Curley?
[4:27:25]I have no specific recollection
[4:27:27]of an interaction with him.
[4:27:31]Now I asked you
[4:27:32]during the first hour
[4:27:33]if you had ever directed
[4:27:36]private investigators in any way.
[4:27:39]I believe you testified
[4:27:40]that you had not.
[4:27:41]But in connection
[4:27:42]with the investigation?
[4:27:44]Correct, correct.
[4:27:46]Did you subsequently learn
[4:27:48]about the directions
[4:27:50]that they were receiving
[4:27:51]from other counsels?
[4:27:58]Not in any kind of
[4:28:00]any real substance of manner.
[4:28:03]I knew that there were
[4:28:04]communications or I became aware
[4:28:06]of their communications
[4:28:08]that had happened between them
[4:28:09]but I wasn't privy
[4:28:10]to the content of the communication.
[4:28:13]It's been alleged
[4:28:14]that the private investigators
[4:28:19]were acting in such a way
[4:28:21]that was intimidating
[4:28:22]towards those that they were following.
[4:28:24]You didn't know anything about that.
[4:28:27]I remember seeing that allegation
[4:28:30]and I don't recall
[4:28:31]where I saw that allegation
[4:28:33]and that was,
[4:28:37]I think that happened
[4:28:40]I think that happened
[4:28:47]during the investigation
[4:28:52]by the U.S. Attorney's Office
[4:28:54]if I'm not mistaken.
[4:28:55]He's asked if you have
[4:28:56]personal knowledge of it.
[4:28:57]I have no personal knowledge of it.
[4:29:00]If it's personal knowledge
[4:29:01]the answer is no.
[4:29:02]Sorry, thank you.
[4:29:03]And you mentioned
[4:29:05]the private investigators
[4:29:08]that you knew of.
[4:29:09]Do you know what company
[4:29:10]they were with?
[4:29:11]No.
[4:29:13]Does Road Rock Investigation
[4:29:15]sound familiar to you?
[4:29:17]That name sounds familiar to me.
[4:29:23]It does sound familiar to me.
[4:29:24]Yeah.
[4:29:25]I don't know that it's because of that
[4:29:27]but the name sounds familiar to me.
[4:29:36]And I think I could supplement
[4:29:37]that a little bit.
[4:29:37]I believe Road Rock
[4:29:38]was used for background checks
[4:29:40]on new employees.
[4:29:47]Are there any storage units
[4:29:49]that were at any time
[4:29:50]in possession of the trust
[4:29:52]after Jeffrey Epstein's death?
[4:29:56]Can you repeat the question, please?
[4:29:59]After following Mr. Epstein's death
[4:30:01]were there any storage units
[4:30:04]in possession of the trust?
[4:30:07]Estate as a command.
[4:30:11]Excuse me, the estate.
[4:30:13]So after Mr. Epstein's death
[4:30:16]there were storage units
[4:30:18]but the storage units happened
[4:30:19]after we inventoried the assets
[4:30:22]and then moved them
[4:30:22]out of the houses into storage.
[4:30:25]They were relationships
[4:30:27]created after his death
[4:30:29]based upon, you know, furniture
[4:30:31]and whatever clothing
[4:30:35]and all the stuff
[4:30:35]that was put into the house.
[4:30:46]I'm going to zoom out a little bit
[4:30:48]and just talk about why we're here.
[4:30:52]Almost 300 victims have been documented
[4:30:55]and possibly up to another 100 out there.
[4:31:00]Pre-2008, 200 have been documented
[4:31:03]of which 70% of those
[4:31:05]these are all proximate or underage.
[4:31:07]Post-2008, there have been 70 documented.
[4:31:11]My understanding is that 0% were underage.
[4:31:15]To compensate those victims
[4:31:17]there's been around three quarters
[4:31:20]of a billion dollars in settlements
[4:31:22]from JP Morgan, Deutsche Bank,
[4:31:24]the estate, Bank of America
[4:31:27]and I think the purpose
[4:31:28]of this entire exercise
[4:31:31]is additional accountability.
[4:31:32]The American people are best
[4:31:33]and I think appropriately so.
[4:31:35]A very wealthy man has taken advantage
[4:31:39]and ruined a lot of lives
[4:31:40]and so I kind of view
[4:31:43]the whole purpose of this
[4:31:43]as being five different things we're doing.
[4:31:45]Number one, it seems
[4:31:47]there was these allegations
[4:31:48]that pre-2008 underage women
[4:31:51]were engaging in sex
[4:31:54]with rich old dudes
[4:31:55]and we want a list of those names
[4:31:57]and we're trying to figure that out.
[4:31:58]Second, there's possible undue influence
[4:32:01]associated with the guilty plea
[4:32:03]and the fact that he never really
[4:32:05]went to jail for stuff
[4:32:06]that put him on the sex finner registry.
[4:32:08]I was a prosecutor for five years.
[4:32:09]I know people that did less in him
[4:32:12]that got a very long time in jail
[4:32:13]and it seems that he was given
[4:32:15]a sweetheart deal.
[4:32:16]Number three, we want accountability
[4:32:18]for the people that conspired
[4:32:20]to continue the same scheme
[4:32:22]that he had pre-2008
[4:32:23]and honestly, I'll get back
[4:32:25]to that in a minute
[4:32:26]but that's the number one
[4:32:27]reason you're here.
[4:32:29]Number four, whether a foreign government
[4:32:31]or federal agency was involved
[4:32:32]in any of this,
[4:32:33]why he was doing the things
[4:32:34]that he was doing,
[4:32:35]it didn't make sense.
[4:32:36]And then last but certainly not least,
[4:32:38]deterrence to future perpetrators
[4:32:41]makes sure this doesn't happen again.
[4:32:44]Back to number three,
[4:32:45]the American people want accountability
[4:32:47]for people that conspired
[4:32:49]with Jeffrey Epstein
[4:32:50]to destroy these lives
[4:32:52]and you have been his attorney
[4:32:55]for decades
[4:32:56]and you were instrumental
[4:32:58]to his operations,
[4:32:59]his estate's operations
[4:33:01]and you've received millions
[4:33:02]and millions of dollars for that.
[4:33:03]So you're here answering questions.
[4:33:05]We appreciate that.
[4:33:07]I'm going to walk you through
[4:33:08]the scheme that occurred post-2008
[4:33:11]and it's really hard
[4:33:13]for me to believe
[4:33:14]that you were not complicit.
[4:33:15]You were not an instrumental part
[4:33:18]of his human trafficking operation.
[4:33:21]So for purposes of words,
[4:33:24]the only assistant he had
[4:33:26]was Leslie Groff.
[4:33:28]Everyone else is a survivor
[4:33:29]or a victim,
[4:33:30]whichever one you want to use.
[4:33:31]He may have called them assistants
[4:33:33]but he had this scheme.
[4:33:34]His scheme was to get them
[4:33:37]into the United States somehow.
[4:33:39]Some of them,
[4:33:40]it was a promise of education.
[4:33:42]Some of it was promise of modeling careers
[4:33:45]or jobs, whatever it was.
[4:33:47]And once he got them in,
[4:33:49]he used a pretty complicated scheme
[4:33:52]to trap them.
[4:33:54]And you actually were a part
[4:33:56]of every single one of those things.
[4:33:57]Immigration was one.
[4:34:00]I want to talk to you about that
[4:34:01]because you said that
[4:34:01]while you have had interactions
[4:34:04]with Arda Biscardi,
[4:34:09]there was just a lot
[4:34:10]of really shady things going on.
[4:34:12]And so you communicate with him
[4:34:14]about the two marriages
[4:34:17]for the assistants to each other.
[4:34:20]And it's your testimony here today
[4:34:23]under oath that you did not realize
[4:34:25]those were sham marriages.
[4:34:28]Just to be clear,
[4:34:29]because that was a long statement.
[4:34:31]And I know there's a question
[4:34:32]at the end.
[4:34:35]Okay.
[4:34:35]Well, but that's not fair
[4:34:36]to set a table,
[4:34:37]not give them a chance to react
[4:34:38]but then say,
[4:34:39]so after that,
[4:34:40]I have a very simple question.
[4:34:41]Just to be clear,
[4:34:42]before you just want them
[4:34:43]to answer the simple question.
[4:34:44]We'll back up, we'll back up.
[4:34:48]Remove my question.
[4:34:51]For the purposes of the rest
[4:34:52]of my questions,
[4:34:53]Leslie Groff is an assistant.
[4:34:55]Everyone else is a victim or a survivor.
[4:34:56]And I'm going to ask you about
[4:34:58]the scheme that occurred after that.
[4:34:59]If you want to argue
[4:35:00]with anything that I just said
[4:35:01]before I ask you questions
[4:35:03]about the scheme that occurred
[4:35:04]that you seem complicit in,
[4:35:05]by all means,
[4:35:06]say whatever you'd like.
[4:35:08]That's not a question.
[4:35:09]I mean, come on.
[4:35:10]So I just asked one question.
[4:35:12]Very simple.
[4:35:13]The question is this.
[4:35:16]Do you believe
[4:35:18]that the two marriages
[4:35:20]that you helped facilitate
[4:35:21]with Arda Biscardi
[4:35:23]were legitimate marriages
[4:35:24]or not?
[4:35:26]I don't know.
[4:35:28]But just because
[4:35:29]I think you asked
[4:35:30]that you helped facilitate
[4:35:31]the marriages.
[4:35:32]He's already testified.
[4:35:33]He didn't even know
[4:35:34]in advance of the marriage.
[4:35:36]Are you aware of the email
[4:35:37]in the Epstein files
[4:35:38]that I can get for you
[4:35:38]that says from Epstein
[4:35:40]to him copying both of you.
[4:35:41]I think that Arda Biscardi
[4:35:42]is going to flip on us.
[4:35:44]So, I mean,
[4:35:45]what was he going to flip on?
[4:35:46]How was he?
[4:35:47]What information did he have
[4:35:48]that would have caused him
[4:35:49]to flip on you?
[4:35:50]Okay.
[4:35:51]I have no recollection
[4:35:52]of that email.
[4:35:53]And let me be clear.
[4:35:54]I have no no belief
[4:35:56]at the time that
[4:35:57]I did anything
[4:35:59]for these marriages
[4:36:00]that they were share marriages.
[4:36:02]I didn't believe that.
[4:36:02]Just the marriage.
[4:36:03]I didn't believe.
[4:36:04]Let me finish, please, sir.
[4:36:05]I didn't believe them
[4:36:06]to be share marriages.
[4:36:07]I did not.
[4:36:08]I didn't have any reason
[4:36:09]to believe they were.
[4:36:11]These are women.
[4:36:12]These are women
[4:36:13]who I believed
[4:36:13]were associated with.
[4:36:15]These are women
[4:36:16]I believe to be associated
[4:36:17]with each other.
[4:36:18]I wasn't part
[4:36:19]of their social world.
[4:36:20]I did not question them
[4:36:21]why they got married.
[4:36:22]But they did get married.
[4:36:24]And I wasn't part
[4:36:24]of arranging those marriages.
[4:36:28]Absolutely was not.
[4:36:29]Did Epstein ever talk to you
[4:36:31]about trying to arrange marriages
[4:36:32]with members of the opposite sex
[4:36:34]to his the women
[4:36:35]you call assistants
[4:36:36]but were actually survivors
[4:36:37]or were victims?
[4:36:38]No.
[4:36:39]Okay.
[4:36:39]I mean, I'm not even sure
[4:36:40]what that question was.
[4:36:42]Did Jeffrey Epstein talk to you
[4:36:44]about marrying his assistance
[4:36:46]to other people
[4:36:47]in an attempt to address
[4:36:48]immigration fraud?
[4:36:49]No.
[4:36:54]Did you create leases
[4:36:56]for the six victims,
[4:36:59]survivors at 301 East 66th Street
[4:37:04]for the purpose of
[4:37:06]immigration fraud?
[4:37:08]I did not create leases,
[4:37:10]number one.
[4:37:11]It wasn't for immigration fraud
[4:37:13]that I obtained a copy
[4:37:14]of the leases
[4:37:15]from OSSA properties
[4:37:16]to give to Arda Biscardis.
[4:37:18]I was requested by the women
[4:37:20]to get a copy of the lease
[4:37:22]so that they could give it to Arda.
[4:37:23]And I did so.
[4:37:24]Did leases exist prior to that moment
[4:37:26]or were they just staying there
[4:37:27]without a lease?
[4:37:29]I don't know when the leases
[4:37:31]were created.
[4:37:32]I don't know when the leases
[4:37:33]were created.
[4:37:34]But given that this was property
[4:37:39]that Epstein had an ownership
[4:37:41]or a leasing interest in,
[4:37:44]it doesn't surprise me
[4:37:45]that if they were living
[4:37:46]in that property,
[4:37:47]they didn't have a written document
[4:37:49]and they needed a written document
[4:37:51]in order to give it to immigration.
[4:37:54]When they asked me
[4:37:55]for their written document,
[4:37:56]I asked OSSA,
[4:37:57]do you have a lease?
[4:37:58]Can you get me a lease?
[4:37:59]Did you ever change a lease
[4:38:00]for one individual
[4:38:01]to include two
[4:38:02]for the purposes of
[4:38:03]the immigration application
[4:38:07]was one person on a lease
[4:38:09]and then because
[4:38:11]the idea was saying,
[4:38:12]all right,
[4:38:12]we're going to marry these two.
[4:38:14]Did you change a lease
[4:38:16]that had one person's name on it
[4:38:18]to change at least
[4:38:19]to put two people's name on it
[4:38:20]for the purpose of
[4:38:21]then giving it to Arda Biscardis
[4:38:23]for the purpose of then
[4:38:24]filing for immigration documents?
[4:38:29]I think I probably did, yeah.
[4:38:31]Got it.
[4:38:31]I think I did, yeah.
[4:38:32]All right.
[4:38:32]You said earlier
[4:38:33]that you didn't know where-
[4:38:34]Let's talk about that for a minute
[4:38:36]because I know you want to
[4:38:36]jump to the next conclusion.
[4:38:38]Let's talk for that for a minute.
[4:38:39]If somebody gives me a lease
[4:38:40]and tells me this
[4:38:42]I need to give for immigration
[4:38:44]and it doesn't have both parties
[4:38:45]to the lease on the lease,
[4:38:47]I would have said to them,
[4:38:49]you should put both parties
[4:38:50]on the lease.
[4:38:50]Let me-
[4:38:51]We're going to walk through
[4:38:52]a bunch of questions here.
[4:38:53]You're going to have an answer
[4:38:53]to all of them
[4:38:54]but when you listen
[4:38:56]to these answers,
[4:38:56]you're going to say,
[4:38:57]oh, that's interesting.
[4:38:57]That could be true
[4:38:58]in this little narrow scope
[4:39:00]but then when you put them
[4:39:01]all together,
[4:39:01]it creates a different story.
[4:39:02]So we're going to keep going.
[4:39:03]Your story is based upon
[4:39:05]a hindsight that's based upon
[4:39:07]allegations that are made
[4:39:08]now looking back.
[4:39:09]Correct.
[4:39:10]And your story assumes
[4:39:12]that I had knowledge
[4:39:13]that these women
[4:39:13]had sexual relationships
[4:39:15]with Jeffrey,
[4:39:16]that these women
[4:39:17]didn't have relationships
[4:39:18]with each other
[4:39:19]and I absolutely did not.
[4:39:22]Okay.
[4:39:23]So you can piece together
[4:39:25]however you want.
[4:39:26]We're going to piece it together.
[4:39:27]However you want.
[4:39:28]Okay, so-
[4:39:29]You cannot make something
[4:39:31]that's not true true.
[4:39:32]So these six or seven survivors,
[4:39:34]when they got to this country
[4:39:36]under the promise of
[4:39:37]a job of education,
[4:39:42]of modeling,
[4:39:43]whatever it is,
[4:39:44]they didn't have an immigration issue.
[4:39:45]So I don't know-
[4:39:46]I don't know how they got
[4:39:47]to this country.
[4:39:48]I don't know about those promises.
[4:39:49]I know nothing of that.
[4:39:51]A lot of this is public record.
[4:39:53]That doesn't mean
[4:39:54]that I have knowledge of it.
[4:39:55]I'm sorry.
[4:39:56]But that's-
[4:39:57]But you were imputing knowledge
[4:39:58]to me that doesn't exist.
[4:40:00]So then they have
[4:40:01]to find a way to stay here
[4:40:03]and the way to stay here
[4:40:04]was through this immigration scheme
[4:40:08]which you were not
[4:40:10]overtly complicit
[4:40:11]and according to you
[4:40:11]but it seems that
[4:40:12]there's a lot of variables
[4:40:14]that cause a lot of questions.
[4:40:15]So let's go to the next one.
[4:40:17]Businesses.
[4:40:19]You previously said
[4:40:19]you did not set up businesses
[4:40:21]for any of these victims
[4:40:23]and I'm going to ask you again.
[4:40:25]Did you set up LLCs
[4:40:27]for any of the people
[4:40:29]that you call assistants
[4:40:30]that have been deemed victims
[4:40:31]by many courts?
[4:40:32]I believe that I testified
[4:40:34]that SLK Designs
[4:40:36]is something that I-
[4:40:37]that I formed.
[4:40:38]Any other-
[4:40:38]I testified that.
[4:40:39]Any other LLCs you created?
[4:40:41]I don't recall any other-
[4:40:42]Any other LLCs.
[4:40:43]So you do not recall
[4:40:44]creating any other LLCs
[4:40:45]for the victims
[4:40:46]that you call assistants?
[4:40:49]Are they-
[4:40:50]I don't recall setting up an LLC
[4:40:52]for a victim, number one.
[4:40:54]Do you recall setting up an LLC-
[4:40:55]Number two, if you have an LLC
[4:40:57]that you want me to ask-
[4:40:58]I have the artist's corporation
[4:40:59]but I'm not going to ask-
[4:41:00]Then tell me what they are
[4:41:02]and I'll answer
[4:41:02]whether or not I formed them
[4:41:04]or had something to do with that.
[4:41:05]I know you formed them
[4:41:06]because you're on the document
[4:41:07]that created them.
[4:41:08]Then tell me what they are.
[4:41:09]We're going to move on.
[4:41:12]Did you take out loans
[4:41:13]on behalf of the assistants?
[4:41:16]I'm going to keep calling them assistants
[4:41:17]but they're not.
[4:41:18]The only assistant is Leslie Gruff.
[4:41:20]Can you-
[4:41:21]Did I take out loans-
[4:41:22]You take out loans
[4:41:24]using their social security numbers,
[4:41:26]using their names,
[4:41:27]using their LLCs that you created
[4:41:30]on behalf of these assistants?
[4:41:32]No.
[4:41:34]So it would surprise you
[4:41:35]to say that some of the victims,
[4:41:37]some of the assistants
[4:41:38]have said that loans were taken out
[4:41:40]using their social security number
[4:41:42]and then held over them
[4:41:43]in addition to the leases
[4:41:45]that you created
[4:41:45]that you say you didn't create.
[4:41:47]So there's this complex
[4:41:49]immigration fraud scheme
[4:41:51]that you knew nothing about.
[4:41:52]There's this complex web
[4:41:54]of financial control
[4:41:56]and then we're just getting
[4:41:57]to the phone and the computers.
[4:41:59]Is there a question here?
[4:42:01]I'm showing you why it's incredulous
[4:42:05]that you're sitting here
[4:42:05]and saying that you had no knowledge of this.
[4:42:07]You're actually not showing them anything.
[4:42:09]You're just making a lot of statements
[4:42:10]and then just calling them a liar.
[4:42:12]So if you actually want to show them something,
[4:42:14]that'd be great.
[4:42:15]But you haven't yet.
[4:42:17]I've asked him under oath
[4:42:18]whether he created LLCs for the victims
[4:42:20]and he's saying that
[4:42:21]he did not accept for one.
[4:42:23]Firstly, you don't even say
[4:42:25]who you're talking about.
[4:42:26]So you're just general.
[4:42:27]I don't say who I'm talking about
[4:42:29]because I don't want to use names
[4:42:30]because they deserve their privacy.
[4:42:31]I totally agree.
[4:42:32]We have been on the same page.
[4:42:34]But the American people
[4:42:35]also deserve accountability.
[4:42:36]But you're asking
[4:42:37]if he's done something for somebody
[4:42:39]and not saying who it is
[4:42:40]and he's supposed to remember.
[4:42:43]You're putting him
[4:42:43]in a very difficult position.
[4:42:45]There's seven people.
[4:42:46]There's seven people
[4:42:46]that he knew the names of.
[4:42:48]What's seven people?
[4:42:49]First of all,
[4:42:50]I don't know that's seven people.
[4:42:52]Which people are you talking about?
[4:42:53]Tell me.
[4:42:54]The congressman has clarified,
[4:42:55]I believe,
[4:42:56]that his question applies
[4:42:59]to the assistants at the time.
[4:43:00]If there was anyone who had the title
[4:43:03]or role of assistant
[4:43:05]being granted a lease
[4:43:08]or a loan.
[4:43:09]If that can be the world
[4:43:11]of which we're working through
[4:43:12]for the purpose of this question.
[4:43:18]That's the thing about the loans
[4:43:19]because I don't really understand the question.
[4:43:22]Some of the assistants have alleged
[4:43:23]that loans were taken out
[4:43:24]in their name for their LLCs
[4:43:27]that they never signed off on.
[4:43:29]They never did their taxes.
[4:43:30]They had nothing to do with these LLCs
[4:43:32]and they were operated by you and Khan.
[4:43:34]Did they allege that I took out the loans?
[4:43:37]Your name is on the document.
[4:43:39]Did they allege that I took out loans for them?
[4:43:41]You signed it.
[4:43:42]I mean, I'm not going to sit here
[4:43:44]and out with people.
[4:43:45]Show me a document
[4:43:45]because I don't know
[4:43:46]what you're talking about.
[4:43:48]We will follow up.
[4:43:51]I'm not going to out people
[4:43:52]that want to move on with their life
[4:43:56]but we'll see what happens.
[4:44:02]Mr. Indyke, when I asked you
[4:44:05]about the storage units
[4:44:06]you asked us to be more specific.
[4:44:10]Do you recall any storage unit
[4:44:11]in Palm Beach, Florida?
[4:44:16]I have a storage unit
[4:44:18]or had a storage unit
[4:44:19]for the estate in Palm Beach, Florida
[4:44:22]when we emptied the house
[4:44:24]because it was going to be sold.
[4:44:27]All the contents of the house
[4:44:30]were taken out of the house
[4:44:32]and put in the storage unit.
[4:44:34]So what years would the...
[4:44:36]That storage unit doesn't exist anymore.
[4:44:38]Yeah, but what years
[4:44:39]would the contents of the house
[4:44:41]have been moved into the storage unit?
[4:44:44]Say that again, please.
[4:44:46]You said that it was all
[4:44:47]in furtherance of the estate.
[4:44:49]I'm just asking a clarifying question.
[4:44:51]Are we talking 2019
[4:44:53]that everything from the house
[4:44:55]would have been moved to the...
[4:44:57]2019 or 2020.
[4:44:59]What about West Palm Beach?
[4:45:02]The storage unit in Palm Beach
[4:45:04]for the Palm Beach house
[4:45:07]was in West Palm Beach.
[4:45:11]Were there any storage units
[4:45:13]in New York State?
[4:45:17]When the house was being prepared
[4:45:19]for sale in New York,
[4:45:24]a moving company
[4:45:28]also packed the belongings
[4:45:29]from that house
[4:45:30]and put them in a storage unit.
[4:45:33]I don't sit in here
[4:45:34]and know where the storage unit
[4:45:36]was located,
[4:45:36]whether it was New York,
[4:45:37]it may have been on Long Island City,
[4:45:38]it may have been across the river
[4:45:41]in New Jersey, I don't know.
[4:45:43]I'm going to save us time
[4:45:44]and just ask,
[4:45:45]are you aware of any storage units
[4:45:48]that were used prior to storage units
[4:45:54]for the estate?
[4:45:55]No.
[4:46:15]I believe I asked you in a previous hour,
[4:46:17]but I'm going to ask you again
[4:46:18]for the sake of these questions.
[4:46:20]Did Mr. Epstein ever discuss
[4:46:21]receiving massages with you?
[4:46:27]With me, no.
[4:46:28]In the context of
[4:46:32]conversations with defense counsel,
[4:46:35]they discussed them,
[4:46:36]but he never discussed them with me.
[4:46:41]Were you aware that Mr. Epstein
[4:46:43]was receiving massages?
[4:46:45]My understanding based upon
[4:46:46]what I learned from defense counsel
[4:46:49]and the statements
[4:46:50]that were in the police report
[4:46:51]was that there were massages,
[4:46:53]that some of them
[4:46:54]ended in sexual conduct,
[4:46:56]and that some of them involved
[4:46:58]underage people,
[4:46:59]that Epstein claimed
[4:47:01]they didn't know
[4:47:01]that they were underage,
[4:47:04]was adamant about it.
[4:47:06]There was a lie detector test
[4:47:09]in substance that said that,
[4:47:13]and again, the statement suggested
[4:47:15]there was no, or indicated
[4:47:17]there was no force, no coercion.
[4:47:21]After Mr. Epstein's incarceration,
[4:47:26]are you aware of whether
[4:47:27]he continued to receive massages?
[4:47:31]No, I'm not aware.
[4:47:33]At this time, I'd like to introduce
[4:47:34]will be marked as Majority Exhibit 5.
[4:47:45]This is base number EFTA 326543,
[4:47:50]and it is itinerary email
[4:47:52]from April 13th, 2016.
[4:48:28]Mr. Indyke, the sender,
[4:48:32]Baby Adieu, are you familiar with her?
[4:48:36]I am.
[4:48:37]Who is she?
[4:48:38]She was my assistant,
[4:48:40]and at times,
[4:48:43]and at times when
[4:48:45]Epstein's assistants
[4:48:47]were not available,
[4:48:49]I think Leslie,
[4:48:50]in particular, Leslie,
[4:48:52]BD would fill in for Leslie.
[4:48:56]Her office was down the hall from mine.
[4:49:01]When did Baby start?
[4:49:03]Her name is BD.
[4:49:04]BD start employment with you?
[4:49:06]I'm not sure.
[4:49:22]Somewhere around the mid-2010,
[4:49:27]I think 2014, 15, around there.
[4:49:32]And you mentioned that
[4:49:34]she would fill in for
[4:49:38]Mr. Epstein.
[4:49:39]Did Mr. Epstein direct you to hire her?
[4:49:41]No, I went to view her,
[4:49:45]got her name from,
[4:49:46]I think one of those job search places.
[4:49:51]She had previously worked for a law firm.
[4:49:56]Now I want to direct your attention
[4:49:57]just to the April 15th,
[4:49:59]2020, 2016,
[4:50:02]and it references a Thai massage course.
[4:50:09]Would it be,
[4:50:10]was it typical that,
[4:50:13]actually, let me back up.
[4:50:15]Who do you understand
[4:50:16]this itinerary to be prepared for?
[4:50:20]I don't have an understanding
[4:50:22]of who was prepared for it.
[4:50:23]Sense of BD.
[4:50:24]Would you presume
[4:50:25]that it was for Mr. Epstein?
[4:50:29]It seems like,
[4:50:30]that seems like that's right, yeah.
[4:50:41]It appears that your legal assistant
[4:50:43]had a role in scheduling massage courses.
[4:50:46]Would you disagree
[4:50:47]with that characterization?
[4:50:51]It would surprise me if that were true.
[4:50:53]This looks to me to be simply
[4:50:57]acknowledging as a reminder to him
[4:51:00]that this was scheduled.
[4:51:02]It's not something I ever received.
[4:51:05]And it doesn't indicate
[4:51:07]that she prepared it for him.
[4:51:10]This is in 2016
[4:51:12]after Mr. Epstein's incarceration,
[4:51:14]which was based on inappropriate conduct
[4:51:18]that was a result of massages.
[4:51:19]Would this strike you as unusual
[4:51:21]or concerning?
[4:51:24]Inappropriate conduct
[4:51:25]with underage women, right?
[4:51:29]And yeah, knowing what I know now,
[4:51:32]yes, of course, this is this is this is
[4:51:35]this is this concern.
[4:51:37]Who else worked at DKI?
[4:51:43]As I said,
[4:51:44]Leslie Groff worked for me for some time
[4:51:48]when Epstein was in jail.
[4:51:58]And during the minority's hour,
[4:52:00]you talked about performing legal work
[4:52:03]for that related to the Westerners.
[4:52:07]Did you ever perform legal work
[4:52:10]for Leon Black?
[4:52:12]Some.
[4:52:13]What was your relationship
[4:52:14]with Leon Black?
[4:52:15]Only through Mr. Epstein.
[4:52:17]What was the nature of the work
[4:52:19]you did for Mr. Epstein?
[4:52:22]Mr. Epstein did a did tax planning
[4:52:24]and estate planning for him.
[4:52:26]And the transactional work
[4:52:29]that I did was an offshoot of that.
[4:52:32]That worked.
[4:52:33]Did you have any interactions
[4:52:34]with Mr. Black outside of the work
[4:52:37]that you did for him?
[4:52:39]No, I did not.
[4:52:58]We discussed Bibi previously,
[4:53:01]but was she on an employer
[4:53:03]sponsored visa?
[4:53:04]Oh, Bibi.
[4:53:06]No, Bibi was.
[4:53:41]During the previous hour,
[4:53:43]it was mentioned that there was
[4:53:44]a joint defense agreement.
[4:53:47]Can you elaborate on what that is?
[4:53:51]I believe that was referring
[4:53:53]to the agreement among all
[4:53:54]of the defense counsel
[4:53:56]in connection with the investigation
[4:54:00]and negotiation of Mr. Epstein's
[4:54:04]issues in Florida.
[4:54:35]We've discussed Mr. Epstein's
[4:54:37]arrest in July of 2006,
[4:54:40]but I want to make sure
[4:54:41]the record is clear.
[4:54:43]Following his arrest,
[4:54:44]did you have any discussions
[4:54:46]with Mr. Epstein related
[4:54:48]to his arrest?
[4:54:51]Any discussions that I
[4:54:52]would have had would have been
[4:54:53]amongst counsel in relation
[4:54:56]to some of the civil claims
[4:54:59]that I had with him.
[4:55:02]But it would have been
[4:55:03]in a joint defense context.
[4:55:08]Was Epstein present?
[4:55:16]There were a number
[4:55:16]of those conversations.
[4:55:24]Yes, I can't tell you how many,
[4:55:26]but I assume he was present.
[4:55:33]Did Mr. Epstein ever discuss
[4:55:35]the allegations with you?
[4:55:37]No, and there was no discussion
[4:55:40]of the allegations.
[4:55:42]The discussion centered
[4:55:43]on the incorrectness
[4:55:47]of other people's statements.
[4:56:00]Mr. Indyk, with the benefit
[4:56:02]of hindsight, were there
[4:56:04]things you witnessed
[4:56:05]or observed about Mr. Epstein
[4:56:07]that could have suggested
[4:56:08]he was trafficking and sexually
[4:56:10]abusing young women and girls?
[4:56:17]At what period of time?
[4:56:21]During the entirety
[4:56:22]of your relationship?
[4:56:28]No, I had no knowledge
[4:56:35]of any allegations before 2006.
[4:56:39]And after 2006, when he
[4:56:41]ultimately went to jail
[4:56:43]and was back, my understanding
[4:56:46]was that the issue was
[4:56:47]underage people, sex
[4:56:50]with underage people.
[4:56:51]My understanding was that
[4:56:52]it was limited to Florida.
[4:56:57]And when I was in New York,
[4:57:00]which is where I spent my time,
[4:57:02]I never saw any underage people.
[4:57:04]I never saw any sexual activity.
[4:57:08]Nobody ever complained
[4:57:09]to me about sexual activity.
[4:57:11]I had no reason to believe
[4:57:12]that there was engaging
[4:57:13]in sexual activity.
[4:57:14]And frankly, given the amount
[4:57:16]of scrutiny that Epstein was under,
[4:57:18]I didn't believe he would
[4:57:19]do something like that,
[4:57:20]particularly after he told me
[4:57:21]he was going to be
[4:57:22]in that position again.
[4:57:23]He was by all accounts
[4:57:25]a very smart man.
[4:57:26]I couldn't imagine he would do
[4:57:28]anything to put himself back
[4:57:29]in that position again.
[4:57:31]So no, there's nothing that I saw
[4:57:35]that would lead me to believe
[4:57:36]that he was engaging in misconduct.
[4:57:38]And you've discussed at length
[4:57:40]the past that was withdrawn
[4:57:44]that I believe you had a role
[4:57:46]and in retrospect,
[4:57:48]would that have been something
[4:57:49]that should have raised concerns?
[4:57:52]Not with the size of his households,
[4:57:54]not with all of the things
[4:57:56]that was needed for that cash.
[4:58:00]I mean, the island alone,
[4:58:02]they were buying tools
[4:58:04]and supplies and furniture
[4:58:06]and all manner of things, food.
[4:58:10]They had construction workers
[4:58:13]on the island.
[4:58:14]Pools were breaking down
[4:58:15]all the time.
[4:58:15]They had machine shops.
[4:58:17]They needed lubricating supplies
[4:58:19]for the machine shop.
[4:58:23]Any number of things like that,
[4:58:25]given the size and scope
[4:58:27]of his households
[4:58:29]and the number of people involved
[4:58:30]and the fact that there wasn't
[4:58:32]a lot of credit cards
[4:58:33]available at the time
[4:58:35]because banks were basically
[4:58:37]shutting him down that way.
[4:58:40]No, the cash that was being asked
[4:58:45]for me seemed to be
[4:58:47]for legitimate purposes
[4:58:48]and I had no reason to think
[4:58:49]that they weren't
[4:58:50]for illegitimate purposes.
[4:58:51]Did you also handle his taxes?
[4:58:54]No.
[4:58:55]Did you ever review his tax returns?
[4:58:58]I reviewed his tax return.
[4:59:00]The answer is no,
[4:59:01]not while they were being done.
[4:59:03]In connection with the estate,
[4:59:06]I reviewed the tax return.
[4:59:10]Hundreds of thousands of dollars
[4:59:11]were given every year out in cash.
[4:59:13]I mean, technically,
[4:59:14]you have to file a 1099
[4:59:16]if you exceed $600
[4:59:18]in a year for services.
[4:59:19]So that's not-
[4:59:21]Are you aware that 1099s
[4:59:23]were not filed?
[4:59:28]We'll look into that
[4:59:28]and get back to you.
[4:59:29]Okay.
[4:59:31]But that's not my role.
[4:59:32]That wasn't what I did.
[4:59:49]I believe in previous hour
[4:59:52]you were asked questions
[4:59:53]related to visits
[4:59:54]to the Palm Beach jail
[4:59:56]while he was incarcerated.
[4:59:58]Yes.
[5:00:01]What were the purpose of these visits?
[5:00:04]I think I explained previously
[5:00:05]but I'll say it again.
[5:00:07]While he was in jail,
[5:00:09]there were households
[5:00:10]that were running.
[5:00:12]There were projects
[5:00:13]that were going on
[5:00:15]on Little St. James.
[5:00:18]I was handling lots of those kind of projects
[5:00:27]and lots of those kind of transactions.
[5:00:29]And I would go to him
[5:00:30]and report to him on the status.
[5:00:32]He would give me requests
[5:00:33]to take care of those types of projects.
[5:00:37]And I would implement those requests
[5:00:40]and report back to him.
[5:00:43]Did you provide Epstein with cash
[5:00:45]during these visits?
[5:00:47]In jail?
[5:00:48]Correct.
[5:00:49]No.
[5:00:54]Did you ever bring any other items
[5:00:57]or packages to Mr. Epstein
[5:00:58]while he was incarcerated?
[5:01:00]There was.
[5:01:02]When he first went into jail,
[5:01:03]I'd never been to jail before.
[5:01:04]So when he first went to jail,
[5:01:07]I believe I had a muffin
[5:01:08]that somebody wanted me to give him.
[5:01:10]And maybe a sweatshirt.
[5:01:11]I'm not sure if I had this.
[5:01:12]Somebody gave me to give him the sweatshirt.
[5:01:14]But I believe I brought that in
[5:01:16]and that was something that I brought.
[5:01:25]Did he ever ask you
[5:01:27]to deliver money or property
[5:01:28]to anyone outside of jail?
[5:01:30]No.
[5:01:33]Other than in the context
[5:01:34]of a transaction that we're working,
[5:01:35]but not in the context of anything
[5:01:38]illicit or improper.
[5:01:42]During the committee's investigation,
[5:01:45]we've been interested
[5:01:46]in the circumstances
[5:01:47]surrounding the non-prosecution agreement
[5:01:49]in 2008 and spoke with
[5:01:54]Alexander Acosta this past summer.
[5:01:57]Did you have any role
[5:01:58]in the 2008 non-prosecution agreement?
[5:02:02]Very, very minimal role.
[5:02:04]I looked at it once
[5:02:05]and I looked at some of the language
[5:02:07]and made a suggestion
[5:02:08]about some of the language
[5:02:09]I don't remember exactly which one.
[5:02:12]Did you settle victims' claims
[5:02:14]associated with the crimes pre-2008?
[5:02:17]Did I settle the claims?
[5:02:20]Were there dozens of victims
[5:02:22]that were underage
[5:02:23]that ended up suing
[5:02:24]Epstein or the estate,
[5:02:27]and did you settle those claims?
[5:02:28]I don't know the number
[5:02:29]of people that were underage,
[5:02:31]but there were,
[5:02:32]there was a list of people
[5:02:39]that the government provided.
[5:02:43]I believe there were a number of those,
[5:02:45]a number of those people
[5:02:46]that filed claims against Epstein
[5:02:50]and those claims were
[5:02:51]ultimately settled, yes.
[5:02:52]Were those settled in 2009-10
[5:02:54]or were they settled post-death?
[5:02:56]2009-10.
[5:02:58]Okay, so you, in fact,
[5:03:02]did have to get somewhat involved
[5:03:04]in the alleged criminal activity
[5:03:07]prior to that to settle the claims.
[5:03:09]I wasn't involved
[5:03:10]in this criminal activity.
[5:03:11]Well, you had to understand
[5:03:13]the depths of it
[5:03:13]because you had to settle the claim
[5:03:15]on behalf of the state.
[5:03:16]So that we're clear,
[5:03:17]people settle claims
[5:03:18]for all kinds of reasons,
[5:03:20]all kinds of reasons,
[5:03:21]including the cost of litigating,
[5:03:24]the time spent litigating,
[5:03:27]how much it interferes
[5:03:28]with your current business.
[5:03:31]So wait, did he go to jail
[5:03:33]because he didn't do anything wrong?
[5:03:34]I didn't say that.
[5:03:35]Okay, so he did something wrong
[5:03:36]and he settled the claim.
[5:03:39]You're saying he didn't, I mean.
[5:03:40]No, no, I'm not saying that
[5:03:42]and you're putting words
[5:03:42]into my mouth
[5:03:43]and it's actually unfair.
[5:03:45]What I'm saying is
[5:03:46]on a case-by-case basis,
[5:03:50]you can look at a settlement
[5:03:52]and see whether or not
[5:03:53]the claims in those cases
[5:03:55]have merit
[5:03:55]or they don't have merit.
[5:03:57]And while I will never
[5:03:58]be in a position,
[5:03:59]I will never want to be put
[5:04:00]to the task of saying
[5:04:02]that any particular woman
[5:04:04]who's claiming abuse
[5:04:05]wasn't abused,
[5:04:06]I won't do that.
[5:04:07]I will say that
[5:04:08]there were facts that came to light
[5:04:09]during the Defense Council's
[5:04:12]investigation of many
[5:04:13]of these claims,
[5:04:13]which suggested
[5:04:15]that some of these claims,
[5:04:16]that some of these allegations
[5:04:17]in these claims
[5:04:18]were not accurate.
[5:04:20]So which claims were true?
[5:04:22]Which claims are not true?
[5:04:23]I don't know.
[5:04:24]I wasn't there.
[5:04:25]I wasn't in Florida.
[5:04:26]I don't know what was true
[5:04:27]or was not true.
[5:04:27]But you were involved.
[5:04:28]But let me finish
[5:04:29]what I was saying, please.
[5:04:30]What I have said
[5:04:32]is that now it's clear
[5:04:35]that there was misconduct, okay?
[5:04:38]I also was clear
[5:04:39]that when he was in jail
[5:04:41]and he looked devastated
[5:04:42]and told me he wasn't
[5:04:44]ever going to be
[5:04:45]in that position again
[5:04:46]and told me he didn't know
[5:04:48]that there were people
[5:04:49]that were underage
[5:04:50]and said this was never
[5:04:51]going to happen again,
[5:04:52]I believed him.
[5:04:53]And I told you
[5:04:54]in my opening statement
[5:04:55]that that was a mistake.
[5:04:57]And I do feel horrible
[5:04:58]about that.
[5:05:00]Had I known that he was doing it,
[5:05:02]I would have walked away.
[5:05:05]But in the context
[5:05:06]of all of this,
[5:05:07]all of the information
[5:05:09]that was provided,
[5:05:10]which suggests that
[5:05:12]a lot of what was being said
[5:05:13]was not true
[5:05:15]and a lot of what
[5:05:16]was being claimed about
[5:05:18]happened in the past.
[5:05:19]After he had gone to jail
[5:05:20]and after he said
[5:05:21]he wasn't going to do it again,
[5:05:23]I didn't have a reason
[5:05:24]to believe after he got out
[5:05:25]that he was doing it again.
[5:05:27]I started out,
[5:05:28]the first question I asked
[5:05:29]was about this
[5:05:30]because in your opening statement
[5:05:31]you said,
[5:05:33]I made the mistake
[5:05:34]of believing Mr. Epstein
[5:05:35]that he would not
[5:05:36]again commit a crime.
[5:05:38]He has never been indicted,
[5:05:40]charged,
[5:05:41]I don't even know
[5:05:42]if he's been investigated
[5:05:43]for anything after 2009.
[5:05:45]I mean the indictment
[5:05:46]in 2019 was 2002,
[5:05:47]2005.
[5:05:48]So what criminal activity
[5:05:51]are you aware of
[5:05:51]that occurred
[5:05:52]after he got out of prison
[5:05:54]that violated your trust?
[5:05:56]Is what you're talking about here.
[5:05:57]When he died
[5:06:00]and it precipitated
[5:06:03]kind of a flow
[5:06:05]of people coming
[5:06:06]and making claims against it,
[5:06:08]claims against Epstein.
[5:06:10]And there were lots of people
[5:06:11]that made claims
[5:06:11]against Epstein.
[5:06:13]And there were lots of people
[5:06:14]that went to the Epstein
[5:06:15]Victims Compensation Fund
[5:06:17]to make claims against Epstein.
[5:06:20]With that benefit
[5:06:22]and as you said,
[5:06:24]how could I possibly say
[5:06:25]that nothing happened
[5:06:26]with that number of claims out there?
[5:06:29]And given that,
[5:06:34]that's what I was talking about.
[5:06:36]I don't know what's true,
[5:06:37]what's not true,
[5:06:38]but I know there's stuff there.
[5:06:40]The crimes that have been alleged
[5:06:42]are sex assault,
[5:06:43]are sex trafficking,
[5:06:45]human trafficking,
[5:06:46]what else is on the left?
[5:06:49]I don't know if the crimes
[5:06:51]are sex trafficking
[5:06:52]or human trafficking.
[5:06:53]What I know is that
[5:06:54]people claimed
[5:06:55]that he abused them,
[5:06:58]he sexually abused them.
[5:07:00]There were claims,
[5:07:02]I believe,
[5:07:02]in some of the complaints
[5:07:03]that were filed
[5:07:04]after he died
[5:07:05]about rape.
[5:07:08]Those are the claims
[5:07:09]that I did not know about.
[5:07:13]How many of the victims
[5:07:15]that have made claims
[5:07:17]and have recovered
[5:07:19]from the different funds
[5:07:21]post-2008,
[5:07:23]did you interact
[5:07:24]with on a regular basis
[5:07:26]in your capacity as his lawyer?
[5:07:27]A very small minority of them.
[5:07:30]A dozen?
[5:07:33]The only people
[5:07:34]that I would have interacted with
[5:07:35]were people who were
[5:07:37]Ostensibly assisted.
[5:07:38]Ostensibly assisted.
[5:07:47]You had mentioned
[5:07:49]that your role
[5:07:51]with the non-prosecution agreement
[5:07:52]was related to
[5:07:54]making a single suggestion,
[5:07:56]is that right?
[5:07:58]Reviewing the agreement
[5:07:59]for language,
[5:08:01]and I don't remember
[5:08:02]specifically
[5:08:03]what the language was,
[5:08:04]but I was one of...
[5:08:07]I wasn't a criminal attorney.
[5:08:08]There were criminal attorneys
[5:08:09]like Roy Black
[5:08:10]and Lily Sanchez
[5:08:11]and people who were
[5:08:13]celebrated criminal counsel
[5:08:14]that were looking
[5:08:15]this thing over.
[5:08:16]So my input was
[5:08:19]margin with best.
[5:08:21]What suggestion
[5:08:22]did you make?
[5:08:24]It was a linguistic one.
[5:08:28]For the record,
[5:08:29]did it have anything to do
[5:08:31]with those identified
[5:08:33]to be co-conspirators?
[5:08:39]With the language of that?
[5:08:40]Yeah.
[5:08:41]I think maybe it did.
[5:08:42]Yeah.
[5:08:48]In relation to the co-conspirators,
[5:08:50]did it have to do
[5:08:52]with creating a list
[5:08:54]of individuals
[5:08:55]who would be protected
[5:08:56]as co-conspirators?
[5:08:58]No.
[5:09:04]It's been alleged
[5:09:07]repeatedly that Mr. Rapsin
[5:09:09]used his influence,
[5:09:11]his connections,
[5:09:12]to powerful figures
[5:09:14]to curry favor
[5:09:15]and receive this
[5:09:19]non-prosecution agreement.
[5:09:22]Is there anything that
[5:09:25]as far as the circumstances
[5:09:26]surrounding the
[5:09:26]non-prosecution agreement
[5:09:28]that would be
[5:09:31]concerning in that regard?
[5:09:36]I don't think so
[5:09:37]because my view
[5:09:38]of the non-prosecution agreement,
[5:09:40]although based upon
[5:09:44]the positions laid out
[5:09:46]by the defense council,
[5:09:49]was probably different
[5:09:51]than other people.
[5:09:52]The non-prosecution agreement
[5:09:53]was based upon
[5:09:58]attempts to charge Epstein
[5:10:01]for what the defense council
[5:10:02]were telling the government
[5:10:05]were state crimes.
[5:10:09]And what the defense council
[5:10:10]was saying at the time
[5:10:11]was that the crimes
[5:10:15]that were actually
[5:10:17]testified to,
[5:10:19]the crimes,
[5:10:21]the actions
[5:10:22]that were actually testified to
[5:10:25]were activities
[5:10:27]which weren't
[5:10:30]according to the defense council,
[5:10:32]weren't what was intended
[5:10:33]by the sex trafficking statutes.
[5:10:39]And so my understanding
[5:10:42]subsequently came
[5:10:43]that after they reached
[5:10:48]this agreement,
[5:10:49]which none of the defense council
[5:10:51]was satisfied with,
[5:10:53]that even after they reached
[5:10:54]the agreement,
[5:10:55]they were fighting it
[5:10:56]with Acosta's office a lot.
[5:11:00]They explained that
[5:11:04]they went back
[5:11:04]and talked about how
[5:11:05]the record was defective.
[5:11:07]They went back
[5:11:07]and talked about how
[5:11:08]the petite policy
[5:11:10]should make it
[5:11:12]so that the federal government
[5:11:13]doesn't get involved in this case.
[5:11:15]They mentioned the fact
[5:11:16]that there was a state sex crime prosecutor
[5:11:18]that made a determination,
[5:11:20]that there was a grand jury
[5:11:21]determination,
[5:11:22]a grand jury convened
[5:11:23]that had a determination
[5:11:25]and that the federal government
[5:11:27]shouldn't be involved in this.
[5:11:28]And again,
[5:11:30]listed why the statutes
[5:11:34]that were being cited by the government
[5:11:35]were not intended
[5:11:37]to be used in this way.
[5:11:39]And I think based on what I recall
[5:11:42]Acosta saying
[5:11:43]was that Acosta wanted
[5:11:45]to get something out of this.
[5:11:46]He was concerned
[5:11:48]that maybe Epstein
[5:11:50]would be able to beat
[5:11:52]the charges
[5:11:54]and wanted to make sure
[5:11:55]that Epstein actually did jail time
[5:11:57]and also wanted to make sure
[5:11:59]that Epstein had to plead
[5:12:00]to an offense
[5:12:04]that would require him
[5:12:05]to register as a sex offender
[5:12:08]and registration as a sex offender
[5:12:11]is a lifetime.
[5:12:13]And those were his goals
[5:12:15]and the defense counsel
[5:12:17]was not particularly crazy
[5:12:19]about what his goals were
[5:12:21]given what the state outcome was.
[5:12:24]And Acosta, as I understood
[5:12:26]and were challenging
[5:12:28]the deal that was made.
[5:12:30]So the defense counsel
[5:12:31]didn't look at this
[5:12:32]as a sweetheart deal
[5:12:33]and that's the view that I had
[5:12:34]based upon what they were saying to me.
[5:12:36]Outside of Acosta,
[5:12:38]are you aware of any efforts
[5:12:40]to talk to his superiors
[5:12:43]or any other government officials
[5:12:45]related to the claims
[5:12:47]against Mr. Epstein?
[5:12:49]No.
[5:12:50]Did you have any role
[5:12:52]in negotiating
[5:12:55]Mr. Epstein's work release?
[5:12:57]No.
[5:12:58]During the previous hour
[5:13:00]the minority asked you
[5:13:01]about the Florida Science Foundation,
[5:13:03]is that right?
[5:13:04]Yes.
[5:13:05]And I believe that
[5:13:06]you had mentioned that
[5:13:07]its purpose was
[5:13:09]in the furtherance of
[5:13:10]scientific endeavors.
[5:13:11]Is that a fair characterization?
[5:13:13]Yes.
[5:13:14]What specific scientific endeavors?
[5:13:17]It's really that's something that
[5:13:19]Epstein was as
[5:13:20]I think has been reported.
[5:13:21]Epstein was very interested
[5:13:24]in scientific and academic research
[5:13:26]in a lot of different areas.
[5:13:28]It wasn't something that I
[5:13:30]did much in the way of.
[5:13:31]But the idea was to
[5:13:35]to search out and find
[5:13:38]these types of projects
[5:13:40]that were worthy of funding
[5:13:41]and then fund them.
[5:13:45]I can't tell you the specific kinds.
[5:13:47]Do you know any
[5:13:49]entities or individuals
[5:13:50]that he would have interacted with
[5:13:52]in the furtherance
[5:13:53]of the foundation?
[5:13:54]A couple of universities
[5:13:55]I think have been reported.
[5:13:56]I think Princeton was one.
[5:13:58]There was one
[5:14:00]in the Southwest.
[5:14:01]I can't remember where.
[5:14:03]Harvard was one.
[5:14:04]Stuff about the brain that
[5:14:07]that he was he was looking at.
[5:14:12]There's some academic research
[5:14:13]that I wasn't really familiar with
[5:14:14]that I know that he was
[5:14:15]looking at as well.
[5:14:17]And when he was on
[5:14:17]this work release,
[5:14:18]did you have meetings with him
[5:14:20]at the office
[5:14:21]that they were working out of?
[5:14:23]In the same way that I would go
[5:14:25]to his house in New York
[5:14:27]when he was on work release,
[5:14:28]I would travel to Florida
[5:14:29]and meet with him at the office
[5:14:31]to report on the status of things
[5:14:34]that I was working on for him.
[5:14:36]And for the record,
[5:14:37]because I don't believe it was asked,
[5:14:39]where was this office?
[5:14:41]I think it was stated by someone
[5:14:43]that it was on 250
[5:14:45]Australian Avenue
[5:14:46]or South Australian Avenue.
[5:14:52]Did you ever
[5:14:53]when you visited him at this office,
[5:14:56]did you ever see
[5:14:57]young women or girls?
[5:15:01]I saw people that I understood
[5:15:03]to be his assistants.
[5:15:05]At the office.
[5:15:11]Did you have to deal with
[5:15:11]any issues associated with him
[5:15:13]registering as a sex offender
[5:15:14]relative to his different properties?
[5:15:16]In South Carolina,
[5:15:17]you can't live in like most places.
[5:15:19]So did he have any issues with that?
[5:15:22]Ask me again.
[5:15:23]Once he was registered
[5:15:24]as a sex offender,
[5:15:25]he still already owned
[5:15:26]all these properties.
[5:15:27]In South Carolina,
[5:15:27]you're not allowed to live
[5:15:28]a lot of places,
[5:15:29]parks, schools,
[5:15:31]just there's no-go zones.
[5:15:33]Did you have to deal with
[5:15:33]any of that associated
[5:15:34]with his existing properties?
[5:15:36]I did a little bit, sure.
[5:15:39]But usually in conjunction
[5:15:40]with the criminal counsel.
[5:15:43]So obviously we had to make sure
[5:15:47]that where he lived in Palm Beach
[5:15:50]was clear and as I understood it,
[5:15:53]then it was.
[5:15:57]The New Mexico Ranch
[5:15:58]was isolated from other places.
[5:16:00]The island was isolated
[5:16:01]from other places.
[5:16:02]So that wasn't it.
[5:16:03]And New York,
[5:16:04]also from what I understood
[5:16:06]was not a problem.
[5:16:10]Are you aware of whether
[5:16:12]Epstein sexually abused
[5:16:15]young women or girls
[5:16:17]while on work release?
[5:16:21]I was not aware at the time
[5:16:23]that he was doing
[5:16:24]anything like that.
[5:16:25]And as I said,
[5:16:27]had somebody even mentioned
[5:16:28]that to me,
[5:16:28]I would have been surprised by it
[5:16:30]given that there was
[5:16:31]a sheriff's deputy
[5:16:32]sitting at the reception desk
[5:16:34]every time that I went
[5:16:35]to that office.
[5:16:36]And the reception desk was,
[5:16:39]you know, maybe the distance
[5:16:40]from those chairs over there
[5:16:42]from the office
[5:16:43]from where the offices were.
[5:16:45]So that would have surprised me.
[5:16:47]I have since learned
[5:16:49]after his death.
[5:16:50]There were, I think
[5:16:50]it was after his death
[5:16:52]that there were allegations made
[5:16:54]that he was having sex
[5:16:55]with somebody in his office.
[5:17:00]To be clear,
[5:17:02]Mr. Epstein did have privacy
[5:17:04]at this office.
[5:17:06]The office had a door, it did.
[5:17:15]Did you ever see any woman there
[5:17:17]that you later identified
[5:17:19]to be a victim?
[5:17:22]That I later,
[5:17:23]I later identified.
[5:17:24]That was later identified.
[5:17:25]That later played to be a victim?
[5:17:28]Yes.
[5:17:29]Who?
[5:17:30]Is it okay that we say it?
[5:17:34]I believe.
[5:17:41]How many times did you see her though?
[5:17:43]I don't recall.
[5:17:46]Do you recall having
[5:17:47]any conversations related
[5:17:48]to her with Mr. Epstein?
[5:17:51]There?
[5:17:52]At any time?
[5:17:57]Nothing, nothing remarkable.
[5:18:00]No.
[5:18:01]Did Bruce Reinhardt have an office
[5:18:04]at the Florida Science Foundation?
[5:18:07]Bruce Reinhardt did not have an office
[5:18:09]at the Florida Science Foundation.
[5:18:11]We did, however,
[5:18:12]have an office in the building.
[5:18:15]He was an attorney at a
[5:18:18]at a firm called
[5:18:19]I think Atterbury Goldberger.
[5:18:24]I think was the name of the firm.
[5:18:27]Did he do any work for Mr. Epstein?
[5:18:30]I don't recall if he did any work
[5:18:33]for Mr. Epstein, but
[5:18:35]there were,
[5:18:37]I believe he did some representation
[5:18:41]of people who were associated
[5:18:43]with Mr. Epstein
[5:18:44]relating to claims
[5:18:45]that were made against him,
[5:18:47]I think.
[5:18:49]Did you ever have conversations
[5:18:51]with Mr. Epstein
[5:18:51]about his requirement
[5:18:52]to register as a sex offender?
[5:18:55]Yes.
[5:18:56]What were the nature of those conversations?
[5:19:00]Where he had to register,
[5:19:02]where he was going,
[5:19:04]any number of different things.
[5:19:06]Where did he have to register?
[5:19:07]What state?
[5:19:08]He registered in New York.
[5:19:11]He registered in the U.S. Virgin Islands.
[5:19:14]He registered in Florida.
[5:19:20]Went to the registry in New Mexico,
[5:19:22]but was told for some reason
[5:19:24]that registration wasn't required
[5:19:30]based upon something
[5:19:31]with the statute, I think.
[5:19:32]I'm not familiar with it.
[5:19:33]I would assume it was a primary place
[5:19:35]of residence,
[5:19:35]but that's not the case.
[5:19:36]You stay somewhere for longer
[5:19:37]than a certain period of time?
[5:19:39]It does convert it to a primary.
[5:19:41]He never stayed in Mexico very long.
[5:19:46]And in New York,
[5:19:46]he wasn't there long enough, apparently.
[5:19:48]There was a specific statement
[5:19:53]made by whoever was handing the registry
[5:19:56]that he wasn't required to register
[5:20:02]that as a primary residence.
[5:20:05]Are you aware that Leslie Graf
[5:20:09]and Bella Klein facilitated cell phones,
[5:20:12]computers for the survivor's victims
[5:20:17]that you have referred to as assistants?
[5:20:20]The word facilitated.
[5:20:22]Are you aware that they gave them
[5:20:23]cell phones and computers?
[5:20:25]For assistance?
[5:20:28]We now know that they weren't assistants.
[5:20:30]I knew them as assistants.
[5:20:33]Are you aware that Jeffrey Epstein
[5:20:35]would use that to monitor their actions?
[5:20:38]No.
[5:20:39]Would it surprise you to know
[5:20:40]that he monitored their cell phone
[5:20:42]communications to control them?
[5:20:45]Now? After what we know now?
[5:20:49]No, that would not surprise me.
[5:20:54]Are we about done?
[5:20:56]I guess I just have one question.
[5:20:58]It seems like working for him
[5:20:59]was a huge pain in the ass.
[5:21:01]I mean, at some point were you like,
[5:21:03]maybe I should do something else?
[5:21:06]I was compensated very well
[5:21:07]and I worked very hard
[5:21:08]to do the things I did for him.
[5:21:10]And those things I did were
[5:21:12]all business transactional work experiences
[5:21:14]that I wouldn't get necessarily anywhere else.
[5:21:18]I was working with people
[5:21:20]who were billionaires on transactions
[5:21:22]that were, you know,
[5:21:24]really interesting transaction.
[5:21:26]So, yeah, let me finish what I was saying.
[5:21:32]Sir, are you a lawyer?
[5:21:34]Yes, sir.
[5:21:34]Okay, so you know
[5:21:36]that when you become a lawyer,
[5:21:37]you're destined to work long hours
[5:21:40]for demanding people doing difficult things.
[5:21:43]I'm in Congress to see more stuff.
[5:21:45]So I'm sure that's true.
[5:21:47]So given that that was the case,
[5:21:50]one for me, why not?
[5:21:55]I was there.
[5:21:57]And I know, you know,
[5:21:58]you have your own views on that,
[5:21:59]but and I know you want to try
[5:22:03]to hold me accountable.
[5:22:05]I think we all have roles to play.
[5:22:07]I'm just I understand.
[5:22:08]Oh, yeah, I understand that.
[5:22:10]Well, you're following your spin on the evidence,
[5:22:13]not really the evidence.
[5:22:14]Not my spin.
[5:22:15]It is your spin on the evidence
[5:22:16]because the evidence doesn't,
[5:22:17]evidence makes it pretty clear
[5:22:19]that nobody said anything to me
[5:22:20]that I never saw anything.
[5:22:21]Nobody alleged that I saw anything.
[5:22:23]Time will tell.
[5:22:25]All right, I'm glad you guys
[5:22:26]are having a conversation now,
[5:22:27]but I don't think there's questions pending.
[5:22:30]We will go off the record.
[5:22:32]We can go back.
[5:22:49]Mr. Indyk, I wanted to return
[5:22:52]if I could to the topic
[5:22:53]of the conversation you had
[5:22:55]with Jeffrey Epstein two days before his death.
[5:22:58]And for the moment,
[5:22:59]I'm not going to ask you
[5:23:01]to tell me about the substance
[5:23:02]of that conversation,
[5:23:03]but I would like to understand
[5:23:08]some of the details
[5:23:08]surrounding that communication
[5:23:11]to begin with.
[5:23:11]Where did it happen?
[5:23:12]Was this over the phone or in person?
[5:23:14]No, it was at the jail.
[5:23:15]It was at the prison.
[5:23:17]And how long did the conversation last?
[5:23:21]I don't remember how long I was there.
[5:23:24]There were other attorneys
[5:23:25]and a paralegal there at the time.
[5:23:28]So this conversation involved
[5:23:31]more than just you and Mr. Epstein.
[5:23:33]There were other people present.
[5:23:34]Yes.
[5:23:35]Other attorneys.
[5:23:36]Yes.
[5:23:37]And anyone else?
[5:23:39]No, just the attorneys.
[5:23:40]Sorry, I said a paralegal too.
[5:23:42]I believe there was a paralegal.
[5:23:44]Who were the other attorneys?
[5:23:49]These were these were
[5:23:51]might have been Michael Miller
[5:23:53]from Steptoe.
[5:23:56]There may have been
[5:23:56]another Steptoe attorney there.
[5:23:57]And Epstein had some other lawyers
[5:24:01]who were new to the thing.
[5:24:04]I don't know if Marty Weinberg
[5:24:05]was there or not.
[5:24:07]I don't remember them.
[5:24:11]And there were some
[5:24:14]associate level attorneys
[5:24:15]from criminal firms there too.
[5:24:18]Just don't remember who they were.
[5:24:19]Okay.
[5:24:19]And other than the one paralegal
[5:24:21]you mentioned,
[5:24:21]were there any non-attorneys present?
[5:24:23]No.
[5:24:26]And I understood you to say
[5:24:28]that you don't have
[5:24:29]a specific recollection
[5:24:30]of how long you were in the prison.
[5:24:32]And different question.
[5:24:34]Do you have a recollection
[5:24:35]of how long the conversation
[5:24:37]with Mr. Epstein lasted?
[5:24:40]They were just continuing
[5:24:42]conversations about items
[5:24:44]that were of relevance at the time.
[5:24:49]So there was not like a specific
[5:24:52]conversation.
[5:24:56]So we're talking about a meeting.
[5:24:57]Yeah.
[5:24:58]And not to belabor the point
[5:25:00]but the duration of the meeting
[5:25:02]an hour, more or less.
[5:25:05]Maybe an hour, maybe two.
[5:25:07]Okay.
[5:25:07]Possibly.
[5:25:09]And again, without getting into
[5:25:12]the substance of the communications,
[5:25:14]what were the topics
[5:25:15]that were discussed?
[5:25:18]Fail, requirements.
[5:25:27]This is not my thing.
[5:25:29]Some requirements,
[5:25:31]procedural requirements
[5:25:32]with respect to what needed
[5:25:38]to happen there.
[5:25:41]I'm not exactly sure
[5:25:42]what the procedural requirements were
[5:25:43]but they were
[5:25:44]related procedural requirements.
[5:25:50]You say procedural requirements
[5:25:51]were those legal in nature?
[5:25:53]Yes, in connection
[5:25:54]with the criminal case.
[5:26:00]Trying to think what else.
[5:26:04]I believe roles
[5:26:06]of the different attorneys.
[5:26:18]That's what comes to mind.
[5:26:20]And again, just so we're all clear,
[5:26:22]are you asserting
[5:26:25]the attorney-client privilege
[5:26:26]as to the entirety
[5:26:28]of the communications
[5:26:29]that took place during that meeting?
[5:26:32]I think I have to
[5:26:33]because I can't remember
[5:26:36]specifically things that were said.
[5:26:39]So I think the answer is yes,
[5:26:40]I have to.
[5:26:42]And again, just so we're all clear,
[5:26:46]is that based on your participation
[5:26:49]in the legal representation
[5:26:51]of Mr. Epstein
[5:26:52]in his criminal case?
[5:26:55]Yes.
[5:26:56]Any other legal representations
[5:26:58]that come into play
[5:27:00]during that meeting
[5:27:00]or is that the only one?
[5:27:04]I would think during that meeting
[5:27:06]there was probably some kind of
[5:27:10]status of projects
[5:27:12]that were going on.
[5:27:14]So I would imagine that came up as well.
[5:27:28]I appreciate that, Mr. Renday.
[5:27:30]I'm going to shift back
[5:27:32]to yet another topic
[5:27:34]that we discussed earlier.
[5:27:36]And that is the hard drives
[5:27:40]that you learned
[5:27:42]through your communications
[5:27:43]with the Joint Defense Group
[5:27:44]that had ended up
[5:27:46]in the possession
[5:27:47]of private investigators.
[5:27:49]Okay.
[5:27:51]Just some follow-up questions
[5:27:52]to make sure we have
[5:27:53]a complete understanding
[5:27:54]with respect to that issue.
[5:27:59]To begin with,
[5:27:59]I understand from your testimony
[5:28:01]during the previous round
[5:28:02]that the private investigator
[5:28:04]you were referring to
[5:28:05]was the firm Riley Karali.
[5:28:08]Is that correct?
[5:28:09]I think so,
[5:28:10]though I'm not 100% certain,
[5:28:12]but that's a name
[5:28:13]that stands out in my head.
[5:28:14]To your knowledge,
[5:28:15]were there any other
[5:28:16]private investigators involved?
[5:28:19]Based upon what I heard today,
[5:28:23]Roadruck may have been involved.
[5:28:28]To your knowledge,
[5:28:29]how did the private investigators
[5:28:31]obtain those hard drives?
[5:28:33]I don't know.
[5:28:34]I have no personal knowledge.
[5:28:37]And when, to your understanding,
[5:28:39]did they obtain the hard drives?
[5:28:41]Again, I don't know.
[5:28:43]And at whose direction,
[5:28:45]to your understanding,
[5:28:46]did they obtain the hard drives?
[5:28:47]Also, I don't know.
[5:28:50]Anyone else, to your knowledge,
[5:28:52]knew that the investigators
[5:28:53]had the hard drives?
[5:28:55]Other lawyers in the defense group.
[5:28:59]Keep your voice up.
[5:29:00]Sorry, other lawyers
[5:29:01]in the defense group.
[5:29:03]And how many hard drives in total
[5:29:05]did the private investigators have?
[5:29:07]I don't know.
[5:29:09]And to your knowledge,
[5:29:10]were those hard drives
[5:29:11]ever provided to law enforcement?
[5:29:13]I don't know.
[5:29:15]But my sense is that no,
[5:29:19]that they weren't.
[5:29:21]Were the contents of the hard drives
[5:29:24]ever described to you?
[5:29:25]No.
[5:29:27]As you sit here today,
[5:29:28]do you have an understanding
[5:29:29]of what they contain?
[5:29:30]No.
[5:29:34]I also asked you earlier this afternoon
[5:29:38]about the removal of video equipment
[5:29:42]from any Epstein home
[5:29:44]in advance of a search warrant
[5:29:45]being executed.
[5:29:47]I just wanted to be even more specific
[5:29:48]and ask you the same question
[5:29:49]with respect to audio equipment.
[5:29:54]Did you ask?
[5:29:55]Sure.
[5:29:56]So I know the question is clear.
[5:29:57]Yes.
[5:29:59]Do you have any knowledge
[5:30:00]of any audio equipment
[5:30:01]being removed
[5:30:02]from any of Mr. Epstein's properties
[5:30:04]prior to the execution
[5:30:05]of a search warrant?
[5:30:07]I have no personal knowledge of it,
[5:30:09]and I don't have any other knowledge.
[5:30:16]Do you have any personal knowledge
[5:30:20]or other kind of knowledge
[5:30:22]of any other type
[5:30:24]of electronic equipment
[5:30:25]being removed from any residence
[5:30:27]of Jeffrey Epstein
[5:30:28]prior to the execution
[5:30:29]of a search warrant?
[5:30:33]Electronic equipment?
[5:30:35]So we've talked hard drives,
[5:30:36]we've talked video equipment,
[5:30:38]audio equipment, any other?
[5:30:40]You're capable of understanding
[5:30:44]conversations.
[5:30:47]I'm casting a wide net.
[5:30:49]Any type of electronic equipment,
[5:30:51]anything that's electronically operable?
[5:30:53]That could be a printer or anything.
[5:30:56]I don't know.
[5:30:59]I don't have any knowledge of it,
[5:31:01]but I don't want to give a broad,
[5:31:05]I don't know,
[5:31:05]because maybe somebody
[5:31:06]took out a washing machine
[5:31:07]or something.
[5:31:08]I don't know,
[5:31:09]but I don't like answering questions
[5:31:11]for stuff that I don't know
[5:31:13]what the universe is that we're talking about.
[5:31:16]Yes, it's just it's that broad,
[5:31:18]broadly defined category
[5:31:19]that I just described,
[5:31:20]any type of electronic equipment.
[5:31:23]It sounds like your answer
[5:31:24]is you do not have such knowledge.
[5:31:26]Nothing jumps out in my mind.
[5:31:28]And again, I don't know
[5:31:29]how far back we're talking.
[5:31:31]You know, it's like you said before
[5:31:33]that I was talking about within,
[5:31:35]within, you know,
[5:31:37]what period of time also,
[5:31:38]because that's also an issue.
[5:31:40]Let's say within a year
[5:31:41]before the search warrant was executed.
[5:31:45]Nothing jumps in my mind about that.
[5:31:48]And the same question,
[5:31:49]except as to records of any kind.
[5:31:52]Do you have any knowledge,
[5:31:53]whether firsthand or otherwise,
[5:31:55]that any records of any kind
[5:31:57]were removed from any of Mr. Epstein's
[5:31:59]residences prior to the execution
[5:32:01]of a search warrant?
[5:32:02]Nothing to my mind.
[5:32:05]Just not to say that I don't know.
[5:32:07]I have no personal knowledge
[5:32:08]of that.
[5:32:08]I've never heard anything.
[5:32:09]Did you ever hear any other person
[5:32:14]express a belief that any hard drive,
[5:32:18]video equipment, audio equipment,
[5:32:20]or other type of electronic equipment
[5:32:22]had been removed from any
[5:32:23]of Mr. Epstein's properties
[5:32:24]prior to the execution
[5:32:26]of a search warrant?
[5:32:27]Other than the hard drives
[5:32:28]that we've talked about?
[5:32:29]Yes.
[5:32:35]So the hard drives,
[5:32:37]to your knowledge, where are they now?
[5:32:40]I don't, I have no idea.
[5:32:45]Did you come to learn
[5:32:48]which Epstein properties
[5:32:50]specifically the hard drives
[5:32:51]were obtained from?
[5:32:54]My sense, because it was
[5:32:55]the Palm Beach investigation
[5:32:56]that was being talked about,
[5:32:59]that it was Palm Beach.
[5:33:02]Do you have specific knowledge?
[5:33:04]No.
[5:33:11]Did you ever become aware
[5:33:12]or did you ever hear
[5:33:14]that the hard drives
[5:33:15]were withheld from law enforcement?
[5:33:23]I believe in the context
[5:33:24]of the discussions
[5:33:27]with the U.S. Attorney's Office,
[5:33:29]there were conversations
[5:33:31]about hard drives
[5:33:34]and the U.S. Attorney's Office
[5:33:35]not having those hard drives.
[5:33:37]The U.S. Attorney's Office
[5:33:39]in Florida?
[5:33:39]In Florida.
[5:33:42]And?
[5:33:42]I believe, I'm not 100% certain,
[5:33:45]but I believe that's,
[5:33:46]I believe that's what I recall.
[5:33:50]And when you say
[5:33:50]the U.S. Attorney's Office
[5:33:51]did not have the hard drives,
[5:33:54]was it to your understanding
[5:33:55]their expectation
[5:33:56]that they should have received them?
[5:33:58]No, there was a,
[5:33:59]there was some discussion
[5:34:00]back and forth
[5:34:01]between the defense counsel
[5:34:02]and them about it.
[5:34:11]Just shifting again
[5:34:13]to the topic of Epstein survivors
[5:34:18]and the allegations
[5:34:21]that they have made
[5:34:22]against Jeffrey Epstein
[5:34:23]and his estate.
[5:34:25]Since Mr. Epstein's death,
[5:34:27]have you had any contact
[5:34:29]with any women
[5:34:30]who have made allegations
[5:34:31]against Jeffrey Epstein?
[5:34:33]Personal contact, no.
[5:34:36]With the exception,
[5:34:38]I was at a couple of mediations
[5:34:42]where those people appeared.
[5:34:46]But beyond that, no.
[5:34:48]Have you instructed
[5:34:50]or engaged anyone else
[5:34:52]to contact any women
[5:34:53]who have made allegations
[5:34:54]concerning Jeffrey Epstein?
[5:34:56]No.
[5:34:59]Have you engaged
[5:35:00]any private investigators
[5:35:02]in connection with allegations
[5:35:03]of sexual abuse by Jeffrey Epstein?
[5:35:08]They don't.
[5:35:09]I have not personally done that.
[5:35:13]And I can't recall
[5:35:14]if one of the civil lawyers
[5:35:17]representing the estate
[5:35:19]may have,
[5:35:21]I remember discussions
[5:35:22]I don't recall
[5:35:23]if they actually did so.
[5:35:25]And do you recall
[5:35:26]which lawyer that is?
[5:35:34]Maybe Bennett Moskowitz's team
[5:35:39]in Troutman?
[5:35:42]Moskowitz's team and-
[5:35:44]Bennett Moskowitz's team
[5:35:45]at Troutman.
[5:35:46]Thank you.
[5:35:49]I think that.
[5:35:50]I think.
[5:35:53]We have multiple attorneys,
[5:35:54]so there's a lot of claims,
[5:35:57]obviously.
[5:35:59]To your knowledge,
[5:36:01]have any private investigators
[5:36:03]working on behalf
[5:36:05]of Jeffrey Epstein
[5:36:06]or his estate themselves
[5:36:09]contacted any survivors?
[5:36:12]I don't think so, no.
[5:36:14]And can we go back
[5:36:14]to the previous question
[5:36:16]you talked about
[5:36:18]private investigators
[5:36:20]after he died, right?
[5:36:22]At any time.
[5:36:23]I believe that-
[5:36:25]just to amend this a little bit-
[5:36:26]I believe that prior to his death
[5:36:29]or maybe just as he died,
[5:36:32]there was a private investigator
[5:36:36]that in connection
[5:36:39]with the civil case
[5:36:40]to find out about the plaintiff
[5:36:43]that was retained.
[5:36:44]I believe I may have had-
[5:36:46]I think I did have communications
[5:36:48]with the private investigator
[5:36:49]about it.
[5:36:50]I think I got communications
[5:36:54]with the private investigator
[5:36:56]about it to do some
[5:36:56]background research.
[5:36:58]Was that private investigator?
[5:36:59]I don't remember the name.
[5:37:01]And you said the engagement
[5:37:02]was to provide background research?
[5:37:04]Yeah.
[5:37:05]What do you know about this person?
[5:37:08]In many instances,
[5:37:09]we don't know about them.
[5:37:14]The co-executive and I,
[5:37:15]in most instances,
[5:37:15]we don't know these people.
[5:37:17]What do you say these people
[5:37:18]are you talking about?
[5:37:18]The plaintiffs?
[5:37:19]The plaintiffs, yes.
[5:37:21]And how did
[5:37:23]this private investigator
[5:37:26]go about conducting
[5:37:27]this background research?
[5:37:28]I don't know.
[5:37:29]I got a report.
[5:37:30]I think they got a report
[5:37:31]at some point.
[5:37:33]And what did the report say?
[5:37:37]I think it's privileged,
[5:37:38]number one,
[5:37:38]but I don't recall
[5:37:40]the top of my head.
[5:37:41]Did the report contain
[5:37:42]any indication that this
[5:37:44]investigator had contacted
[5:37:46]any Epstein survivors
[5:37:47]or plaintiffs?
[5:37:49]No, I don't think
[5:37:51]that they would have done that.
[5:37:54]To your knowledge,
[5:37:55]has either this private
[5:37:56]investigator or any other
[5:37:58]private investigator
[5:37:59]conducted surveillance
[5:38:00]of Epstein survivors
[5:38:02]or plaintiffs?
[5:38:03]I'm trying to remember
[5:38:04]if the one that I'm talking
[5:38:07]about did.
[5:38:14]It's possible.
[5:38:15]It is possible.
[5:38:17]But I don't know for sure.
[5:38:21]To your knowledge,
[5:38:22]have any women
[5:38:23]who have made allegations
[5:38:24]of sexual abuse
[5:38:25]by Jeffrey Epstein
[5:38:26]been threatened?
[5:38:28]No, in my knowledge, no.
[5:38:30]To your knowledge,
[5:38:31]have any women
[5:38:32]who have made such allegations
[5:38:33]been pressured in any way
[5:38:35]not to pursue their allegations?
[5:38:37]Not to my knowledge.
[5:38:54]If I could return to
[5:38:56]the topic of an individual
[5:38:58]you were asked about
[5:39:00]several rounds ago,
[5:39:01]and that's Howard Lutnick.
[5:39:02]The question, I believe,
[5:39:05]was whether you ever became
[5:39:06]aware of a relationship
[5:39:07]between Jeffrey Epstein
[5:39:08]and Howard Lutnick.
[5:39:10]And as I understand,
[5:39:12]your answer was
[5:39:13]you did not know
[5:39:13]of such a relationship.
[5:39:14]Is that right?
[5:39:16]Up until recently,
[5:39:18]I had no knowledge
[5:39:19]other than that
[5:39:20]Lutnick was a neighbor.
[5:39:23]I'm just going to quickly
[5:39:24]ask the court reporter
[5:39:25]to mark, as an example,
[5:39:34]an email dated May 28, 2018.
[5:39:54]It is a thread
[5:39:55]between Jeffrey Epstein
[5:39:57]and an individual
[5:39:59]with an email address
[5:40:00]bearing the initials HWL.
[5:40:04]Given that it appears
[5:40:05]to originate
[5:40:06]from Cantor Fitzgerald,
[5:40:07]we believe that
[5:40:08]to be Howard Lutnick.
[5:40:10]The message down below
[5:40:14]from Mr. Epstein
[5:40:17]reads, tell your lawyer
[5:40:18]that Darren, my lawyer,
[5:40:20]will contact him.
[5:40:22]And then the response
[5:40:23]up above from HWL
[5:40:25]meeting is tomorrow morning.
[5:40:28]You are not on this email,
[5:40:29]but do you have any recollection
[5:40:31]of meeting with
[5:40:34]Howard Lutnick's attorney?
[5:40:37]No, I have no
[5:40:39]recollection of meeting
[5:40:40]with Howard Lutnick's attorney at all.
[5:40:43]And I don't have a recollection
[5:40:45]of any instruction
[5:40:45]or contact with Howard Lutnick's lawyer.
[5:40:48]So if he had said this,
[5:40:51]I don't recall him ever saying to me.
[5:40:54]Thank you.
[5:40:56]Thank you.
[5:41:10]Mr. Rendex, thank you.
[5:41:12]Before we go off the record,
[5:41:16]I'm going to note that
[5:41:18]based on your responses
[5:41:20]to my questions
[5:41:21]regarding your conversation
[5:41:22]with Mr. Epstein
[5:41:24]prior to his death,
[5:41:25]we are no longer seeking
[5:41:26]a ruling from the chair
[5:41:27]regarding your meeting
[5:41:29]with Mr. Epstein.
[5:41:31]Thank you.
[5:41:32]Thank you.
[5:41:33]We can go off the record.
[5:41:49]We'll go back on the record.
[5:41:58]During the previous hour,
[5:42:00]we discussed Mr. Epstein's
[5:42:02]registration as a sex offender.
[5:42:04]Did you ever do any work
[5:42:06]in relation to his status
[5:42:08]as a sex offender
[5:42:09]as it related to
[5:42:11]being granted visas to travel?
[5:42:17]I recall there was a request
[5:42:19]at some point to go to Canada.
[5:42:23]And I recall that
[5:42:24]because of his status,
[5:42:26]that was not going to be possible.
[5:42:27]I don't know.
[5:42:28]They actually didn't work on it
[5:42:30]other than to advise
[5:42:32]that it was going to be possible.
[5:42:35]Did Mr. Epstein get
[5:42:37]special privileges to travel
[5:42:40]to the U.S. Virgin Islands
[5:42:41]as a sex offender?
[5:42:43]Special privileges?
[5:42:44]I'm not sure I understand the question.
[5:42:46]Was he able to travel
[5:42:47]to the Virgin Islands?
[5:42:49]The U.S. Virgin Islands?
[5:42:51]He was registered in the U.S.
[5:42:52]Virgin Islands.
[5:42:53]That was his primary residence
[5:42:54]and he was registered
[5:42:55]as a sex offender
[5:42:57]in the U.S. Virgin Islands.
[5:42:59]You mentioned Canada.
[5:43:01]Did Mr. Epstein apply
[5:43:03]for a visa to visit Russia?
[5:43:07]I have no independent
[5:43:11]recollection of this.
[5:43:13]I have since learned that,
[5:43:15]and I forget where,
[5:43:17]that application was made
[5:43:19]that I'm talking about
[5:43:20]very recently.
[5:43:22]And for the record,
[5:43:23]you said you have since become aware,
[5:43:26]are you aware of emails
[5:43:28]involving you
[5:43:29]related to a visa application
[5:43:32]to travel to Russia?
[5:43:33]No.
[5:43:51]Did Epstein ever discuss
[5:43:54]any business that he had
[5:43:56]in Russia with you?
[5:43:57]Generally, I knew they were,
[5:44:02]though I don't know the names,
[5:44:03]but there were people
[5:44:04]that he did business with
[5:44:06]that had Russian relationships.
[5:44:09]Generally, there were people
[5:44:10]that I understood
[5:44:11]that he did business with
[5:44:12]that had some Russian connection.
[5:44:16]Were they affiliated
[5:44:18]with the Russian government?
[5:44:23]I don't think so,
[5:44:24]but I don't know,
[5:44:25]but I don't think so.
[5:44:28]My sense was that
[5:44:28]they were businessmen.
[5:44:32]Over the course of your representation,
[5:44:34]Mr. Epstein,
[5:44:34]did you have signatory authority
[5:44:36]over his personal
[5:44:37]and business accounts?
[5:44:39]Yes.
[5:44:39]Did anyone else
[5:44:41]within Epstein's orbit
[5:44:42]have signatory authority?
[5:44:44]I believe at times
[5:44:46]there were people who did.
[5:44:48]Why were you granted this authority?
[5:44:52]Two reasons that I recall.
[5:44:54]One was to make sure
[5:44:59]that people who were requesting
[5:45:03]money on behalf of Epstein
[5:45:05]had authority to request the amounts.
[5:45:08]So, and I guess
[5:45:09]they didn't want the accounting
[5:45:10]to be the same people
[5:45:14]writing the checks.
[5:45:15]So I had a series of
[5:45:19]my understanding was
[5:45:20]there were these conditions.
[5:45:22]This person,
[5:45:24]and I don't remember who,
[5:45:25]but this person could have had $5,000.
[5:45:27]This household manager
[5:45:28]could have $3,000.
[5:45:33]And so if the request was made,
[5:45:35]they'd have to be
[5:45:36]within that threshold,
[5:45:37]or there had to be some kind of an email
[5:45:41]from Epstein saying,
[5:45:44]pay this or something.
[5:45:46]And so part of my job was to
[5:45:49]is to make sure
[5:45:50]that checks were going out
[5:45:53]or going out within these conditions.
[5:45:56]Did you ever sign off on payments
[5:45:59]to women or young girls for services?
[5:46:04]I recall,
[5:46:05]I think I discussed this earlier,
[5:46:07]Svetlana Pazadeva
[5:46:12]had some kind of a marketing relationship
[5:46:13]with one of the foundations.
[5:46:15]And I remember the foundation
[5:46:18]was writing checks to her
[5:46:20]on a monthly basis.
[5:46:23]And I believe I signed those checks.
[5:46:27]For what reason were checks being sent?
[5:46:29]She was a marketing rep for the foundation.
[5:46:33]Did you ever authorize wires
[5:46:35]to girls in Eastern Europe?
[5:46:41]You have something that you can show me
[5:46:42]because nothing that I recall.
[5:46:47]Do you have anything that I could look at?
[5:46:52]This is a tricky, well, tightrope
[5:46:54]trying to protect victims.
[5:46:56]I understand.
[5:46:57]Anything I show you
[5:46:58]is going to create issues, but yeah.
[5:47:02]Did you ever sign off on,
[5:47:04]actually let me back up,
[5:47:06]as it related to the woman
[5:47:08]you previously mentioned
[5:47:09]in her marketing business,
[5:47:11]did you ever question
[5:47:12]the legitimacy of that marketing business?
[5:47:15]No, she had a resume,
[5:47:18]which was fairly wholesome.
[5:47:19]She had a business degree.
[5:47:21]I think it was a business degree.
[5:47:22]She had a degree.
[5:47:25]And so her role
[5:47:27]was consistent with what was in her degree.
[5:47:32]Did Epstein pay for that degree?
[5:47:35]I don't think so now.
[5:47:38]Generally, again,
[5:47:39]did you ever sign off
[5:47:41]on payments for women's health care visits?
[5:47:45]There's nothing.
[5:47:46]Not that I don't know that I didn't,
[5:47:48]but there's nothing that I recall.
[5:47:51]Did you ever sign off on
[5:47:52]tuition or donations to schools?
[5:47:57]I recall tuition.
[5:48:02]I don't know if I signed off on them or not,
[5:48:05]but I recall it.
[5:48:08]It was, as I explained,
[5:48:10]not unusual for Epstein to get donations
[5:48:13]for employees, for colleagues,
[5:48:16]for associates.
[5:48:21]So it certainly is possible.
[5:48:27]How many bank accounts
[5:48:28]did you manage for Epstein
[5:48:30]and Epstein-related entities?
[5:48:32]They didn't manage bank accounts.
[5:48:33]I wouldn't say I managed any bank accounts.
[5:48:36]That was an accounting function,
[5:48:38]not my function.
[5:48:39]I was a signatory on many accounts.
[5:48:41]I don't know how many.
[5:48:43]Does 140 sound about right?
[5:48:47]Honestly, I don't know.
[5:48:48]And if you're talking about
[5:48:50]at one time, that doesn't sound right.
[5:48:52]If you're talking about over the years
[5:48:54]when banking arrangements were lost
[5:48:55]and then gained and now lost,
[5:48:58]and then new ones are created,
[5:49:01]I think that could be possible.
[5:49:03]Did Mr. Epstein maintain
[5:49:05]any accounts in foreign countries?
[5:49:08]I believe there was in Paris a bank account.
[5:49:12]Maybe more than one.
[5:49:14]Did you have signatory authority
[5:49:16]over those accounts?
[5:49:17]I don't recall if I did or if I didn't.
[5:49:26]Are you aware of whether
[5:49:27]he had any accounts in Switzerland?
[5:49:33]I seem to remember HSBC,
[5:49:37]but I don't know if he had an account
[5:49:38]or that was an account
[5:49:39]of one of his clients.
[5:49:42]But I seem to remember
[5:49:43]there were HSBC accounts.
[5:49:45]I just, I'm not sure.
[5:49:47]Again, my function wasn't
[5:49:50]the accounting department.
[5:49:51]That's not something I've ever done.
[5:49:54]Generally, though, are you aware
[5:49:56]of any accounts in Grand Cayman?
[5:50:01]No.
[5:50:03]I'm not personally aware
[5:50:04]and I don't have any recollection.
[5:50:09]It's been reported that you provided
[5:50:11]cash and log costs for Epstein's
[5:50:13]coverage of doctor visits, rent,
[5:50:15]lingerie from Victoria's Secret,
[5:50:17]and haircuts from luxury salons.
[5:50:19]Is that true?
[5:50:21]Can I have that question again?
[5:50:22]The first part of it.
[5:50:23]Cash and somewhere it said.
[5:50:26]Cash and log costs
[5:50:28]for Epstein's coverage of doctor.
[5:50:30]What's a log cost?
[5:50:34]Let me rephrase the question.
[5:50:37]Well, log costs kept a ledger.
[5:50:43]Let me hear the question.
[5:50:46]It's been reported, Mr. Indyke,
[5:50:48]that you provided cash and logged costs
[5:50:51]for Epstein's coverage of doctor's
[5:50:53]visits, rent, lingerie
[5:50:54]from Victoria's Secret,
[5:50:55]and haircuts from luxury salons.
[5:50:58]Is that true?
[5:50:59]So it's been reported that I did that?
[5:51:02]Correct.
[5:51:03]That's not true.
[5:51:19]It's been reported and alleged
[5:51:21]that in February and March of 2016,
[5:51:23]you authorized approximately 60,000
[5:51:25]in wire transfers to young women
[5:51:27]at foreign beneficiary banks.
[5:51:30]Mr. Indyke, did you initiate these wires?
[5:51:33]I don't know what they're referring to.
[5:51:35]I'm not saying I didn't,
[5:51:36]but I don't know what they're referring to.
[5:51:44]Did you ever initiate wires to foreign
[5:51:47]beneficiary banks for young women?
[5:51:56]Could you tell me a bank?
[5:51:57]Could you tell me something?
[5:51:59]Are there young women?
[5:52:01]And can you tell,
[5:52:02]when you say young women,
[5:52:03]you mean women?
[5:52:04]Are there women that today
[5:52:06]you can identify that you,
[5:52:08]that were recipients of wires
[5:52:09]that you transfer to foreign banks?
[5:52:11]I don't recall anything in particular.
[5:52:18]If you could show me something,
[5:52:19]I could tell you whether or not I did it.
[5:52:22]The victims that you referred to as assistance,
[5:52:24]most of them came from Eastern Europe.
[5:52:25]They were financially incentivized to come here
[5:52:30]and they got wire transfers
[5:52:31]between 2010 and 2013.
[5:52:33]So those, you're not aware of those wire transfers
[5:52:37]to Eastern European banks
[5:52:38]to facilitate the travel of the people
[5:52:41]you now call assistance with your victims?
[5:52:43]Okay, so there's a lot in that question
[5:52:46]and I don't, you're doing it again to me
[5:52:49]and I'm trying to answer your question
[5:52:50]and there's a lot in there
[5:52:52]and I don't know how to answer the question.
[5:52:54]So have you wired money to Eastern Europe?
[5:52:56]I don't believe I've wired money to Eastern Europe.
[5:53:04]Have you wired money to Russia?
[5:53:07]I don't believe so.
[5:53:20]I mean, is it possible over the course
[5:53:22]of however many years
[5:53:23]that something like that happened?
[5:53:25]I guess.
[5:53:26]But unless you show it to me,
[5:53:27]I can't tell you.
[5:53:33]Have you subsequently learned
[5:53:35]that money that was wired
[5:53:37]was used or intended
[5:53:39]to compensate women for sexual services?
[5:53:44]So I've not learned anything like that.
[5:53:47]I've heard allegations here
[5:53:49]and after he died that that happened
[5:53:53]but I don't know that that's true.
[5:53:56]I have no idea.
[5:54:02]As it relates to foreign wires generally,
[5:54:05]did you ever have concerns with the volume
[5:54:07]of wires that were being sent overseas?
[5:54:11]I don't recall doing a volume of foreign wires.
[5:54:17]So I don't recall any concerns.
[5:54:23]Are you sure that these questions
[5:54:25]are directed at me?
[5:54:28]I guess wire transfers
[5:54:29]were not generally something I did.
[5:54:55]Has any bank ever requested
[5:54:57]explanations from you
[5:54:58]for suspicious payments?
[5:55:11]I'm not sure if it was from me
[5:55:13]but I do recall Deutsche Bank
[5:55:15]requesting information about payments
[5:55:18]I don't recall what the subject matter
[5:55:20]of the amount of the payment
[5:55:23]or when the payment was due.
[5:55:29]I believe there are times
[5:55:42]if I am doing a transfer
[5:55:45]that I'll get a request what's this for
[5:55:48]but not because they were suspicious.
[5:55:54]That happens from time to time
[5:55:55]when I do wires for any transaction
[5:55:57]they want to know what that's holding.
[5:55:59]With respect to suspicious transfers
[5:56:04]I don't know that I got one.
[5:56:07]I guess it's possible but I don't think so.
[5:56:15]Do you consider Western Union
[5:56:16]to be a wire transfer?
[5:56:22]I don't know.
[5:56:25]I'll re-ask.
[5:56:26]Have you sent any Western Union
[5:56:28]payments to Eastern Europe or Russia?
[5:56:29]No.
[5:56:34]Reportedly J.P. Morgan
[5:56:36]raised concerns with checks signed by Beller.
[5:56:41]Do you have any recollection
[5:56:43]of J.P. Morgan raising concerns
[5:56:46]to you related to checks signed by Beller?
[5:56:51]No.
[5:57:03]Why did J.P. Morgan
[5:57:07]chase drop Epstein as a client in 2013?
[5:57:10]I don't know.
[5:57:11]I think I said this before
[5:57:12]but I'll say it again.
[5:57:14]When the bank drops you as a client
[5:57:17]or when they dropped him as a client
[5:57:19]we didn't get a reason why
[5:57:20]they don't tell you why.
[5:57:23]There were assumptions made on this end
[5:57:25]that it had to do with his criminal conviction
[5:57:30]but beyond that I did not know why.
[5:57:34]After he was dropped
[5:57:35]what did you do or did you have any role
[5:57:38]in transferring Mr. Epstein's money
[5:57:41]to another financial institution?
[5:57:43]When they opened up new accounts
[5:57:47]I believe I became a signatory of accounts
[5:57:50]and I had to sign documents
[5:57:52]for accounts opening documents
[5:58:00]but the actual transfer of funds
[5:58:02]was not done by me.
[5:58:04]Mr. Epstein maintaining accounts
[5:58:06]at Deutsche Bank thereafter,
[5:58:08]is that right?
[5:58:09]I believe that was what it happened
[5:58:11]after he was removed.
[5:58:13]Yes, sorry.
[5:58:14]Sorry, yes.
[5:58:21]Do you have any recollection
[5:58:23]of Deutsche Bank ever raising
[5:58:24]concerns with the financial activities
[5:58:26]of Mr. Epstein's accounts?
[5:58:30]I received a call from Deutsche Bank once
[5:58:34]asked me about an interaction
[5:58:35]I had at the bank.
[5:58:42]I believe the interaction was relating
[5:58:46]to the fact that I had gone in on one day
[5:58:49]with one of these $7,500 checks
[5:58:52]and told the bank when I was there
[5:58:55]that I thought I would be coming
[5:58:57]in within a day or two
[5:58:59]to withdraw money for my own firm's account
[5:59:02]cash for the petty cash of that firm
[5:59:05]and specifically to be transparent
[5:59:08]told them that if they needed
[5:59:10]to somehow aggregate this
[5:59:11]because the total would be more than 10,000
[5:59:13]I wanted to tell them now
[5:59:15]because I did not want it
[5:59:16]to be considered something wrong.
[5:59:22]And then I got a call
[5:59:24]from one of the client relationship managers
[5:59:26]I don't remember who it was
[5:59:28]asking me about what happened.
[5:59:31]I explained that very thing
[5:59:33]and the client relationship manager
[5:59:35]was satisfied and then
[5:59:36]I didn't hear about it again.
[5:59:40]But for the record what you were inquiring
[5:59:49]why did you make this inquiry?
[5:59:52]We had gotten fired from the bank, right?
[5:59:57]I wanted to make sure that
[5:59:58]I did not do anything
[6:00:00]that would get us fired from another bank.
[6:00:04]So I wanted to be transparent.
[6:00:07]And if there was something
[6:00:07]that had to be done
[6:00:08]I didn't want people to think
[6:00:09]that I was doing something
[6:00:10]that wasn't supposed to do.
[6:00:18]So one was for $7,500
[6:00:20]one was for I think $4,000.
[6:00:22]The total was over 10, right?
[6:00:25]So if that was aggregated
[6:00:27]and they thought I was trying
[6:00:28]to get under 10
[6:00:29]but taking out 10 within the same week
[6:00:32]I didn't want them to think
[6:00:33]that was the case.
[6:00:35]So I told them in advance
[6:00:37]and told them if they had to report it
[6:00:38]they should.
[6:00:40]I didn't know if they had to report it
[6:00:41]but I told them if they do
[6:00:42]they should
[6:00:43]because I didn't want people
[6:00:44]to be suspicious of me.
[6:00:46]That wasn't the only time
[6:00:48]you took $7,500 out, is that right?
[6:00:50]That's correct.
[6:00:51]How many times did you take out
[6:00:52]that specific amount?
[6:00:54]The number has been quoted here
[6:00:55]is like 97 times.
[6:00:57]I don't know if that number is accurate
[6:00:58]but it's possible.
[6:01:01]And remember that limit was a limit
[6:01:02]that the bank imposed.
[6:01:04]That $7,500 amount
[6:01:07]I would have done fewer times
[6:01:09]more money
[6:01:09]because that's what
[6:01:10]the accounting department wanted.
[6:01:11]They wanted money
[6:01:12]in their petty cash safe
[6:01:16]and every couple of weeks
[6:01:17]I would get a request
[6:01:18]we need more money
[6:01:19]for the petty cash safe.
[6:01:29]By doing so were you actively
[6:01:32]trying to avoid complying
[6:01:33]with the Bank Secrecy Act?
[6:01:35]Absolutely not.
[6:01:37]That's just not possible.
[6:01:39]The limits were imposed
[6:01:40]by the bank itself, not by me.
[6:01:42]I want to go back
[6:01:55]to the immigration issue.
[6:01:56]Okay.
[6:01:57]So 2013
[6:02:00]there were assistants
[6:02:03]that we now know are victims
[6:02:06]living at 301 E-66
[6:02:09]or with Mr. Epstein in his house.
[6:02:13]Two of them, one of them Karina
[6:02:17]and then the other both of them
[6:02:24]lived at 301 E-66 Street
[6:02:26]to your knowledge?
[6:02:26]To my knowledge, yes.
[6:02:28]To your knowledge, yes.
[6:02:30]You said that one of them
[6:02:31]lived at his house.
[6:02:32]I understand Karina lived
[6:02:33]at his house.
[6:02:34]I don't believe that's true.
[6:02:36]So you think they both lived at 301?
[6:02:38]Yes, I do.
[6:02:39]And who was a US citizen?
[6:02:42]My understanding was that
[6:02:43]she was a US citizen, yeah.
[6:02:45]And Karina is a Belorussian?
[6:02:47]I think that's right, yes.
[6:02:49]And Mr. Epstein asked you to
[6:02:52]well, those people got married.
[6:02:55]Correct.
[6:02:56]And Mr. Epstein asked you to
[6:02:58]help Arda Biscardi's
[6:03:02]apply for Karina's citizenship?
[6:03:06]That's not true at all.
[6:03:08]They didn't ask me to ask Arda Biscardi.
[6:03:10]Sorry, did you give your voice up?
[6:03:12]Sorry, that's not true.
[6:03:13]Did Mr. Epstein ask for you
[6:03:15]to provide documents
[6:03:16]to the immigration attorney
[6:03:17]that was facilitating
[6:03:18]Karina's citizenship application?
[6:03:21]I believe either
[6:03:23]Karina asked me to provide documents.
[6:03:30]What documents did you provide
[6:03:33]at their request?
[6:03:34]I believe it was a lease.
[6:03:39]Any other?
[6:03:40]All that you remember is a lease?
[6:03:41]That's what I remember.
[6:03:43]Did you ever communicate with
[6:03:44]Mr. Epstein regarding
[6:03:47]the application
[6:03:50]for citizenship for Karina?
[6:03:53]I believe I did, yeah.
[6:03:56]But not at his request?
[6:03:57]You just updated him on it?
[6:04:01]What was the nature of that?
[6:04:03]He was concerned that his employees,
[6:04:05]ostensible employees, were...
[6:04:09]I believe this is some time ago.
[6:04:19]I don't remember.
[6:04:22]I want to be helpful,
[6:04:22]but I don't remember.
[6:04:24]So then four years later,
[6:04:25]did you file for their divorce?
[6:04:27]I didn't file for their divorce, no.
[6:04:30]Did you facilitate...
[6:04:31]Did you connect them
[6:04:32]with people that helped them
[6:04:34]get their citizenship?
[6:04:35]Four years later,
[6:04:36]as I understand it,
[6:04:43]at a divorce attorney
[6:04:44]that filed for the divorce.
[6:04:49]How long do you have to be married
[6:04:51]in order to maintain
[6:04:52]your citizenship after divorce?
[6:04:54]I have no idea.
[6:04:56]It's three years.
[6:04:59]Did you provide documents
[6:05:01]for another couple
[6:05:02]that got married in 2013?
[6:05:06]I believe also a lease.
[6:05:09]Any other...
[6:05:09]Who was that?
[6:05:14]I believe their last name was...
[6:05:15]Okay.
[6:05:16]And one, again,
[6:05:17]one was a U.S. citizen?
[6:05:19]Correct.
[6:05:20]And one was not?
[6:05:21]Correct.
[6:05:24]And again?
[6:05:26]At the request of...
[6:05:27]One of them requested
[6:05:28]for you to file a lease?
[6:05:29]One of them requested
[6:05:30]that I do it, yes.
[6:05:31]Okay.
[6:05:34]I feel like earlier you said
[6:05:35]that you weren't involved
[6:05:36]with 301 East 66th Street,
[6:05:38]substantially.
[6:05:39]Correct.
[6:05:40]You just were a tenant.
[6:05:41]I was a tenant.
[6:05:43]I had an office space there.
[6:05:46]Why wouldn't they go
[6:05:47]to a property manager for that?
[6:05:49]What do you mean?
[6:05:51]If you're not the property manager
[6:05:52]of the building...
[6:05:55]Because Jeffrey had a connection
[6:05:58]with 301.
[6:05:59]Okay, so Jeffrey's...
[6:06:00]Which is how they found the building.
[6:06:03]Okay, so Jeffrey's brother
[6:06:05]owned Osa Properties?
[6:06:06]I believe he was a principal
[6:06:08]at Osa Properties.
[6:06:10]And so?
[6:06:12]And I believe Epstein leased space.
[6:06:15]I just don't know if the space
[6:06:16]that he leased was
[6:06:18]those apartments or not.
[6:06:22]This is very convoluted.
[6:06:25]All right, so you were a tenant
[6:06:27]in 301?
[6:06:28]I was a tenant in 301.
[6:06:30]You were not the property manager?
[6:06:31]Not the property manager.
[6:06:33]Did you control any units
[6:06:35]other than your own?
[6:06:36]No.
[6:06:37]So what role did you have
[6:06:38]in providing a lease for a company
[6:06:40]that your employer didn't own?
[6:06:44]There was a relationship
[6:06:45]between Jeffrey and 301.
[6:06:49]Did you sign the lease
[6:06:50]or did somebody else sign the lease?
[6:06:52]301 signed the lease, I think.
[6:06:55]Did you sign it on behalf of 301
[6:06:56]or did somebody else sign it?
[6:06:58]I don't have that relationship with 301.
[6:07:00]No, I did not sign it.
[6:07:02]Okay, again, this is just confusing
[6:07:03]because you're not the property manager.
[6:07:05]Your employer doesn't own the building.
[6:07:07]What role did you have
[6:07:08]in creating a lease for a building
[6:07:10]that you have no association with?
[6:07:11]Well, I never created the lease.
[6:07:13]I requested the lease.
[6:07:14]I told you I requested the lease.
[6:07:15]Okay, so you requested the lease
[6:07:17]from the property manager?
[6:07:19]From the property manager, yes.
[6:07:21]And the purpose of that
[6:07:22]was to get a lease
[6:07:23]that had two names on instead of one?
[6:07:25]I was requested to get a lease
[6:07:27]with 301 for such.
[6:07:28]By Karina or...
[6:07:32]Karina, right there.
[6:07:34]Did you give it to the women
[6:07:39]or did you give it to Arda Piscardis?
[6:07:42]I don't recall.
[6:07:43]If I would have given it to Arda,
[6:07:45]I was probably asked to give it to her.
[6:07:49]By Mr. Epstein or by the women?
[6:07:51]By the women.
[6:07:54]I'm just going to circle back to the email
[6:07:56]and I wish I had it on me,
[6:07:57]but there's an email
[6:07:59]on the five million documents.
[6:08:01]It says from Epstein to you and Khan
[6:08:04]saying that he's worried that
[6:08:06]Arda Piscardi is going to turn on you.
[6:08:09]What does that mean?
[6:08:11]I have no idea.
[6:08:22]Did Mr. Epstein ask you to apply
[6:08:25]for visas for him or any of his
[6:08:28]people that you refer to as assistants?
[6:08:32]No, I don't think he asked me
[6:08:33]to apply for any visas.
[6:08:35]Not to Japan?
[6:08:37]I don't think so.
[6:08:55]Real quick, you just discussed
[6:08:58]the marriage between Ms. Schuliak
[6:09:01]and the other victim.
[6:09:05]Did either one of them ever approach
[6:09:08]you to ask for assistance
[6:09:12]in obtaining a divorce?
[6:09:14]Yes.
[6:09:15]Did you ever advise either one
[6:09:17]of them to not get a divorce?
[6:09:19]No, I never advised anybody
[6:09:20]not to get a divorce.
[6:09:23]Came to me and said,
[6:09:30]would I help her get a divorce?
[6:09:33]I told her that one,
[6:09:34]I wasn't a matrimonial attorney,
[6:09:36]so that's not something
[6:09:37]I ordinarily did.
[6:09:39]I also expressed concern to her
[6:09:43]based upon my understanding
[6:09:44]that she had just filed
[6:09:46]some kind of an application
[6:09:48]for Karina Schuliak.
[6:09:52]What I knew about divorce in New York
[6:09:54]was that you are either filing
[6:09:56]for something called
[6:09:56]irreconcilable differences
[6:09:58]or abandonment
[6:09:59]or something like that.
[6:10:00]That seemed to me
[6:10:01]that would be inconsistent
[6:10:03]with statements that she likely
[6:10:04]made to the government
[6:10:05]in the application,
[6:10:06]and I expressed concern
[6:10:07]about doing that.
[6:10:09]And portions were about it.
[6:10:11]Yes, that's what I said.
[6:10:14]Now, I just want to briefly
[6:10:16]focus generally.
[6:10:17]Did any victims,
[6:10:20]individuals identified as victims
[6:10:22]ever come to you
[6:10:23]to ask for help as it related
[6:10:25]to being sexually abused
[6:10:27]by Mr. Epstein?
[6:10:28]No.
[6:10:42]On July 6th of 2019,
[6:10:44]Mr. Epstein was arrested
[6:10:46]on federal sex trafficking charges.
[6:10:50]When did you become aware
[6:10:51]of those charges?
[6:10:59]So Epstein was seized
[6:11:01]at the airport.
[6:11:02]I'm not sure if it was Newark
[6:11:04]or Teterboro,
[6:11:05]but he was seized at the airport,
[6:11:06]and at some point after that,
[6:11:08]I forget who told me,
[6:11:09]but I was told that
[6:11:10]that he was arrested.
[6:11:13]And we discussed your role
[6:11:18]during the 2008 prosecution.
[6:11:22]Did you have any role whatsoever
[6:11:24]as it related to his arrest
[6:11:27]in 2019?
[6:11:32]I went to the jail
[6:11:34]a couple of times.
[6:11:36]I understood that
[6:11:41]he needed his criminal
[6:11:42]defense team,
[6:11:44]and I think I contacted them,
[6:11:50]and I think I contacted them
[6:11:53]about it, and I believe
[6:12:04]I had did some kind of research
[6:12:06]or legwork in connection
[6:12:07]with the bail application,
[6:12:13]and then participating
[6:12:17]in meetings with defense counsel.
[6:12:19]During the previous hour,
[6:12:22]I believe the minority
[6:12:23]had asked you if you ever
[6:12:25]had any contact with victims.
[6:12:28]I believe you answered no.
[6:12:30]Is that right?
[6:12:33]I think so, yes.
[6:12:35]When you say contact
[6:12:36]other than assistance, right?
[6:12:37]So for the record,
[6:12:38]you never told victims
[6:12:42]not to contact
[6:12:43]or speak with law enforcement.
[6:12:45]Is that right?
[6:12:48]The answer is yes.
[6:12:49]I never told anybody
[6:12:51]not to speak with law enforcement.
[6:12:54]I remember one or two occasions,
[6:12:56]and I don't know when,
[6:12:57]and I think this was
[6:12:58]in the early investigation
[6:12:59]of the later investigation,
[6:13:01]that there were people
[6:13:05]who were concerned
[6:13:07]that law enforcement
[6:13:08]was calling them,
[6:13:10]and the defense counsel,
[6:13:11]who they didn't know,
[6:13:14]asked me to call them
[6:13:15]and tell them
[6:13:17]that they could have
[6:13:17]a lawyer if they want,
[6:13:19]that they didn't have to speak
[6:13:20]to them if they didn't want,
[6:13:22]but I never told them
[6:13:23]not to speak to one.
[6:13:25]I simply related the statement
[6:13:28]from the defense counsel
[6:13:29]that if they wanted a lawyer,
[6:13:30]they could have one provided.
[6:13:33]We will briefly go off the record.
[6:13:40]We'll go back on the record.
[6:13:44]So I just want to finish
[6:13:45]that answer.
[6:13:46]So I built,
[6:13:48]and it's been a long time now,
[6:13:50]but I believe I would have said
[6:13:51]and did say something
[6:13:53]to the effect that
[6:13:54]you don't have to speak to them
[6:13:55]without a lawyer present,
[6:13:56]and if you want,
[6:13:57]counsel would be provided for you,
[6:14:02]and the reason
[6:14:03]that I was asked to do that
[6:14:04]is that people were
[6:14:05]expressing fear
[6:14:07]about having to talk
[6:14:07]to law enforcement.
[6:14:09]They didn't know,
[6:14:10]they've never done it before
[6:14:11]and it scared them,
[6:14:12]and they wanted to know.
[6:14:14]A quick question.
[6:14:17]Do you know the name
[6:14:18]Ramsey L. Colley?
[6:14:22]No, I don't think so.
[6:14:23]Big allegations that
[6:14:24]I've seen paid him
[6:14:25]to recruit women,
[6:14:27]but if you don't know the name?
[6:14:28]I don't know the name.
[6:14:32]Mr. Rendite,
[6:14:33]do you believe that
[6:14:34]Jeffrey Epstein killed himself?
[6:14:40]It's a tough question to answer.
[6:14:43]The answer is I don't know,
[6:14:45]really.
[6:14:45]At the end of the day,
[6:14:46]I just don't know.
[6:14:48]I could see reason Jeff
[6:14:49]and I could see reason him.
[6:14:52]Do you have concerns
[6:14:53]that he didn't kill himself?
[6:14:57]I really don't know.
[6:14:59]Did he appear suicidal
[6:15:01]when you met with him?
[6:15:02]No.
[6:15:06]Did he ever say
[6:15:07]he was depressed?
[6:15:09]No, it's not something
[6:15:11]he would have said to me.
[6:15:23]What is the 1953 trust?
[6:15:25]It is what's colloquially called
[6:15:28]the pour-over trust from the will.
[6:15:32]It's the trust
[6:15:34]after the will is completely probated
[6:15:36]and all claims are settled.
[6:15:39]If there are assets
[6:15:41]and funds left over,
[6:15:44]they would be transferred over
[6:15:46]from the estate to that trust.
[6:15:53]Why was the 1953 trust created?
[6:15:58]It is to my understanding,
[6:16:00]because I am not
[6:16:02]a trusted state's lawyer per se,
[6:16:04]but to my understanding
[6:16:07]as a generalist,
[6:16:09]many times you,
[6:16:13]because you don't want
[6:16:15]your dispositions to be
[6:16:17]a matter of public speculation,
[6:16:20]you put everything in the estate
[6:16:23]over to a trust,
[6:16:24]which is then administered
[6:16:25]outside probate.
[6:16:28]When did you learn
[6:16:29]that you'd be a co-executor
[6:16:31]of the 1953 trust?
[6:16:37]I'm trying to remember.
[6:16:38]I think the 1952 trust
[6:16:39]was an amendment
[6:16:40]to an existing trust.
[6:16:43]So if you're asking about
[6:16:44]the 1953 trust amendment,
[6:16:47]that would have been
[6:16:49]at some point while he was in jail
[6:16:51]that I was there with him
[6:16:52]and his other attorneys.
[6:16:58]If you're talking about
[6:16:59]the prior trust,
[6:17:02]the name was changed to that trust.
[6:17:04]If in fact I'm remembering correctly,
[6:17:06]it would have been
[6:17:07]when that trust was drafted
[6:17:10]and I was appointed
[6:17:11]as a trustee of that trust.
[6:17:14]What was the discussion
[6:17:15]around how much you would receive
[6:17:16]as a co-executor of the trust?
[6:17:20]As a co-executor?
[6:17:21]There was no discussion.
[6:17:22]There was simply
[6:17:23]this is what it provided.
[6:17:31]So you have no understanding
[6:17:32]of how $50 million was decided?
[6:17:36]I think I tried
[6:17:37]to answer this question before.
[6:17:39]The trust itself,
[6:17:40]the estate document itself
[6:17:44]provides for a relatively,
[6:17:46]it's not small amount,
[6:17:47]but a relatively small amount,
[6:17:49]$250,000 to each
[6:17:52]of the each of the executors.
[6:17:55]Normally a trust,
[6:17:57]an estate of this size
[6:17:58]if it were being probated,
[6:18:00]say for example in New York
[6:18:04]or in Florida
[6:18:06]would as a base amount
[6:18:08]get a large percentage,
[6:18:10]tens of millions
[6:18:11]of the large amount of the estate.
[6:18:15]And if it's more complex
[6:18:16]than it's trading
[6:18:17]and requires more time,
[6:18:19]there would be applications
[6:18:21]for more money
[6:18:21]to be paid for there.
[6:18:24]In this case,
[6:18:24]that wasn't the case.
[6:18:26]There was one payment
[6:18:27]to be made of $250,000
[6:18:29]to each of the executors
[6:18:31]to be made upon completion
[6:18:33]of the probating of the will.
[6:18:35]So as to the why he did,
[6:18:38]what he did and who
[6:18:39]and why he gave money
[6:18:40]to whom he gave money to,
[6:18:42]we never had conversations
[6:18:44]like that with him.
[6:18:46]He did,
[6:18:46]he always did what he did
[6:18:47]for his reasons
[6:18:48]and he never discussed
[6:18:50]his reasons with me.
[6:18:51]What is the current
[6:18:52]remaining value of the estate?
[6:18:54]Gosh, I think the accounting
[6:19:03]has it, is it like a hundred
[6:19:05]and I don't have the number
[6:19:07]but I think it's just north
[6:19:09]of a hundred or so.
[6:19:12]Are you factoring in
[6:19:18]funds that are still due
[6:19:20]from outstanding investments?
[6:19:22]I'm not because I don't know
[6:19:23]what that ultimately
[6:19:24]will look like.
[6:19:26]So the rough math is 170 million
[6:19:28]from the investment
[6:19:31]of our investors.
[6:19:32]Anybody who's ever invested
[6:19:34]in a fund like that
[6:19:36]can tell you that those numbers
[6:19:38]are they're not meaningful
[6:19:39]until they're actually real.
[6:19:41]When does that fund come to?
[6:19:46]The funds I think are a year apart.
[6:19:49]Their initial due date,
[6:19:51]one of them I think two
[6:19:52]was due in 26
[6:19:55]but there is an option
[6:19:58]for the fund manager to extend.
[6:20:03]I think at least two years
[6:20:04]and then even then
[6:20:06]with the consent of the majority
[6:20:07]of the holders could extend it further.
[6:20:09]So right now I don't have
[6:20:11]any specific details
[6:20:13]on when those funds
[6:20:14]will ultimately be realized.
[6:20:16]So the estate is currently valued
[6:20:18]just north of a hundred
[6:20:19]with the potential of 170.
[6:20:20]I appreciate that's unknown
[6:20:23]and the fund allocation
[6:20:26]at the wrap up of all
[6:20:27]of the outstanding claims
[6:20:28]would be a hundred to Karina,
[6:20:30]50 to you and 25 to Khan.
[6:20:32]That's roughly a hundred to her
[6:20:38]except no because
[6:20:39]at the end of the day
[6:20:40]because Karina was the recipient
[6:20:43]of all of the properties
[6:20:44]that were ultimately sold
[6:20:46]to pay off all the claims.
[6:20:49]There's some kind of
[6:20:50]a make-up formula for that.
[6:20:52]They should get more than 100.
[6:20:53]She'll get more than 100.
[6:20:54]So and that's first.
[6:20:57]So that make-up formula
[6:20:58]for all those properties
[6:20:59]gets done first
[6:21:00]and then the rest gets done.
[6:21:03]So you all get paid in order
[6:21:05]or do you strike
[6:21:06]a proportional balance?
[6:21:09]I believe it's a proportional balance
[6:21:11]after the payment of
[6:21:13]the make-up for the properties.
[6:21:15]Okay.
[6:21:16]So first is property make-up
[6:21:18]and then the 150, 25
[6:21:20]is divided proportionally
[6:21:22]based off of available assets.
[6:21:23]This is my understanding.
[6:21:24]And remember you're charged this.
[6:21:27]I know, but I have counsel
[6:21:29]that tells me what to do.
[6:21:30]Okay.
[6:21:30]Just clarify.
[6:21:31]So that's.
[6:21:32]Are there any other
[6:21:34]unknown amounts that are due
[6:21:37]other than the hundreds
[6:21:38]other than the potential
[6:21:39]of 170 from Valor Ventures?
[6:21:45]There are two other funds.
[6:21:50]One of the funds is
[6:21:53]I think some
[6:21:54]or something like that
[6:21:54]sort of partnerships
[6:21:57]that I believe that's
[6:21:58]being sold in them.
[6:22:00]I don't know after taxes
[6:22:02]what the number comes to,
[6:22:03]but it's a.
[6:22:03]Tens or hundreds?
[6:22:04]Ten.
[6:22:05]Less than ten.
[6:22:07]Or maybe it's just over tens.
[6:22:09]But you have to pay for taxes,
[6:22:11]number one.
[6:22:12]And that money's
[6:22:14]in part being used
[6:22:15]to fund the cash requirements
[6:22:17]of the
[6:22:21]plus action settlement.
[6:22:22]You said there's three outstanding claims?
[6:22:24]The third one.
[6:22:26]Or so are there three
[6:22:27]overall outstanding claims?
[6:22:29]Let me say three outstanding claims.
[6:22:31]You're talking about.
[6:22:32]Against the estate
[6:22:32]that would preclude you
[6:22:33]from wrapping it up.
[6:22:35]Well, there's new claims
[6:22:37]that are filed almost daily.
[6:22:38]So, you know, it's certainly
[6:22:41]there were new claims filed
[6:22:42]this past month.
[6:22:43]In addition to this class action,
[6:22:47]I don't know.
[6:22:48]So it could be a while.
[6:22:49]It could be a while.
[6:22:50]I'm, you know.
[6:22:51]And the most you can get,
[6:22:52]you've already got
[6:22:52]you've got paid $250,000
[6:22:54]for the entire thing?
[6:22:55]I haven't gotten paid $250,000.
[6:22:57]That doesn't get paid
[6:22:57]until after the estate is probated.
[6:22:59]How are you paying for attorney's fees
[6:23:01]associated with all this?
[6:23:02]So the attorney's fees
[6:23:03]are paid from the estate
[6:23:04]because this is all.
[6:23:05]OK, it's not forced.
[6:23:06]No.
[6:23:08]That's not fun.
[6:23:11]Well, I think you're saying.
[6:23:13]Are you getting paid hourly
[6:23:14]for services?
[6:23:15]You're talking about my attorney's fee?
[6:23:16]Correct.
[6:23:17]Oh, I'm not getting paid
[6:23:19]from the estate.
[6:23:23]For seven years,
[6:23:24]this has taken up
[6:23:26]thousands of hours of your life.
[6:23:27]Exactly.
[6:23:28]And you have not gotten paid a dollar?
[6:23:30]Not from the estate, no.
[6:23:31]I pay, you know, I had a legal practice
[6:23:34]that I'm trying to work up.
[6:23:35]I have real estate,
[6:23:37]a real estate business
[6:23:38]that I'm trying to get off the ground.
[6:23:43]Now, can we consult on one of
[6:23:44]that's an earlier question?
[6:23:46]I just want to make sure
[6:23:46]we get the record straight on
[6:23:47]on the value of the estate.
[6:23:49]Can we consult for a minute?
[6:23:50]Yeah, let's go off the record.
[6:23:57]We'll go back on the record.
[6:23:59]Thank you.
[6:23:59]Can Mr. Indyk just clarify
[6:24:00]on something that the Congress?
[6:24:02]So when you had asked before
[6:24:04]about the 172 rough value
[6:24:07]of those two funds of the law,
[6:24:10]I wanted to make sure
[6:24:11]that it was clear
[6:24:14]that the 100 something valuation
[6:24:17]of the estate from the last accounting
[6:24:19]includes some valuation of the law.
[6:24:22]So the 172 is not on top of that.
[6:24:25]There was a portion of that 172,
[6:24:27]which is not included in the 100,
[6:24:29]but I don't know what the exact number is,
[6:24:31]but it is not the full 172.
[6:24:37]Does that make sense?
[6:24:38]Could you ballpark it?
[6:24:42]I really don't want to be an actor.
[6:24:43]It's in the accounting, though.
[6:24:44]That's fine.
[6:24:45]I'll look at the account of the USPI.
[6:24:47]Sorry, thank you.
[6:24:47]I don't want to be an actor.
[6:24:49]I appreciate you clarifying.
[6:24:53]Mr. Indyk, I want to run through
[6:24:56]some entities that you may have had a role in.
[6:25:00]First, what is the Southern Trust?
[6:25:05]The Southern Trust or Southern?
[6:25:07]Southern Trust Company.
[6:25:09]Southern Trust Company Inc.
[6:25:11]is a current entity that's owned by the estate,
[6:25:17]and it was the main operating business
[6:25:21]of Epstein before he died.
[6:25:23]Main operating business.
[6:25:25]What was its general purpose?
[6:25:27]It was ultimately going to be
[6:25:32]providing financial and medical
[6:25:34]informatics.
[6:25:36]It was also doing consulting services.
[6:25:40]Who else beside you were affiliated
[6:25:45]with this entity, I would presume, right?
[6:25:48]As an administrative role, I was secretary,
[6:25:50]I believe secretary and the vice president.
[6:25:52]Who else was involved?
[6:25:58]I'm trying to remember at the time,
[6:25:59]but right now, Colin is a treasurer.
[6:26:04]I think I'm president now,
[6:26:09]but at the time, I don't remember
[6:26:12]who had a titular role,
[6:26:16]but the office had multiple employees
[6:26:19]in the U.S. for generalists.
[6:26:21]Who were the beneficiaries of the trust?
[6:26:25]It's not a trust, it's a company.
[6:26:26]Excuse me.
[6:26:28]What is the Butterfly?
[6:26:29]Epstein was the sole stockholder.
[6:26:32]I think it's a stockholder.
[6:26:33]Yeah, sole stockholder of that entity.
[6:26:35]What is the Butterfly Trust?
[6:26:40]Are you familiar with the concept
[6:26:41]of a grant, a grant or retained annuity trust?
[6:26:46]Can you briefly elaborate for the record?
[6:26:49]Again, this is not my specialty,
[6:26:52]but as a generalist, a grant or retained
[6:26:54]annuity trust is a trust that you put
[6:26:59]in an asset that you believe
[6:27:01]has appreciating value,
[6:27:05]and you put in that value,
[6:27:07]and then you take annuities from the trust
[6:27:11]over some period of time.
[6:27:12]Sometimes it's two years, sometimes it's three years,
[6:27:13]sometimes it's five years,
[6:27:15]but the idea that you're taking annuities
[6:27:17]out every year at a certain percentage
[6:27:19]results in the gift to the trust being zero
[6:27:31]because you're getting it back
[6:27:32]every percentage every year,
[6:27:35]and while it's in that trust,
[6:27:38]and assuming it appreciates over the time,
[6:27:41]over the term of that trust,
[6:27:43]the appreciation,
[6:27:48]although there's an income tax on the appreciation,
[6:27:56]the gift of that appreciation to a four-over trust,
[6:28:01]which is the Butterfly Trust,
[6:28:03]so the gift of the appreciation
[6:28:06]of the property that's appreciated.
[6:28:08]If I put in $100 worth of property
[6:28:10]and it turns into $400
[6:28:12]at the end of the term of this trust somehow,
[6:28:16]that appreciation that's left
[6:28:19]after you pay the annuities back,
[6:28:23]that appreciation goes into a trust,
[6:28:26]which is called a pour-over trust,
[6:28:29]and that goes estate tax-free.
[6:28:32]So it's a convention that, as I understand it,
[6:28:37]is used regularly for appreciating assets
[6:28:40]to put those in a new trust
[6:28:44]after they've appreciated in value.
[6:28:47]So the Butterfly Trust was a pour-over trust,
[6:28:49]had the appreciation in it,
[6:28:52]and allowed gifts to be made
[6:28:56]from the Butterfly Trust to be made tax-free.
[6:29:00]It appears that there were three distinct trusts,
[6:29:04]Butterfly appears 2013,
[6:29:08]and then a Caterpillar Trust.
[6:29:11]Are you able to distinguish those three?
[6:29:13]Caterpillar Trust is the grat
[6:29:17]that I just told you about
[6:29:19]that poured into the Butterfly Trust.
[6:29:24]Butterfly Trust 2013 was a pour-over
[6:29:28]from another trust.
[6:29:30]Who were the beneficiaries of these trusts?
[6:29:36]I can't tell you all of the names today.
[6:29:45]I can't list them for you.
[6:29:46]Was Karina Szuliak a beneficiary?
[6:29:51]It's possible.
[6:29:52]Were you a beneficiary?
[6:29:54]Yes.
[6:29:55]Why would you be a beneficiary if you're organizing?
[6:29:59]The same, I wasn't the organizer of the trust,
[6:30:02]but it's the same.
[6:30:05]Unfortunately, the only person who would know that
[6:30:06]would be Jeffrey Epstein.
[6:30:14]I may have got ahead of myself.
[6:30:16]You had mentioned that you couldn't tell the committee
[6:30:19]who these individuals were.
[6:30:21]Is it because you cannot recall all of their names?
[6:30:27]For example, the Butterfly Trust
[6:30:29]the pour-over trust is allowed to be amended
[6:30:33]and from time to time there were amendments to that trust.
[6:30:37]I just don't know what the final iteration looks like
[6:30:39]and I don't remember at this point
[6:30:41]who was initially, who's not initially, et cetera.
[6:30:44]Did these trusts make payment
[6:30:46]to women identified to be victims?
[6:30:53]I believe the trust made payments to women.
[6:30:56]I can't tell you which the women were
[6:31:01]but I cannot tell you that women
[6:31:03]who were later claiming to be victims
[6:31:05]weren't recipients of those payments.
[6:31:07]Did you have any role in determining
[6:31:09]who would be beneficiaries of the trust?
[6:31:12]No, I had no role in determining
[6:31:13]who would be beneficiaries.
[6:31:24]How much did you receive from being a beneficiary?
[6:31:32]In total?
[6:31:33]I'll take it any time.
[6:31:34]Total.
[6:31:38]Trying to remember.
[6:31:45]It's either three or four million over time.
[6:31:52]Have you ever facilitated a charitable contribution
[6:31:56]from an Epstein account or entity
[6:31:58]to a Leon Black-owned account or entity?
[6:32:03]I don't understand what that word
[6:32:05]facilitated means.
[6:32:08]Did you ever have any role in transferring
[6:32:15]or wiring money as a charitable contribution
[6:32:23]from an Epstein account to a Leon Black-owned account?
[6:32:28]No, I don't think so, no.
[6:33:00]What is JEGE Inc.?
[6:33:05]There were two JEGEs.
[6:33:07]One was an Inc., one was an LLC.
[6:33:13]Each of those entities own separate aircraft.
[6:33:16]They don't remember what Inc. owned.
[6:33:21]I think Inc. owned the Boeing aircraft.
[6:33:27]And I think JEGE LLC owned either a G4 or a G5 aircraft.
[6:33:40]Did you have any role in the employment
[6:33:42]of staff for the plane?
[6:33:46]Did I have a role in the employment of staff?
[6:33:49]Did you draft employment agreements
[6:33:52]for staff of the plane?
[6:33:53]No, I didn't draft employment agreements
[6:33:55]for the staff of the plane.
[6:33:59]It was one pilot who was the chief pilot.
[6:34:03]And then there were other, some of the planes
[6:34:05]required two pilots at a time
[6:34:07]because they were so large.
[6:34:10]But they were kind of part of the staff.
[6:34:13]And to the extent a second pilot was employed,
[6:34:17]I wasn't the one to be employed.
[6:34:19]What is the COUQ Foundation?
[6:34:23]COUQ Foundation, I think it's a private foundation.
[6:34:29]It's a corporation.
[6:34:31]You don't remember if it's Delaware or not,
[6:34:33]but I think it might be a Delaware corporation.
[6:34:35]But it's a private foundation,
[6:34:37]the primary kind of idea which was to do,
[6:34:43]to make grants to individual research and scholarship.
[6:34:50]And I think it also did other charitable
[6:34:51]contributions as well.
[6:34:53]Income tax filings from this foundation
[6:34:56]reflect over 200,000 scholarship payments
[6:34:58]at NYU, Columbia, and Hunter College
[6:35:00]between 2001 and 2006.
[6:35:03]Do you know who these scholarships were for?
[6:35:07]I don't realize I'm sitting here today.
[6:35:13]There are also reports that COUQ
[6:35:15]made direct payments of over 30,000 euros
[6:35:19]to women with Eastern European surnames.
[6:35:22]Did you initiate these payments?
[6:35:26]Is there any way to tell me what you're talking about?
[6:35:30]Because it doesn't, as I'm sitting here today,
[6:35:33]I don't have the recollection of that.
[6:35:36]But if you could tell me, if it's possible
[6:35:37]to tell me what payments you're talking about,
[6:35:39]I'd like to answer the question.
[6:35:45]During your time working for Mr. Rapsane,
[6:35:49]do you recall any payments made to women
[6:35:53]with European surnames or Eastern European, excuse me?
[6:36:00]First of all, the idea of an Eastern
[6:36:01]European surname, I'm not sure.
[6:36:04]I'm not exactly, I understand the implication of it,
[6:36:06]but I don't know for sure.
[6:36:09]But putting that aside, there were payments
[6:36:13]for employees made by some of the foundations.
[6:36:20]If you're not in front of me,
[6:36:23]it is possible that this was one of them.
[6:36:25]But it's hard for me to answer that question
[6:36:29]without looking at what it is that you're talking about.
[6:36:33]What is the Gratitude America Foundation?
[6:36:36]Also a private foundation.
[6:36:39]I believe Gratitude America was formed
[6:36:46]to do charitable contributions.
[6:36:52]I'm trying to remember if there was anything
[6:36:56]more specific other than charitable,
[6:36:59]general charitable contributions.
[6:37:04]The name would suggest more,
[6:37:05]but I don't remember there actually being more
[6:37:07]than charitable contribution.
[6:37:09]On November 24th of 2015,
[6:37:11]you sent a letter to BV70 LLC,
[6:37:14]thanking them for their charitable donation
[6:37:16]of 10 million to Gratitude America.
[6:37:18]You signed at Darren Indyke Secretary.
[6:37:21]Are you familiar with BV70 LLC?
[6:37:25]I want to say the answer is I think so.
[6:37:28]I want to say I believe that was a Leon Black entity
[6:37:32]and that Leon Black made a contribution
[6:37:35]to Gratitude America through that entity
[6:37:38]or that entity made a contribution.
[6:37:40]I don't know if it was Leon Black,
[6:37:41]but I know it was associated with it.
[6:37:44]And we've discussed Leon Black throughout
[6:37:46]our questioning today.
[6:37:49]Why would this entity make a charitable contribution
[6:37:54]of 10 million dollars to Gratitude America?
[6:37:59]Whatever discussions were made
[6:38:02]between Leon Black and Jeffrey Epstein
[6:38:04]as to that contribution would have been received.
[6:38:06]Jeffrey Epstein and Leon Black are not something
[6:38:09]that is not something that I was told
[6:38:13]the reason why for just that it was going to happen.
[6:38:16]And then when I received it,
[6:38:17]I was told the acknowledge receipt.
[6:38:26]What is the Maxx Foundation?
[6:38:30]I don't specifically remember
[6:38:34]when earlier it was mentioned the Maxx Foundation,
[6:38:37]it did kind of go our memory
[6:38:38]of there being a foundation for Peter and Maxwell.
[6:38:44]Other than that being the case,
[6:38:46]I don't know much more about it.
[6:38:48]My understanding was that it was a charitable foundation.
[6:38:50]Were you a trustee of the Maxx Foundation?
[6:38:54]Long time ago, but I think I was, yes.
[6:39:02]And what was the purpose of the Maxx Foundation?
[6:39:04]It was a charitable foundation.
[6:39:09]Did Mr. Epstein direct you
[6:39:10]to serve as a trustee of this foundation?
[6:39:13]I believe it was either him or Maxwell
[6:39:15]that had requested me to do this.
[6:39:17]And this was before any information
[6:39:21]about any allegation for me about either of them.
[6:39:25]Were you compensated for your services
[6:39:27]and serving as a trustee?
[6:39:29]No, not separately from whatever compensation
[6:39:34]I received from Epstein.
[6:39:36]Did your relationship with Ms. Maxwell end at some point?
[6:39:43]The relationship such that it was
[6:39:45]was a kind of a professional relationship
[6:39:47]when she no longer worked with Epstein,
[6:39:49]it kind of discontinued.
[6:39:51]When was the last time you talked
[6:39:54]or communicated with Ms. Maxwell?
[6:39:56]I don't remember specifically,
[6:39:58]but as I think I said,
[6:39:59]it was a couple of years before he died.
[6:40:01]What is the L-
[6:40:02]A year or two, I'm not exactly sure.
[6:40:04]What is the L-S-J-E-L-L-C?
[6:40:08]L-S-J-E or L-S-J-E?
[6:40:11]Excuse me, what is L-S-J-E-L-L-C?
[6:40:18]My understanding is that L-S-J-E-L-L-C
[6:40:23]was the operating entity,
[6:40:26]ultimately became the operating entity
[6:40:28]for Little St. James,
[6:40:30]the island in the U.S. Virgin Islands
[6:40:31]owned by Mr. Epstein.
[6:40:32]Did L-S-J-E make payments to women
[6:40:36]identified as victims?
[6:40:38]I don't know.
[6:40:38]I wouldn't have done payroll for L-S-J-E.
[6:40:41]L-S-J-E was actually called L-S-
[6:40:44]It was L-S-J-E stands for
[6:40:46]Little St. James Employee or Employment LLC.
[6:40:50]So to the extent it was making payments,
[6:40:54]it was to my understanding
[6:40:56]was making payments to people
[6:40:57]who were employed doing work
[6:40:59]on Little St. James.
[6:41:28]Have you ever been contacted
[6:41:29]by any law enforcement agency
[6:41:31]concerning Jeffrey Epstein
[6:41:32]or Ghislaine Maxwell?
[6:41:37]Just have my memory to make sure
[6:41:40]when I tell you the answer is no.
[6:41:42]I don't think I have.
[6:41:45]For the record,
[6:41:46]is it your testimony?
[6:41:47]Have you ever been interviewed
[6:41:49]by any law enforcement agency
[6:41:50]concerning Jeffrey Epstein
[6:41:52]or Ghislaine Maxwell?
[6:41:53]The answer is no.
[6:41:54]I don't believe I have.
[6:41:56]Have you proactively ever provided
[6:41:59]any information to any law enforcement agency
[6:42:02]concerning Jeffrey Epstein
[6:42:03]or Ghislaine Maxwell?
[6:42:05]Personally, no.
[6:42:07]I know that over the last several months
[6:42:13]the estate has provided information
[6:42:15]to the Justice Department.
[6:42:18]And why did they contact
[6:42:21]the estate recently?
[6:42:25]I don't remember how long ago it was,
[6:42:26]but I remember in the early days
[6:42:35]they had contacted us for information.
[6:42:37]The estate, when I say us,
[6:42:38]I mean the estate for information.
[6:42:41]The contact was through lawyers
[6:42:42]and handled by lawyers, not by me.
[6:42:48]We are at an hour,
[6:42:49]so I have one final question.
[6:42:51]Are you surprised that
[6:42:52]no law enforcement body
[6:42:54]ever reached out to you
[6:42:55]to request information
[6:42:57]as it related to Mr. Epstein
[6:42:58]or Ms. Maxwell?
[6:43:00]Even my role in my role
[6:43:03]as a transactional attorney
[6:43:04]for Mr. Epstein, no.
[6:43:06]We will go off the record.
[6:43:22]Back on the record,
[6:43:24]just one follow-up question from us.
[6:43:28]I think we thought we heard an exchange
[6:43:31]at the end of the previous round
[6:43:32]that suggested that the estate
[6:43:35]has provided DOJ
[6:43:37]with some kind of documents or materials
[6:43:40]somewhat recently,
[6:43:42]as in within the last few months.
[6:43:44]Did we hear that correctly?
[6:43:47]No, and if I did say that,
[6:43:49]that's my recollection
[6:43:50]is towards the beginning of what
[6:43:53]I think was after Epstein died,
[6:43:54]though the DOJ
[6:43:56]and this may have been in connection
[6:43:57]with Maxwell's investigation.
[6:44:00]Got it.
[6:44:01]What you were describing
[6:44:02]would be all the way back
[6:44:03]through the time of Ms. Maxwell.
[6:44:06]Or before even.
[6:44:07]Got it.
[6:44:07]But it did not,
[6:44:08]as far as you can recall,
[6:44:10]post-date Ms. Maxwell's conviction
[6:44:12]and certainly was not
[6:44:13]within the last few months
[6:44:15]or a year, let's say.
[6:44:17]I want to tell you
[6:44:18]with a moderate degree of certainty
[6:44:20]that that's correct.
[6:44:22]I'm not a thousand percent sure.
[6:44:24]As far as you can recall,
[6:44:25]has DOJ either seized
[6:44:29]or requested any materials
[6:44:31]from the estate
[6:44:32]within the last year?
[6:44:36]Not to my recollection, no.
[6:44:39]Okay.
[6:44:39]Do you have any indirect knowledge
[6:44:41]or any reason to be unsure about?
[6:44:43]I'm not being evasive.
[6:44:44]I just don't think so.
[6:44:46]I just don't recall.
[6:44:47]But I didn't think so.
[6:44:48]All right.
[6:44:48]We can go off-record.