220 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 times before coming here to testify today; isn't that right? A. Yes. Q. And at one of those meetings, they showed you the same document that I've been showing you just today to refresh your recollection; isn't that right? A. Was that reference to the logbook looking -- Q. Yes. A. Okay. I don't remember if I did see any from the government on that. I'm drawing a blank. I'm going to go with yes. Q. Well, do you recall them pointing out certain flights to you? A. Yes. Q. To see if you recall them? A. Yes. Q. You do remember that? A. Yes, I do. Yes. Q. And in particular, they pointed out certain flights to you where a female passenger was listed with just her first name. Do you remember that? A. Yes. Q. And that first name was the same as true first name; is that right? A. Correct. Q. And that did not list the passenger's last name, right, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068682

221 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 just her true first name? A. Correct. Yes. Q. And there were three of those flights; is that right? A. As far as that same first name? Q. Yes. A. I'm sure, yeah, there is at least three. Q. There was one in '96, one in '97, and one in '98 they showed you; is that right? A. I don't remember the dates, Mr. Everdell. Q. Do you remember those three flights they showed you? A. Yes. Q. Well, when you met with the government and they showed you these three flights, you couldn't recall whether the woman we are referring to as actually flew on those flights or whether it was somebody else with her same first name? A. Correct. There was a -- the first names were the same, but there were no last names. Q. Now, sitting here today, you still don't know whether the women we're calling flew on any of those flights; isn't that right? A. Not to my knowledge. I mean, it was just -- I couldn't tell one from the other with no last name and 20 -- like you said, 20, 22 years ago. Q. Sure. But there were other people in Epstein's world who had that same true first name; isn't that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068683

222 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. That is correct, yes. Q. For example, Epstein had an assistant with that same first name; isn't that right? A. That is correct. Q. And it was spelled the same way, wasn't it? A. Yes. Q. And you met that person, didn't you? A. Yes, I did. MR. EVERDELL: One moment, your Honor. Your Honor, I apologize for the delay. We have a slight choreography issue that we're dealing with here. I wonder if it might be appropriate if we could take a brief break to deal with it or I can try to do it without the issues of the choreography. MS. COMEY: Your Honor, I think a brief break would help with the choreography. I apologize. THE COURT: You mean to send the jury back to the jury room? MS. COMEY: I think that might be necessary, your Honor. There is an exhibit that needs to be submitted under seal instead of on the screens. THE COURT: Okay. Is it possible to move past this moment and then return to it later? MR. EVERDELL: Your Honor, actually, we can do that. If I'm permitted to fix the problem and then display it later, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068684

223 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 we just have to return to this topic when we can figure this out. As long as I'm able to return to this topic and display things to the jury, that's fine. MS. COMEY: That's fine with me, your Honor. THE COURT: I don't usually tell lawyers what topics -- you're not going to get an asked and answered objection, if that's -- MR. EVERDELL: Yes. Understood, your Honor. THE COURT: So we'll keep going for now. I presume we'll hit the lunch break time and then you can do the choreography. MR. EVERDELL: That's fine, your Honor. We'll do that. We're breaking for lunch when? THE COURT: We have jury lunches at 12:30. If you're otherwise done by then, we'll break early and do that. MR. EVERDELL: Let me see if I can also fix it in the meantime. THE COURT: Mr. Everdell, my deputy reminds me, we have a close room with bathrooms, we can just do a short break for the jury. MR. EVERDELL: Thank you, your Honor. THE COURT: So we'll do a five-minute break, members of the jury. Ms. will take you just to that first room where the restrooms are. Thank you. (Recess) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068685

224 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury not present) THE COURT: Are you set, Mr. Everdell? MR. EVERDELL: Your Honor, I have the copies. What I need to do is insert them into the folders. MS. COMEY: No objection, your Honor. THE COURT: Go ahead, Mr. Everdell. (Pause) Are you ready, Mr. Everdell? MR. EVERDELL: Yes. THE COURT: The procedure will be you will direct the jury to open the folder under the chair and turn to a particular page? MR. EVERDELL: Yes. This one will be done on paper, your Honor. We'll have it on the screen for the Court, the deputy, and the witness, but the jurors will just have it in paper, as will the government, and it will not be displayed to the public. THE COURT: This is choreography to maintain the anonymity of the witnesses who might be permitted to testify under pseudonyms? MS. COMEY: That's exactly right, your Honor. And for that reason, we're going to ask that the two exhibits that the defense is about to offer be offered under seal. THE COURT: I am grateful to both counsel for working that through. Thank you. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068686

225 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. EVERDELL: Yes, your Honor. THE COURT: We'll bring in the jury. (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068687

226 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury present) THE COURT: Members of the jury, I guess it ended up being more a medium break, but you're getting your steps in. So, we are ready to proceed, Mr. Everdell, whenever you're ready. MR. EVERDELL: Thank you, your Honor. BY MR. EVERDELL: Q. Hi again, Mr. A. Hi. Q. So when we broke, we were talking about other people in Epstein's world who had that same first name as we were talking about as ; right? A. Yes. Q. And you said that Epstein had an assistant with that same first name? A. Yes, there was another person with that same name. Q. And spelled the same way? A. Correct. Q. And you met that person? A. Yes. MR. EVERDELL: Now, just for the Court, the deputy, and for the witness, if you could please display LV3A and LV3B, if you can display them together. Q. Do you see those, Mr. A. Yes, I do. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068688

227 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Those are two photographs; is that right? A. That's two photographs. Q. Do you recognize the person in those photographs? A. Yes, I do. Q. Is it the same person in both photographs? A. Yes. Q. And you know that person's name? A. Yes. Q. Without telling us the name, is that the person we've been referring to just now that has the same first name as true first name? A. That's correct, yes, it is. Q. And is that a fair and accurate depiction of that woman? A. Yes. MR. EVERDELL: The defense offers LV3A and LV3B. MS. COMEY: No objection so long as they are sealed, your Honor. MR. EVERDELL: We offer them under seal, your Honor. THE COURT: LV3A and LV3B are admitted under seal consistent with my ruling allowed certain witnesses to testify under pseudonyms to protect their privacy. (Defendant's Exhibits LV3A, LV3B received in evidence) MR. EVERDELL: Thank you, your Honor. Now if I could, with the Court's permission, members of the jury, you can take out the manilla folders that are under your chairs, but please SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068689

228 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 don't open them yet. I would just, with the Court's permission, instruct, especially the jurors who are here on the right side of the jury box, as you look at the photos, because they are under seal, please do it in such a way that you do not display what you're looking at to the members of the gallery. So keep that manilla folder upright so no one could see, if you would. Is that right all right, your Honor? THE COURT: Yes. MR. EVERDELL: Is it okay with the government? MS. COMEY: Yes, your Honor. MR. EVERDELL: If you would open the folders and please look at what's been marked as LV3A and LV3B. When you've had a chance to look, you can return the folders under your chair. And you can take that down. BY MR. EVERDELL: Q. Now, Mr. , you spoke to this person in the photos on a number of occasions; is that right? A. That's correct. Q. In fact, you've spoke to her frequently enough that you even had her phone number in your cellphone; right? A. That's correct. Q. And she traveled frequently with Mr. Epstein on his planes; isn't that right? A. Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068690

229 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. But that woman is not , is she? A. Correct. Q. And you testified earlier that you often didn't meet the passengers on the flights, you were just given their names sometimes before takeoff; right? A. Correct. Q. So, for all you know, there may have been many other people with that same first name as first name who traveled on Epstein's planes? A. True. Q. But the bottom line is, you don't know whether was on any of those three flights where there is a passenger listed with true first name? A. Not the three flights you made reference to. Without the last name, I didn't know which one you were referring to or who it was. Q. Thank you. I want to ask you just about a few more flights. A. Sure. Q. Are you familiar with Prince Andrew, the Duke of York? A. Yes, I am. Q. He is the son of Queen Elizabeth II of England, is he not? A. Yes. Q. Did he ever fly on Epstein's planes? A. Yes, he did. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068691

230 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Do you recall the first time when he flew on the plane? A. I do not. Q. Do you recall someone named Emmy Tayler? A. Yes. Q. She was one of Ghislaine's assistants, wasn't she? A. Yes, she was. Q. She started working for Ghislaine in around 1997 or so; isn't that right? A. I don't know the exact date and I actually didn't remember the name until you brought it up, but that's correct, that's a name from the past. Q. Well, did Emmy Tayler fly on Epstein's planes? A. Yes, she did. Q. Do you recall the first time she flew? A. I do not. Q. Are you familiar with the name Andy Farmer? A. Yes. Q. Do you recall meeting or seeing anyone named Andy Farmer on any flights? A. I don't remember. I know the name, but I think we're going back a long way. Q. Well, to your knowledge, is there any record of anyone named Andy Farmer ever flying on A. I don't know of any record. MR. EVERDELL: Just one moment, your Honor. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068692

231 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Mr. Q. Mr. I'll ask we put up for the Court, the deputy, and LV4 and LV5. , do you see those documents in front of you? A. Yes, I do. Q. Each of those documents has a name on it; isn't that right? A. Yes. MR. EVERDELL: Without objection, I believe we will offer these under seal as LV4 and LV5. MS. COMEY: No objection, as long as they're under seal, your Honor. THE COURT: LV4 and LV5 are admitted to the extent of my rulings that certain witnesses may testify pursuant to pseudonyms in order to protect them. (Defendant's Exhibits LV4, LV5 received in evidence) MR. EVERDELL: At this point, I will ask the members of the jury if the government is okay to pick up their folders one more time. MS. COMEY: No objection, your Honor. THE COURT: Go ahead. MR. EVERDELL: It's the same procedure as before. I'm going to ask you to look at the documents that are underneath the two photographs you've already looked at. Please do not show any of them to the members of the gallery. BY MR. EVERDELL: Q. Mr. , I'm going to start with what's now in evidence SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068693

232 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 as LV4; all right? A. Yes. Q. I'm going to refer to the person there as Kate, okay? A. Okay. Q. Now, LV4 has a true name on that exhibit; is that right? A. Correct. Q. Do you recognize true name, the one that's on the paper of LV4? A. Not really. Q. Do you recall meeting or seeing anyone with true name on any of the flights? A. Not to my knowledge. It's not jumping out at me at all. Q. To your knowledge, there is no record with true name ever flying on any of Epstein's flights? A. I don't recall any of them. Q. Now please look at LV5. That has a full name on it, too, doesn't it? A. Yes. Q. And that person's first name is -; correct? A. Correct. Q. I'm going to refer to that person by her first name, , okay? A. Okay. Q. Do you recognize full name that's on the paper, LV5? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068694

233 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I do not. Q. Do you recall meeting or seeing anyone with full name on any flights? A. I do not. Q. And to your knowledge, there is no record of anyone with full name flying on any of Epstein's flights? A. Not to my knowledge. I don't have any memory at all. Q. Mr. , during your testimony so far, you've mentioned the names of some pretty important people; isn't that fair to say? A. Yes. Q. You already said that former president Bill Clinton flew on some of the flights? A. Yes, he did. Q. And Prince Andrew on some of the flights? A. Yes. Q. Itzhak Perlman, the famous violinist, on some of the flights? A. Yes. Q. Donald Trump, before he was president, also flew on Epstein's flights; isn't that right? A. Yes, he did. Q. He flew on them a number of times; right? A. There was more than once I believe, yes. Q. Sometimes he flew with his family members, too; right: SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068695

LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't know -- I don't remember that. I certainly remember President Trump, but not nearly the other people associated with him. Like I said, if it was something special that would get embranded in my head, I certainly remember the president. Q. Did Robert Kennedy Jr. also fly on his plane? A. I don't remember. I'm not remembering that one. Q. What about Senator John the former astronaut? A. I do remember Senator yes. Q. Former Senator George Mitchell also flew on his plane? A. I do remember. Q. The actors Kevin Spacey and Chris Tucker also flew on his plane? A. I remember them, as well. Q. It's fair to say that these are all pretty high profile people; is that right? A. Correct. Q. And these are people who the public at large would be interested in? A. Sure. Q. And these are all people who are subject to a great deal of media attention and scrutiny; is that right? A. I would assume so, yes. Q. And these are all people who might have legitimate privacy concerns about their goings on? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068696

235 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Correct. Yes. Q. Mr. , I think you were asked as part of your employment to sign a nondisclosure agreement? A. That is correct. Q. Now, when you were asked to sign a nondisclosure agreement, you didn't think it was unusual, did you? A. Not at all. Q. And you certainly didn't take it to mean that you needed to sign it so you wouldn't disclose some kind of illegal activity that was happening on the plane, did you? A. No, of course not. Q. You never saw anything that came close to that; right? A. Correct. Q. You just took it to mean you couldn't write a book about the stuff and the people you were interacting with; right? A. That's correct. Several of my colleagues have signed the same or similar documents in my profession. It's a fairly normal request. Q. So for people who fly private jets, this is a fairly common occurrence? A. That is correct, sure. Q. You have a lot of people, high profile people we just mentioned, who don't want necessarily all their business written about in a book; right? A. Exactly. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068697

236 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. I want to ask you a little bit about where you stayed when you flew to Epstein's residences. All right? A. Okay. Q. Now, I believe your home is near Palm Beach; is that right? A. Yes, it was. Q. So when you flew to Palm Beach, you stayed in your home; right? A. Correct. Q. That's where you're based? A. Correct. Q. When you flew to New York, where did you stay? A. The first part of my employment with Mr. Epstein, I stayed in a hotel, but then later on, I was offered to stay at a building he owned, an apartment building on East 62nd or 66th Street. So I had my own apartment. Q. Was that 301 East 66th Street? A. That is correct. Q. Is that where your partner, copilot Dave Rogers also stayed? A. That's correct. Q. And that's an apartment building? A. That is correct. Q. These are basically corporate apartments? A. Correct. Q. Do you know if Epstein owns that building or rents those SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068698

LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 apartments? A. I don't know the actual business of it. It was to my knowledge that he owned the building. Q. But it's safe to say that you and stayed there on your trips to New York? A. That is correct. Q. Do you know if any other Epstein employees stayed there? A. Yes. Q. So you saw some other employees in the building when you were there; right? A. Correct. Q. For example, you saw in the 66th Street building; is that right? A. That's correct. Q. Do you remember any others you saw there? A. The other person was the one we can't say the name. Q. Okay. So you saw the person whose photographs we just looked at, LV3A and LV3B; right? A. That is correct, yes. Q. You saw that woman in that apartment building? A. That is correct, yes. Q. But you never saw the woman we're referring to as there, did you? A. No, not -- no. Q. All right. Now, for the ranch in New Mexico, your SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068699

238 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 recollection is that Epstein bought the ranch I think sometime in the mid 1990s; is that right? A. That's correct. Q. And when he first bought the property, that large main house that we saw pictures of hadn't been built yet right? A. That's correct. Q. That house was under construction for several years; right? A. That's correct. Q. I think you said it was finished towards the end of the '90s, 2000? A. Correct. Q. So you stayed when you went to the ranch in the mid to late '90s -- well, where did you stay? A. In the early part of the mid '90s, I stayed at the Ranch Central in the bunkhouse rooms, and then later on I built a home on the ranch. Q. I'll ask you about that home in a bit. But for the first part, you stayed in Ranch Central; right? A. Ranch Central, correct. Q. And the ranch hands and the property manager stayed there, as well? A. They stayed in the other buildings associated with Ranch Central, but mostly the Ranch Central lodge or bedrooms were for guests that were on the aircraft. But everybody stayed, really, at Ranch Central, like you said, employees or workers SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068700

239 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 on the ranch that lived there. Q. And you said that Epstein, before the main house was built, stayed in that triple-wide trailer you called the lodge; is that right? A. That's correct. Q. Okay. And you've described it already, I think from the outside, it had a deck; is that right? A. That's correct. Q. And it sort of looks nicer than a trailer does from the outside, it was outfitted that way? A. Correct, yes. Q. About how big was it? A. It was probably around two 2,000 square feet. Q. You went inside it? A. Yes. Q. How many times were you inside that triple-wide trailer? A. Many times. Q. And you described the interior before, but you mentioned a number of bedrooms. Can you just describe a little bit when you walk in the front door where things are situated from the front door entrance, the different rooms? A. Sure. When you walked in the front door, there was immediately to your left, there was a fireplace on the wall. Across from the fireplace, there was a couch that faced the fireplace. You went further in, you're in the middle of the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068701

240 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 living room, which was you made a left turn that brought you into the master bedroom, and if you made a right turn, it took you to the two guest bedrooms on the right side of the trailer. Q. Were the guest bedrooms next to each other or how were they set up? A. There was a bedroom with a bathroom in between. They weren't a Jack and Jill bathroom, but it was still a bedroom, a bathroom in between, and then the other bedroom, but they were on the right side of the trailer. The left side of the trailer was the master bedroom. So it was a split floor plan. Q. But you didn't sleep there; right? A. On occasion I have slept there. Q. Where did you sleep, in one of the guestrooms? A. In one of the guestrooms, but this was a vacation where Mr. Epstein was on the ranch. It was before I built my home, so I was able to spend the time at the lodge. We're going really back far. Q. But eventually, and I think maybe it was in the 2000s or so, Epstein gave you some land; is that right? A. That's correct. Q. Epstein gave you about 40 acres of land from his ranch so that you could build a house; isn't that right? A. That's correct. Q. And he didn't charge you for that land? A. No, he did not. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068702

241 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. And you built a house there? A. I built the house there, yes. Q. So from about 2000 onwards when you flew to the ranch, you'd stay at your home? A. That is correct. Q. Let me ask you briefly about the trips to Epstein's island in the Virgin Islands. You said that's Little St. James Island? A. That's correct. Q. When you flew to the Virgin Islands, you didn't fly directly into little St. James, you said; right? A. No. Q. It doesn't have an airstrip? A. That's correct. Q. You flew to St. Thomas, which is the bigger island right by? A. That's correct. Q. You flew Epstein and his guests to Little St. James in a helicopter? A. Correct. Q. Because you're a trained helicopter pilot? A. That is correct. Q. Where did you stay when you went on the trips to the Virgin Islands? A. Typical hotel, Marriott Resorts that were there. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068703

242 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. So you wouldn't stay in the island residence, you'd stay at St. Thomas? A. I would bring the helicopter back and the crew would stay on St. Thomas in a regular hotel. Q. Now, we saw a number of photographs of Little St. James Island when you were on your direct testimony. Do you remember those? A. Yes. Q. I'm not going to call them up, there were a number of them. But you recall that they had structures on the property in those photographs; right? A. Yes. Q. They had the fully built houses on those photographs; right? A. Yes. Q. Well, when Epstein first bought the property, those houses weren't there; right? A. Some of the buildings were not there. He added buildings, yes. Q. So there was a fair amount of construction to make the island look the way it was in those photographs; right? A. That is correct. Q. And was it about -- was it roughly '97 when he purchased the property? A. It was the late '90s, correct. I don't know the exact SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068704

243 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 year, but you're correct that it was late '90s. Q. And that construction was going on for several years, wasn't it? A. Yes. Q. Including the helipad that was there? A. The helipad moved a couple times, but yeah, it was -- it's kind of easy to do a helipad compared to a building, but yes, the helipad moved around. Q. And Ghislaine supervised all that construction? A. She was involved, absolutely. Q. Separate question, Mr. . You are, I believe, somewhat of a car guy; is that right? A. That's correct. Q. You like cars? A. Yes, I do. Q. You enjoy looking at the latest models? A. I like the classics. Q. You like the classics. Okay. Well, Epstein shared that interest with you; is that right? A. That is correct. Q. He also liked cars? A. Yes. Q. And you and he would discuss cars from time to time; isn't that right? A. Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068705

21.4 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. So he knew about your shared interest, you talked about this a lot? A. That is correct. Q. Now he, I believe, bought some cars that he registered in your name; isn't that right? A. Yes. Q. There was a 2008 Land Rover? A. Yes. Q. There was a 2005 Mercedes Benz CLK? A. Yes. Q. There was a 2005 Jaguar X-Type? A. Yes. Q. These were all kept at his residence in Palm Beach? A. That's correct. Q. And you could use the cars if you wanted to; right? A. If I wanted to, sure. Q. But you didn't consider them your cars? A. No. Q. They were Epstein's cars; right? A. I'm sorry? Q. They were Epstein's cars; right? A. That's correct. Q. And other people at the Palm Beach residence could use them, as well? A. That is correct. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068706

245 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. I believe Epstein also bought a 34-foot JVC powerboat; right? A. Yes. Q. That was registered to you, as well? A. Yes, it was. Q. And you could use it if you wanted to; right? A. That's correct. Q. But it wasn't -- you didn't consider it yours? A. No. Q. Are you also aware of a green Cobra sports car that Epstein had? A. Yes. Q. That one was not registered in your name; right? A. No. Q. Do you know where Epstein got that from? A. Yes. Q. Where did he get it from? A. That came from Mr. Wexler in Columbus, Ohio. Q. Do you know approximately when he got that car? A. It had to been -- I know the car was built in '94, Mr. Wexner held it for — I'm only guessing now — a year or two. So I would think Mr. Epstein got it '96, '97. Q. Do you know when he got rid of it? A. When he got rid of the Cobra? Q. Yeah. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068707

246 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. When was that? A. That was probably it was in my possession for 20 years. Probably around 2000. Q. Thank you. Now, Mr. , in your testimony a little while ago, you said that Epstein gave you 40 acres of land on his ranch in New Mexico so you could build a house; right? A. Yes. Q. I think you would agree that was a pretty generous act on his part; yes? A. Yes. Q. Now, over the years, Epstein also gave you other gifts, as well; isn't that right? A. He gave other -- yes, he gave gifts to me as well as other employees, but yes. Q. Isn't it true that he paid for your children's tuition? A. Yes. Q. You have two daughters; is that right? A. Correct. Q. And he paid for both of their tuitions? A. Correct. Q. So were these private school tuitions when they were in high school? A. Yes. Q. Did he also pay for their college tuitions, as well? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068708

217 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. Did you ever mention this to Ghislaine that Epstein was paying for your daughters' tuitions? A. Yes. Q. So she was aware of this fact, too? A. Absolutely. Q. Did you ask Epstein to pay for your daughters' tuitions? A. He offered it when I first got hired. He said that he would take care of all employees' children's education. So we knew it was pretty much a given. Q. So he offered to do this for all of the employees that you're aware of? A. Yes, correct. Q. You didn't have to ask him for it? A. No. Q. So fair to say that Epstein took an interest in seeing your young daughter succeed; isn't that right? A. That's correct. He believed in higher education. Q. And this was when they were high school aged and college aged; isn't that right? A. Yes, and even younger, grade school. Q. You didn't think there was anything inappropriate about that; right? A. No. Q. It was just a generous act on his part, wasn't it? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068709

248 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Absolutely. Q. And you certainly didn't think that Epstein had any ulterior motive for being generous to your daughters, did you? A. No. Q. And he never asked you for anything in return, did he? A. No. Q. Mr. , are you aware that Epstein had back problems? A. He complained about back problems, yes. Q. Are you aware he often used a heating pad on his back? A. Yes. Q. And are you aware that he often got massages on a regular basis for the same reason? A. Yes, he did. Yes. Q. Now, for example, when you flew to the ranch in New Mexico, the ranch manager would sometimes arrange massages for Epstein; isn't that right? A. It's what I heard from the ranch manager, yes. Q. When the masseuses showed up, they were from a professional saloon in Santa Fe? A. To my knowledge, yes. Q. That was called the Ten Thousand Waves; is that right? A. I know that salon existed and it was famous for massage service, yes. Q. And he received massages from both male and female masseuses; isn't that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068710

249 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I didn't know their sexes, to be honest with you. Q. But to your knowledge, these were all adult professional masseuses? A. Oh, absolutely. Q. Now, Mr. , I want to ask you some questions about where Epstein lived in New York and where Ghislaine lived in New York in the 1990s and the 2000s. A. Okay. Q. Epstein, I think you testified, had two different residences in New York from 1991 two 2005? A. Correct. Q. You visited both of these? A. Yes. Q. One of the reasons you would have gone to his residence was to pick up his luggage or drop it off before or after a flight; right? A. That was typically the main reason, correct. Q. Another reason you said you might have gone there was you had a hobby of installing home video and audio equipment and home theaters; is that right? A. It was home theater. I had been using the word "video equipment," but it was in the '90s when home theaters, the Dolby came out, so everybody was on installing that. So he got -- he was an audio/video person, too, as one on high fidelity. So we were doing home theaters in all the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068711

250 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 residences. Q. This is something you know how to do well? A. Yeah, I had a knack for that, as well. Q. So your mechanics background helps with that? A. Yes, it did. Q. And he liked having sort of the latest audio/video equipment or home theater equipment in his homes? A. Absolutely. Q. So you would occasionally go to all of his homes and install this for him? A. Absolutely, yes. Q. Did this in all his residences, not just New York? A. All of them. Q. Palm Beach, Zorro Ranch, the island? A. That's correct. Q. I want to focus on his residences in New York. Your recollection is that when you first began working for him in '91, he lived on a residence on 69th Street; isn't that right? A. Yes, that was of the first residences I remember. I think I only maybe went there one time. It was very early on obviously, in '91. Q. Was that 34 East 69th Street? A. I know it was 69th Street. I don't remember the number. But you are correct when you say 69th Street. Q. And then sometime after that, maybe in the mid '90s, he SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068712

251 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 moved to a townhouse on 71st Street; right? A. That's correct. Q. That's the one we saw photographs of? A. Correct, that's the 9 East 71st Street. Q. That's right off Fifth Avenue and Central Park? A. Correct. Q. And these are the only two New York residences you recall for Epstein; isn't that right? A. That's correct. Q. That's where you go to pick up his luggage and install video equipment? A. Yes. Q. Now, you also went to Ghislaine's residences during the same period, didn't you? A. Yes. Q. And you went for the same purposes; isn't that right? A. Yes, it was exactly -- yes, for luggage and such. Q. You'd go pick up her luggage from the residence, drop it off there? A. Yes. Q. I think you also did the home theater work for her residences, as well? A. Exactly, yes. Q. Now, Ghislaine had several different residences in New York from 1991 to 2005; isn't that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068713

252 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. And I believe you said you think you went to all of them: A. Yes. Q. So when you first started working for Epstein in '91, she lived in an apartment on -- you said a small apartment on the east side of Manhattan; is that right? A. Yes. Q. Do you recall if that was 20 East 66th Street? A. I don't remember the -- I definitely don't remember the 66th Street because I would have remembered that was the apartment building where we stayed, but I don't remember the address of her very first place. Q. And then at some point in the mid '90s, she moved to a different apartment on the east side on 84th Street? A. I do remember 84th Street, yes. Q. I think you described that before in your testimony? A. Yes. Q. Was that 114 East 84th Street? A. Yes, it was. Q. Do you recall her living for a few years in the late '90s and early 2000s at an apartment on East 81st Street? A. I don't remember 81st Street. I just remember 84th Street. Q. But you do recall that, at some point, maybe in the early 2000s, she moved to a townhouse on East 65th Street? A. I do remember 65th Street, yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068714

253 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. And that was 301 East 65th Street; right? A. No, 301 -- well, 301 was the apartment. 66th Street, that address on 65th, which I want to say it was 116 or 114 East 65th Street -- MR. EVERDELL: One moment, your Honor. Q. Sorry. I'm going to correct myself. It was 116 East 65th Street? A. There you go. That's correct. Q. These are all the New York residences that you recall for Ghislaine; correct? A. Yes, it is. Q. These are all different residences than the residences that Epstein had as we discussed; isn't that right? A. That's correct. Q. And that's where you'd pick up Ghislaine's luggage from; right? A. Yes. Q. You wouldn't pick it up from one of Epstein's residences; right? A. No, not unless I was picking up Jeffrey's luggage, I went to Mr. Epstein's residence. Q. So at all times from 1991 to the 2000s, Ghislaine maintained a separate residence in New York from Mr. Epstein's; is that right? A. Correct. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068715

254 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Mr. , I have one related question about the home theater equipment you installed. You testified that you installed this type of equipment in virtually all of Epstein's residences; right? A. Yes. Q. And you installed it in his residence in Palm Beach, you said; right? A. Yes. Q. So that Palm Beach residence was 358 El Brillo Way in Palm Beach? A. That's correct. Q. Do you recall a time when the El Brillo Way residence was being renovated and Epstein had to move to a rental residence in Palm Beach? A. I do remember that time. Q. And did you install the sort of home theater or any audio equipment in the rental residence? A. I don't recall installing in the rental residence, no. Q. Do you recall where the rental residence was located in Palm Beach? A. I don't know the address. I know approximately where it was, but I don't remember the address. Q. Do you recall when the renovation took place? A. I do not. I'd only be guessing if I said the mid 1990s, but I can't give you an accurate date. Nothing sticks out in SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068716

255 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 my head on that. Q. Best guess is sometime in the mid '90s? A. Mid '90s, yes. Q. Do you recall how long the renovation lasted? A. It was a pretty serious renovation. I'd only be guessing if I said six to eight months. Q. Thank you. MR. EVERDELL: Your Honor should I continue? THE COURT: How much longer do you have? MR. EVERDELL: I'm going to have probably about 20 more minutes. THE COURT: Keep going for now. I'll let you know. Keep going for now. MR. EVERDELL: Understood. Q. Mr. , I want to ask you some questions about your sense of the relationship between Epstein and Ghislaine. Okay? A. Okay. Q. Now, you said you flew on numerous flights both of them; right? A. Yes. Q. And you interacted with them on a regular basis for several years from the 1990s and the 2000s; right? A. Yes. Q. So I think you got a sense of what Ghislaine did for Mr. Epstein; right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068717

256 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. And you testified that she was one of the assistants he had in his office; right? A. Yes. Q. He had lots of assistants; isn't that right? A. That's correct. Q. Now, in the mid '90s through the end of the 1990s, Ghislaine was the assistant who took care of Epstein's properties; isn't that right? A. That's correct. Q. She would make sure the cleaning people came; right? A. Yes. Q. Or the -- well, there were -- I should clarify. There were staff at each one of these residences; right? A. Yes, she took -- yes. Q. And there were house managers at each one of these residences? A. That's correct. Q. So they would take care of, sort of, the day-to-day of each of these residences? A. Exactly. She was in charge of the house managers, making sure that -- Q. Right. A. -- it got taken care of. Q. She supervised the house managers who did the day-to-day? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068718

257 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Correct. Q. If there was something wrong, ultimately it was her responsibility if there was a problem? A. It probably would have been the first phone call to Ms. Maxwell to say we got a problem. Q. If there was a problem with a pool guy not coming and the house manager wasn't dealing with it, Ghislaine would deal with it? A. She would jump on it. Q. Same thing, cleaning people didn't come on time and it wasn't being addressed correctly, Ghislaine had to deal with that? A. Yes. Q. She would manage the household staff as a supervisory over the household manager? A. Correct. Q. She would also oversee repairs and renovations and decorating? A. Yes. Q. Things like that? A. Yes. Q. She was a shopper for Epstein; right? A. She liked to shop. Q. She bought furniture and things like that for the residences? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068719

258 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. That is correct. Q. She bought household items? A. Yes. Q. She decorated the planes, too; right? A. She had a lot put into the airplanes, stocking the airplane on what we carry as far as beverages. Q. We saw photographs of the plane, right, this isn't a matter of hanging a few curtains; right? A. No. Q. This is a pretty big job to outfit one of these planes correctly for their flight? A. Sure. Q. And we also saw these properties; right? They were -- let's talk about the ranch in particular. That was a large piece of property; right? A. A lot of square footage, yes. Q. You said 10,000 acres, roughly? A. Yes. Q. It's a pretty big job to manage those properties; right? A. Yes. Q. In particular, just to call out the ranch for a moment, there were animals on that property; right? A. Yes. Q. There were horses in the stables? A. She loved her horses. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068720

259 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. She took care of the horses; right? A. Yes, she did. Q. She took care of the other animals on the property? A. Yes. Q. This took a lot of Ghislaine's time and energy to do this job, didn't it? A. Yes. Q. And she had to travel to the properties from time to time to do this work; right? A. That's correct. Q. Now, I think in your testimony, you called her Epstein's number 2; right? A. Yes. Q. But from your perspective, she was dealing with the aircraft and the properties; right? A. Yes. Q. She wasn't dealing with Epstein's finances; right? A. No, not the business side. It was Jeffrey household personal. Q. The reason why you call her number 2 is because she was generally overseeing the running of the households; right? A. Correct. Q. But as we said, she wasn't on site at each of these properties every single day running the day-to-day of these households? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068721

260 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. No. Q. There were house managers that did that on a day-to-day basis? A. That's correct. Q. Now, your recollection is that Ghislaine generally worked out of Epstein's offices in New York; isn't that right? A. Yes. Q. And you testified there was a room in Epstein's offices that had about five desks in it that was sort of off to the right of his office? A. That's correct. Q. And that's what you called the personal assistants' room; right? A. There was no official name for it, but it was my best description of who was in that room. Q. And Ghislaine was one of the personal assistants who had a desk in that room? A. That's correct. Q. Now, when you first met Ghislaine in 1991, she seemed to you to be just an employee of Epstein; isn't that right? A. It might in the first introduction. Q. So at that point early on, I'm talking '91, '92 when you first started working, it didn't seem to you like she had a personal relationship with Epstein; right? A. No. I believe when Mr. Epstein introduced her, that he SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068722

261 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 needed help because he was expanding, getting bigger, you know, first time he had his own private jet, that he needed help to handle everything else in his life so that he could focus on his business. And when you start buying homes and properties, he -- Q. I'm sorry to interrupt. A. He knew he was going to get busy. So Ghislaine was his go-to person to handle everything else that was not business-related with his company. Q. So I think you said at some point, though, in the mid '90s, it may have appeared to you that Ghislaine was involved in a personal relationship with Epstein; isn't that right? A. Yeah, I thought they were a couple in the mid '90s. It's just my own take on it. Q. And that was based on your observations of them together at the time and how they interacted with each other? A. Sure. Yes. Q. They made travel plans together, they talked to each other, things like that? A. Yes. Q. But I think you testified that it wasn't totally clear to you that Epstein and Ghislaine had a romantic relationship; right? A. Yeah, I don't know what the definition of a romantic relationship is as opposed to just relationship. To me, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068723

262 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 romantic would mean a more involved relationship. I wasn't aware of anything more than a couple. Q. You never saw them kiss you said; right? A. No. Q. You never saw them hold hands? A. No. Q. Now, it's fair to say, isn't it, that a lot of women were flying on the plane with Epstein in the mid '90s; isn't that right? A. That's correct. Q. It's fair to say that there were plenty of times that Epstein was flying on the plane with these women without Ghislaine? A. There has been times, sure. Q. It appeared to you that these women were adult women? A. Oh, yes. Q. So from your vantage point, whether Ghislaine or any one of these other women was somebody romantically involved or something else, is a little blurry; right? A. Yes. Q. In fact, I think the only person you really considered to be a girlfriend of Epstein was ill ; is that right? A. That's the way she was introduced, as one of Mr. Epstein's original first girlfriends, correct. Q. By the time you started, she was an ex-girlfriend; right: SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068724

263 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Exactly. Q. She was with him in the 1980s? A. Yes, before my time. Q. Now, before she was married, went by ill A. That's correct. Q. She was a former Ms. Sweden? A. That's what I heard. Q. She later married —; is that right? A. That's correct. Q. is a is that right? A. From my understanding, yes. Q. He was one of Epstein's clients; isn't that right? A. I don't know if he was a client. I know he was a friend. Q. But during the period when Ghislaine and Epstein appeared to you to have some sort of a personal relationship, she continued to work for him as an employee; isn't that right? A. Who's that, Ms. Maxwell? Q. Ms. Maxwell, yes. A. Yes. Q. Ghislaine. I'm talking Ghislaine still took care of the houses? A. Yes. Yes. Q. She still shopped for him? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068725

264 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. And you talked to her about the work she did for Epstein, didn't you? A. Yes. Q. She would talk about all the work she was doing on these houses, wouldn't she? A. Yeah, she would tell what's going on and the troubles of decorating and house managers, et cetera, yes. Q. She'd talk about how demanding the job was; right? A. Yes. Q. Now, at some point, it appeared to you that whatever the personal relationship was between Epstein and Ghislaine sort of fizzled out; is that right? A. Yes. Q. And I think that was in about 2000, right, the best of your recollection? A. It was the early 2000s, correct. Q. Now, Ghislaine was still traveling with Epstein in the early 2000s; right? A. Yes. Q. She was still his friend? A. Yes. Q. But by that time, her role in Epstein's life was decreasing, wasn't it? A. I don't know how the decreasing point did, but it just SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068726

265 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 wasn't as personal, it was obviously more business, because in early 2000s is when we went around the world in the Boeing. It was just decreasing. Q. It was all business; right? A. It was all business. Q. And Epstein, at that time, brought in other people to help run his day-to-day business, didn't he? A. Yes. Q. You testified already that appeared around that time in the early 2000s; isn't that right? A. That's correct. Q. She was another one of Epstein's personal assistants? A. Yes. Q. And she became the person or one of the people you spoke to about arranging flights; right? A. That's correct. Q. And do you recall the name A. Yes, I remember that name. Q. She also became one of Epstein's assistants around that same point in the 2000s; isn't that right? A. Yes. Q. And you interacted with her? A. Yeah, not as much, but yeah, I did. It's not like I would with Ms. , but yes. Q. And there were, in fact, many other assistants who appeared SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068727

266 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 over the years in the 2000s, as well, weren't there? A. There was many, yes. Q. Now, you testified that by 2004 or so, to the best of your recollection, Ghislaine was traveling much less frequently on Epstein's planes; isn't that right? A. Yes. Q. She was moving on from Epstein, was she not? A. That's correct. Q. Isn't it true that by 2004, Ghislaine was in a committed relationship with another man? A. Yes. Q. You're familiar with Ted Waitt? A. Yes, I am. Q. He's the cofounder of Gateway Incorporated, the computer company, isn't he? A. That's correct. Q. And Ghislaine was in a relationship with Ted Waitt by 2004, wasn't she? A. I don't know if it was a relationship, but I know she was spending a lot of time with Mr. Waitt, and I think he was completing a boat that she was involved in decorating and building a helipad on it. So it was a different transfer to Mr. Weight. Q. And, in fact, I think Ghislaine introduced you to Waitt's pilots, you guys became friends? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068728

267 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. MR. EVERDELL: Your Honor, this is a convenient stopping point. THE COURT: We'll break here for lunch. Members of the jury, we'll take about a 45-minute lunch break. Enjoy your lunch. Thank you for your continued attention. Witness may step down for the lunch break. (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068729

268 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury not present) (Witness not present) Matters to take up before the break. MS. COMEY: No, your Honor. MR. EVERDELL: Nothing, your Honor. (Recess) (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068730

269 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 AFTERNOON SESSION 1:35 P.M. THE COURT: Matters to take up, counsel? MS. COMEY: Very briefly, your Honor. Some of the courtroom sketch artists have indicated confusion about the order about who they are allowed to draw and not. And so I think we would propose that before we call a witness who cannot be sketched, that that be put on the record. THE COURT: Okay. The only restriction is with respect to the witnesses who I've permitted to testify anonymously. MS. COMEY: That's correct, your Honor. And any sealed exhibits, if someone were to somehow glimpse a sealed exhibit, though I think that's unlikely given the precautions we're taking. THE COURT: Okay. So let's just talk through the protocol, also what the witness will be called using the pseudonym. MS. COMEY: Yes, your Honor. THE COURT: And then I'll swear them in. I would typically say, State your name for the record. I'll just say, I've granted you permission to testify under the pseudonym, fill in the blank. And then turn the witness over for questioning. MS. COMEY: Thank you, your Honor. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068731

270 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: And when I do that, I'll ask the sketch artist not to draw exact likeness of that witness, consistent with my ruling. MS. COMEY: Thank you, your Honor. THE COURT: Okay. Thank you. MS. COMEY: Nothing further. THE COURT: Mr. Everdell? MR. EVERDELL: Nothing from the defense, your Honor. THE COURT: Okay. We can bring the witness back. And Ms. , please bring in the jury. (Jury present) THE COURT: Members of the jury, I hope you had a pleasant lunch. Thank you. THE LAW CLERK: Judge, one second. THE COURT: All right. Thank you. Everyone, I hope you had a good lunch. Thank you for your continued attention and diligence. Mr. Everdell, you may continue with your cross-examination of Mr. Mr. , I remind you you are under oath. THE WITNESS: Yes, ma'am. THE COURT: Go ahead. MR. EVERDELL: Thank you, your Honor. resumed. BY MR. EVERDELL: SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068732

271 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Good afternoon, Mr. A. Good afternoon, Mr. Everdell. Q. I just want to begin with a quick question about the ranch, all right? A. Yes. Q. You testified before that it had a lot of acreage? A. Yes. Q. I think you said roughly 10,000 acres or so? A. 10,000, yes. Q. And there was a lot of open space on that ranch, right? A. That's correct. Q. And one of the things that guests, I think, typically like to do when they were there was to go hiking, right? A. Correct. Yes. Q. Lots of places they could go hiking on the ranch? A. Sure they could, yes. Q. But it's true, isn't it, that the property had a lot of rattlesnakes on it, isn't it? A. Yes, there are several rattlesnakes, yes. Q. Okay. And it was wild country out there. A. Yes. Q. Okay. And so if you were going to hike on this property, you needed proper footwear to go hiking, right? A. Yes. Q. All right. So people would typically wear boots to go SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068733

272 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 hiking? A. That would be a first choice, yes. Q. And that would be recommended for any guest who wanted to go hiking, right? A. Yes. Correct. Q. Okay. Thank you. And I'll just say, I was reminded by the court reporter that we shouldn't talk over each other, so I'll try not to do it and we'll do the same, okay? A. Yes. Q. Thank you. All right. I want to talk to you a bit about your enter actions with Ghislaine. A. Okay. Q. You testified that you first met Ghislaine in about 1991, when you started to work for Mr. Epstein, right? A. That's correct. Q. And Ghislaine would have been about 29 or 30 years or so when you first met her? A. Yes. Q. And Epstein would have been about 37 or 38 at the time; is that right? A. That is right. Q. And you said that Ghislaine flew on numerous flights with you in the 1990s and 2000s, right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068734

273 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. That is correct. Q. And so you knew her and you interacted with her for, it would be, about 15 years, from the early 1990s to the mid 2000s; is that right? A. That is correct. Q. Now, in that whole time period, Ghislaine never appeared to you to be pregnant, did she? A. No, not at all. Q. No one ever told you she was pregnant? A. No, never said that. Q. And you never saw any pictures of her pregnant at any of the residences? A. No, I did not. Q. Now, you had some regular interactions with Ghislaine about your job, right? A. Correct. Q. For example, I believe Ghislaine reviewed your expense reports? A. Yes, that was one detail, yes. Q. So you said you took your expense reports to the New York office maybe about once a week? A. Yeah, whenever I was in New York; correct. Q. And it was Ghislaine's job to review them and approve them, right? A. It was one of her duties, yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068735

274 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. And you also talked to her about scheduling maintenance visits for the planes, right? A. That's correct. Q. And you talked to her about scheduling your own vacations, right? A. Yes. Q. So generally speaking, these were the main interactions you had with Ghislaine regarding employment issues and your job? A. Yes, that was a good description of a lot of the interaction that I had with Ms. Maxwell; correct. Q. But now when Ghislaine had time when she wasn't working, she spent time on other pursuits, right? A. Yes. Q. She became a trained emergency medical technician, didn't she? A. I know she had some medical training, yes. Q. EMT? A. EMT, yes. Q. And she also became a trained helicopter pilot, too? A. Yes, she did. Q. You, yourself, are a trained helicopter pilot, right? A. Yes, I am. Q. And you traveled with Ghislaine when she went to school to become a trained helicopter pilot, right? A. Yes, we traveled frequently together. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068736

275 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Now, Epstein bought his first helicopter, your recollection was, sometime around 1990, 2000; is that right? A. Yeah, '99 to 2000; correct. Yes. Q. So sometime, I believe, in the early 2000s, Ghislaine went to school to become a trained helicopter pilot; is that right? A. Yes, she did. Q. That school was in Pompano Beach, Florida? A. That's correct. Q. Pompano Beach is about an hour or so drive south of Palm Beach, right? A. Yeah, give or take traffic. It could be longer some days; but, yes, it's approximately an hour from Palm Beach to Pompano. Q. And the training sessions that she was taking were about one to three times per week, right? A. That's correct. Q. Each training session lasted about three to four hours, isn't that right? A. Yes, if not longer. Because there's a lot of preparation before you fly, and you're flying for an hour and a half, and then you're still talking about it afterwards, you know, with your instructor, and then your drive home. So it could be a long duration. Q. Right. So each training session was basically a full-day event, wasn't it? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068737

276 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Sure, it was. Q. You had to drive, take the course, talk to the instructor, drive back, all that took about a day, right? A. Yes. Q. So it's fair to say she was away from the Palm Beach residence for the whole day when she was taking these courses, right? A. Yes, good chance, yes. Q. And that helicopter course that she took took about eight months to a year to complete, isn't that right? A. Yes. Q. That course took a fair amount of time, didn't it? A. Took a lot of time, yes. Q. And it goes without saying that at the time, the time that Ghislaine spent at those training sessions in Pompano Beach, she was not at Epstein's residence in Palm Beach, isn't that right? A. That's a correct assumption. Q. Now, you also accompanied Ghislaine to a different helicopter training school in Dallas, Texas; is that right? A. That's correct. Q. Do you remember when that was? A. It was definitely once a year, because we were required to go back for recurrent training. But I don't know the dates, but it was definitely once a year we would go to Dallas for SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068738

LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 training together. Q. And do you remember how long that training lasted on those trips? A. That class, it was typically, I believe, four days; two days of ground school, and two or three days of flight. It could be four to five days, if memory serves. Q. And those training sessions that you're referring to in Dallas, you said, took place every year you recall, right? A. Every year is a requirement for us as pilots. Q. Do you remember when in the year those took place? A. I do not. I remember it being warm, not extremely cold, so I would have to do the summer months; but, you know, the dates escape me without any documentation of when we took the courses. Q. Okay. You guys had fun on those trips, right? A. The training was hard, but we tried to make the best of it. Q. I mean, you occasionally went out to a steak dinner while you were there together? A. Yes, we did. Q. Those were fun events, right? A. Yes. Q. Now, once Ghislaine had her pilot's license, her helicopter pilot's license -- A. Yes. Q. -- she flew Epstein's helicopter; is that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068739

278 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes, she did fly the helicopter. Q. You accompanied her on those flights as the more experienced pilot? A. Yeah, I was going to go in that direction, but yes, I accompanied her as a safety pilot. We flew together. Q. And to your knowledge, that was Epstein's helicopter, not Ghislaine's helicopter, right? A. That's correct. Q. So Ghislaine couldn't call you up and say, I want to fly the helicopter. Have it ready for me. Right? A. She might have; but, no, that wasn't the normal situation. We always had a mission to go on, and it was probably Mr. Epstein driven. But to my knowledge, it was Mr. Epstein's helicopter, yes. Q. To your knowledge, it was Mr. Epstein who controlled whether or not the helicopter was flown or not? A. Correct. Yes. Q. Okay. Now, you said that when Ghislaine did fly the helicopter, you would fly with her as the more experienced pilot? A. Yes. Q. And you got to know her a little bit from that too, from your shared enjoyment of piloting helicopters, right? A. Yes, we talked a lot about aviation. Q. And you remember her as a nice person, right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068740

279 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. And you felt comfortable around her? A. Yes, I did. Q. You never saw Ghislaine do anything or say anything that would lead you to believe she was helping Epstein or anyone else sexually abuse underage girls? A. No, not at all. Q. Now, Mr. , you testified before that you have two girls of your own. A. That is correct. Q. When you started working for Epstein in 1991, how old were your daughters? A. When I started working, well, one was one year old and one was not born yet. Q. And in the mid 1990s, how old would they have been then? A. Mid 1990s. So if you're going to use 1995, so one would be five years old and one would be one year old. Q. Okay. And by the time you get to the mid 2000s, let's call it 2004, just to pick a date, how old would they have been then? A. Okay. It's a math quiz. Let's see. Q. Sorry. A. We're '94. So we're talking 14 11 and 14. Q. So I said 2004; is that right? A. 2004; correct. So one would be 14. One was born in '90, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068741

280 LBUVMAX4 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and the other, '94. So, yeah, 14 and 11-ish. Q. So one was a teenager and one was a preteen? A. That's correct. Q. Now, your daughters occasionally spent time with Ghislaine on the ranch in New Mexico, especially after you built your house there; isn't that right? A. Yes. Q. They loved the animals, I believe, right? A. Yes. Q. Especially the horses? A. Yeah, they are horse lovers. Q. And sometimes Ghislaine would take them riding on the horses at the ranch; isn't that right? A. Yes, my daughters did ride at the ranch on the horses, yes. Q. They did that a fair amount? A. Yes. Q. And you trusted Ghislaine enough that you felt comfortable letting your two young daughters spent time with her; isn't that right? A. That is correct. Q. If you had any inkling whatsoever that Ghislaine was involved in helping Epstein sexually abuse young girls, you wouldn't have let that happen, would you? A. Absolutely not. Q. And if you had any inkling whatsoever that Ghislaine or SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068742

281 LBUVMAX4 - redirect 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Epstein were involved in inappropriate sexual activity with underage girls, what would you have done? A. They would have never seen my daughters. Q. And you would have quit your job? A. Reported it, yes. Q. And you would have quit your job? A. I would have quit my job, that's correct. Q. But you didn't do that, did you? A. No, I didn't. Q. Because nothing you saw or heard in the roughly 30 years you worked for Epstein ever gave you even the slightest hint that anything like that was going on? A. This is absolutely correct. MR. EVERDELL: One moment, your Honor. THE COURT: Okay. (Counsel conferred) MR. EVERDELL: Nothing further, your Honor. THE COURT: All right. Thank you. Ms. Comey. MS. COMEY: Thank you, your Honor. THE COURT: You may redirect. REDIRECT EXAMINATION BY MS. COMEY: Q. Good afternoon. A. Good afternoon, Ms. Comey. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068743

282 LBUVMAX4 - redirect Q. Do you recall being asked questions about your daughters on 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 cross-examination, Mr. A. Yes, I do. Q. When your daughters were 14 years old, did you let them give Mr. Epstein a massage? A. No, I didn't. Q. Do you recall being asked about and another person who has the same first name as A. Yes. Q. Who did you meet first, or the person who is identified in Defense Exhibits LV3A and LV3B? A. The only way to kind of refresh my memory, Ms. Comey, to narrow down that, I could only -- like when I -- when I explained that I first met it was in between the two pilot seats. So I know that was one of Mr. Epstein's smaller aircraft; it wasn't the Boeing. So visually, I can picture the second You have to help me out which one it was. Not the one not the first , but the other I could visualize in the Boeing which would have been sometime 2000 and later. Q. So to the best of your recollection, did you meet the person we're calling in the 1990s? A. I would go with that one, yes, only because with that document of the airplane with, you know, that time frame, I remember the other was in the Boeing, the bigger plane. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068744

283 LBUVMAX4 - redirect 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. I just want to make this clear because I know we're dealing with some pseudonym issues, so just listen to the question please. A. Okay. Q. The person we're calling A. Yes. Q. -- did you meet her in the 1990s, to the best of your recollection? A. Yes. Q. And the person who is depicted in Defense Exhibits LV3A and LV3B, did you meet her in the 2000s, to the best of your recollection? A. Yes. To the best of my recollection, that's a perfect example of how I could remember; so that is correct, yes, Ms. Comey. Q. And do you have that memory because the person depicted in Defense Exhibits LV3A and 3B you remember on the Boeing? A. That's correct. That was my synopsis. THE COURT: Sorry. Just a moment. MR. EVERDELL: Objection. Leading. THE COURT: Overruled. You may finish. You may finish your answer. THE WITNESS: Oh, I'm sorry. A. That is correct, Ms. Comey. It was a way of correlating a name to a date or a person to a date. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068745

284 LBUVMAX4 - redirect 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Do you remember being asked on cross-examination about how old you thought may have been? A. I remember that question, yes. Q. Did you ever meet at summer camp when she was a camper? A. I did not, no. Q. Did you ever pick up at high school? A. No, I did not, ma'am. Q. Did you ever talk with about camp? A. No, I did not. Q. Did you ever talk with about high school? A. No, ma'am. Q. Did you ever meet mother? A. No, I did not. Q. Did you meet other family members? A. I did not. Q. And finally, Mr. do you recall being asked about a Cobra vehicle? A. Yes, ma'am. Q. Do you remember exactly when Mr. Epstein gave you that vehicle? A. Also to clarify, it's a replica Cobra. Probably in the 2000s, 2000; it's been around 20 years since I've had it. I would say 2000, give or take. I don't have an exact date. Q. As you sit here today, do you remember the exact date or is SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068746

285 LBUVMAX4 - redirect 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that an approximation? A. It's just an approximation. I do not know the exact date. MS. COMEY: May I have a moment, your Honor? THE COURT: You may. (Counsel conferred) MS. COMEY: Nothing further. THE COURT: Okay. MR. EVERDELL: Nothing from the defense. THE COURT: All right. Thank you, Mr. You may step down. You are excused. THE WITNESS: Thank you very much, your Honor. THE COURT: Thank you. (Witness excused) THE COURT: Do you have a matter to take up? MR. EVERDELL: Yes, your Honor. You may want to collect the binders and folders before the next witness or at least the defense folders. THE COURT: Okay. Or we leave them there? MR. EVERDELL: There may be another -- it's fine, your Honor. THE COURT: Okay. Jurors, you know this, but don't look at anything unless I direct you to, please. And there may be instances in which I direct you to, but wait for that direction. Ms. Comey, the government may call its next witness. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068747

286 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. MOE: Thank you, your Honor. The government calls THE COURT: The witness testifying under the pseudonym may come forward. called as a witness by the Government, having been duly sworn, testified as follows: THE COURT: Please be seated. This witness will be testifying under the pseudonym Ms. Moe, you may proceed. MS. MOE: Thank you, your Honor. And with respect to the Court's order regarding sketch artists, is that now in effect? THE COURT: It is in effect. I've asked the sketch artist not to sketch the exact likeness -- ordered the sketch artist not to depict the exact likeness. And I will ask the witness to please remove your mask. You are in the Plexiglas box with the HEPA filter. Thank you. MS. MOE: Thank you, your Honor. DIRECT EXAMINATION BY MS. MOE: Q. Good afternoon. A. Good afternoon. Q. Just to be clear, are you testifying under the name SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068748

287 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 today? A. Yes. Q. Leading up to this trial, did you ask to testify under a pseudonym to protect your privacy? A. Yes. Q. I'd ask you to please take a look in the binder in front of you on the witness stand. If you could please turn to what's marked for identification as Government Exhibit 12. Just let me know when you are there please. A. Here. Q. Do you recognize that? A. Yes, I do. THE COURT: I just want to make sure that defense has what they need. MS. MENNINGER: I do. Thank you. THE COURT: Okay. Thank you. Go ahead. Q. What is Government Exhibit 12? A. My birth certificate. MS. MOE: At this time, your Honor, Government Exhibit 12 is in evidence under seal. I'd ask the jurors be permitted to remove their juror binders and turn to Tab 12. THE COURT: Without objection, Ms. Menninger? MS. MENNINGER: No objection. THE COURT: Okay. Jurors, you may open the binder and look at what's been admitted as GX-12, please. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068749

288 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. MOE: Thank you, your Honor. BY MS. MOE: Q. Directing your attention to the top left corner of Government Exhibit 12, where it says "child's name." Do you see that? A. Yes. Q. Without saying that out loud, is that your true name? A. Yes. Q. Is that your date of birth? A. Yes, it is. Q. Thank you. You can close the binder. Now, I want to ask you, did there come a time in your life when you met someone named Jeffrey Epstein? A. Yes. Q. What year was that? A. 1994. Q. Did there come a time in your life when you had sexual contact with Jeffrey Epstein? A. Yes. Q. How old were you when that first happened? A. Fourteen years old. Q. Did that happen once or more than once when you were 14 years old? A. More than once. Q. Was there ever anyone else in the room with you when you SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068750

289 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 had sexual contact with Jeffrey Epstein when you were 14 years old? A. Yes. Q. Who was most frequently in the room when you had sexual contact with Jeffrey Epstein when you were 14 years old? A. Ghislaine Maxwell. Q. I'd like to ask you to take a moment to look around the courtroom, and you can stand up if you need to if you can't see. Do you see Ghislaine Maxwell in the courtroom today? A. Yes. Q. Can you please point to where she's sitting and indicate an article of clothing that she's wearing. A. Right there in the corner wearing a sort of a beige turtleneck. MS. MOE: Your Honor, may the record reflect that the witness has identified the defendant? THE COURT: It may so reflect. Q. Now, I want to ask you more about that in a few moments, but first I want to take a step back. Directing your attention to 1993, where were you living that year? A. Palm Beach, Florida. Q. How old were you in 1993? A. Twelve, going on 13. Q. I'd ask you to take a look at the binder in front of you. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068751

290 LBUVMAX4 - direct If you could please turn to what's been marked for identification only as Government Exhibit 106. Do you recognize that? 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. What is Government Exhibit 106? A. That is a picture of myself. Q. Approximately how old were you when that photograph was taken? A. Thirteen years old. MS. MOE: Your Honor, the government offers Government Exhibit 106 under seal. MS. MENNINGER: No objection. THE COURT: Government Exhibit 106 is admitted under seal, consistent with my ruling, to protect the anonymity of this testifying witness. (Government's Exhibit 106 received in evidence) MS. MOE: Thank you, your Honor. May the jurors turn to Government Exhibit 106, please. THE COURT: Jurors, you may pick up the binder and please turn to GX-106. BY MS. MOE: Q. Who was living with you in your household in 1993 when you were approximately 13 years old? A. My mother and two of my brothers. Q. What type of work did your father do? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068752

291 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. He was a conductor and composer. Q. Directing your attention to the fall of 1993, what happened in your family at that time? A. My father died of leukemia. Q. What was your home life like after your father passed away? A. It was not great. My father's employer had canceled his health insurance without him knowing, and ended up in the hospital and died very suddenly. And basically, my family went into complete bankruptcy and lost everything, and we had to move out of our home. Q. You testified that before he passed away, your father was a composer. Were you involved in the arts growing up? A. Yes. Q. Were your brothers involved in the arts? A. Yes. Q. Did you continue being involved in the arts after your father passed away? A. Yes. Q. Directing your attention to the summer of 1994, what did you do that summer? A. Me and my two brothers, we went to camp for the first time, Interlochen Arts Camp. Q. What is Interlochen Arts Camp? A. It's a camp for children with all kinds of artistic abilities: Music, musical theater, theater, orchestra. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068753

292 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Basically, what we used to joke about being band camp. Q. And where is that located? A. In Interlochen, Michigan, which is northern Michigan. Q. Did anyone else go to camp with you that summer? A. My two brothers. Q. Given your family's financial circumstances at the time, how were you and your brothers able to attend summer camp? A. That first summer, my oldest sister and her husband and her husband's family all pitched in to send us to camp. Q. What grade in school had you just finished when you started at summer camp that year? A. Seventh grade. Q. And when you arrived at camp that summer, how long had it been since your father passed away? A. So the end of October '93, so what is that, nine months? Q. Did there come a time that summer at Interlochen Arts Camp when you met a man and a woman? A. Yes. Q. Where were you when that happened? A. I was in the main campus area where all the students hung out during a break and where all the little cafes were and sort of the gift shop. And I was on a park bench or a picnic bench with my friends from camp. And we were eating ice cream. Q. What do you remember happening next? A. Well, we were sitting around and socializing. And we see SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068754

293 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 this tall thin woman approach us. Well, she was walking with a cute little Yorkie. And the Yorkie came by us and we asked if we could pet the dog. Q. What happened then? A. We started chitchatting, petted the dog. And the rest of my classmates had to go to class. And probably about a minute later, another man came and joined her. Q. Once the man joined her, what happened next? A. We continued chitchat, sort of talked to us. And the rest of my friends, my classmates, left, and I was there by myself. And I sat on the bench still eating my ice cream, and the man sat across from me. Q. Did you have a conversation with that man and that woman? A. Yes, I did. He seemed very interested to know what I thought about the camp, what my favorite classes were, what my least favorite classes, teachers, whatnot, what the experience was like. And proceeded to say that they were big benefactors of this camp; and that they went there every summer; and that they gave different kids scholarships. And so they wanted to really know what a student attending the camp, what their perspective was on it. Q. What, if anything, else did you discuss with them? A. Well, they asked me where I was from. And I said I lived in Palm Beach, Florida. And the man said, What a coincidence, we live there too. What are your parents' names? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068755

294 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 And I said, Well, my father just passed away. But my mother's name is. And he said, I think we know your mom. It's kind of a smaller town. We definitely know her. And I said, You know, my parents were sort of out on the scene, and my father was a musician, and so that would make sense. And he had a newspaper under his arm. And then he put the newspaper on the picnic table and said, Well, what's your mom's name? Gave my mom's name. And he said, Well, what's her phone number? And I just kind of went, Okay. He's asking me for a number, so I gave it to him. And so I gave my mom's, which, you know, at the time was just a landline. Q. How did that conversation end? A. It just sort of ended like, It was, you know, so nice to meet you and I'm going to call your mom. That was it. Q. That man and that woman that you had this conversation with, who were they? A. Jeffrey Epstein and Ghislaine Maxwell. Q. What was your impression of them at that point? A. They seemed very friendly. I thought they were a married couple. They seemed inquisitive. And it made sense, I guess, if they spent time there, that they wanted to know what the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068756

295 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 what the classes were like and what the campus was like. Q. Did you return home to Palm Beach when summer camp was over? A. Yes. Q. Where were you living at that point? A. We were living in a pool house in one of my parents' friend's backyards. Q. Why were you living in a pool house? THE COURT: I'm sorry, Ms. Moe, can you come a little closer to the mic? MS. MOE: Thank you, your Honor. Q. Why were you living in a pool house at the time? A. Because we lost our house and we were homeless. Q. When you were staying there, did you have your own bedroom? A. No. Q. Where did you sleep? A. I slept in a bed with my mom. Q. After you returned home from summer camp in 1994, did you ever hear from those two people that you met at camp? A. Yes. Q. When was the first time you heard from them? A. Well, it was a few days after I had started school again. Q. What grade were you in at that point? A. Eighth grade. Q. What school were you attending? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068757

296 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. Is that a middle school or a high school? A. Middle school. Q. So what happened when you heard from them? What do you remember about that? A. I just remember coming home from school one day, and my mom said, Someone you met at summer camp, someone from their office called me. And I said, Oh, well, I don't -- oh, that's right. I -- I barely remember, because it seemed so long ago. It was maybe four or five or six weeks, but, you know, being that young, it seemed like an eternity. And I said, Yeah, I met and they said that they know you. And my mom said, Well, we've been invited to his house for some tea some afternoon. Q. Did you end up going to his house for tea? A. Yes. Q. What do you recall about going over to the house for tea? A. He sent somebody to come pick us up, like a chauffeur. And we were driven to his house. Q. What was your impression of the house when you first arrived? A. Well, it was enormous. It was not a pool house in the back of someone's yard. It was this giant, like, beach-looking house with a big white fence around it. And these giant gates SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068758

297 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 opened up, and the car pulled in. And it was just this, you know, big beautiful house. Q. Who, if anyone, went with you when you went over for this tea? A. My mother. Q. What happened after you and your mother arrived at the house? A. Well, somebody opened the door for us and let us in the house and escorted us through the house and to Jeffrey's office, which was sort of like an open space. Q. And after you got to the office, what happened next? A. He was on the phone. He got off the phone, stood up, and introduced himself to me and my mother, and then sort of let us outside to the back patio, which had this great big dining table. And there was a big spread of, like, pastries and sandwiches and tea. Q. What happened during the tea with you and your mother and Jeffrey Epstein? A. Well, he was very inquisitive and asked me questions about what I was doing in school, what my interests were, what I wanted to do with my life, and was asking us about our family, asking my mother. It didn't last very long, I would say maybe 30 minutes in total. But he proceeded to say, Well, I like to mentor young students who are artists. And I love music, and I love dance, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068759

298 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and I gave all kinds of scholarships. Q. How did that tea end? A. It ended with him saying, Well, I am I'm very impressed with your daughter and, you know, would love to see her sing next time. Q. After the day that you had this tea, did you ever see Jeffrey Epstein again? A. Yes. Q. In the months after that tea, how frequently did you begin seeing Jeffrey Epstein? A. On average, once or once every week or two. Q. We've been talking about a time period when you were 14 and living in Palm Beach. How old were you when you moved away from Palm Beach? A. When I moved away? 17. Q. I want to focus now first on the first few months that you spent time with Jeffrey Epstein when you were 14. During those first few months, when you spent time with Jeffrey Epstein in Palm Beach, who was typically there with you? A. At Jeffrey's house? Q. Yes. A. I was there by myself. Q. And when you would spend time with Jeffrey Epstein at his house in those first few months, who, if anyone, was there? A. Ghislaine Maxwell. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068760

299 LBUVMAX4 - direct Q. What was your understanding at the time of what the 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 relationship was between Ghislaine Maxwell and Jeffrey Epstein? A. I didn't really understand. They never really shared that information. I just assumed that they were married. And then at a certain point I thought maybe they're best friends. And then I thought, Well, maybe she works for him because he would ask her to do things, make phone calls and things for him. So I guess I was just confused. Q. When you would see Epstein or Maxwell, how were those meetings typically arranged? A. It would be Ghislaine calling the house or Jeffrey's office calling the house, like an assistant or something. Q. Now, you mentioned earlier that you would go to these meetings alone. Just to be clear, did your mother go with you for these meetings? A. No. Q. Why not? A. She wasn't invited. Q. How would you typically get over to the house? A. Jeffrey would send his chauffeur for me. Q. Did you have your driver's license at the time? A. No. Q. Do you recall the driver who would pick you up? A. Yes. I don't remember his name, but he was a sweet Latin-American man. And I know his wife worked at the house as SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068761

300 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 well. Q. When you began spending time with Maxwell and Epstein, what was your impression at the time of how old they were? A. I thought approximately the same age as my parents, my mom. Q. And again, just to be very clear, how old were you when you first started spending time with Maxwell and Epstein? A. 14. Q. What kind of activities would you typically do when you spent time with Maxwell and Epstein during those first few months? A. We would spend time at the house and sort of chitchat and -- or eat in the kitchen or hang out by the pool, sometimes going to the movies. Casual stuff. Q. What, if anything, do you remember about spending time at the pool during those first few months? A. Well, I remember maybe the first time I went to the poolside. And I walked out there. And there was at least four women and Ghislaine all topless, and some of them were naked. Q. What was your reaction to that? A. Well, I was just shocked because I hadn't seen that before. Q. In those first few months when you spent time at the house in Palm Beach, did you have conversations with Maxwell? A. Yes. Q. What kinds of things would she talk about with you? A. Well, we would chitchat, talk about school. She would ask SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068762

301 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 me, you know, what I was up to, and ask me if I had any boyfriend at school. Q. During those first few months, as you were getting to know her, how did Maxwell come across to you? A. She seemed a little bit odd and quirky; but, you know, she would kind of like tease me at times and -- but she was nice. Q. How would you describe your relationship with Maxwell those first few months when you started spending time with her? A. In the first few months, I felt like I think she might have said, I'm sort of like an older sister. Because I at least thought that she was the same age difference maybe as my oldest sister, but I wasn't sure. Q. And at that time, approximately how old was your oldest sister? A. Twenty-seven. I'm not great at math. Sorry. Q. Did there ever come a time when Epstein ever gave you any gifts or money? A. Yes. Q. Approximately when did that first happen? A. It happened probably a few visits in. Q. What do you remember about the first time that that happened? A. I just remember that he said good-bye to me and was going to lead me to the front door. And he put cash in my hand. And I was a polite kid who didn't want to look. And I said, No, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068763

302 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 it's okay. And he said, No, no, no. It's okay. This is for your mother. I know she's having a hard time, so it's not a big deal. Q. After that happened, did he ever give you any money again? A. Yes. Q. How often would that happen? A. Almost every visit. Q. Did there come a point where he began paying for things for you? A. Yes. Q. What kinds of things did he help pay for? A. He helped pay for some voice lessons, he bought me some clothes, things for school. Q. In your conversations with Maxwell, in that first few months that you were spending time with her and with Epstein, did you ever have any conversations with her about boyfriends? A. Yes. Q. What do you remember her telling you? A. I just remember her telling me at one point when I said, No, I don't have a boyfriend, she said, Well, remember when you do, that once you fuck them, you can always fuck them again because they're grandfathered in. Q. What was your reaction to that when she told you that? A. Well, I giggled because I didn't understand what SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068764

LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 "grandfathered" meant, first and foremost. Q. Did there ever come a time when you went shopping with Maxwell and Epstein? A. Yes. Q. Approximately when was that? A. Sometime at the end of 1994 or Q. Did they buy you anything? A. Yes. Q. What did they buy you? A. They bought me some -- some pants and some shoes, like, sort of loafers. I remember some shirts, like, sort of a preppy button-up shirt, like a cashmere sweater. Q. During that trip, did you go shopping for anything else with them? A. Yes, we went to a Victoria's Secret and bought some underwear. Q. What kind of underwear did they buy you? A. It was sort of those, like, white cotton briefs; like, the very sort of, I would say, basic-looking ones that you would, sort of, wear when you're -- when you're younger. Q. During this time in the first few months when you were spending time with Maxwell and Epstein, did they ever tell you anything about their social circle? A. Yes. I mean, from the very beginning there was a lot of bragging about how they were friends with essentially everyone, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068765

?CA LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and they knew everyone. And they would sort of name-drop or sometimes put people on speakerphone whose voices I didn't know and then say, Oh, well, this was so-and-so and so-and-so; and just, you know, say that they were very well-connected and affluent. Q. How did that make you feel at the time? A. I mean, I guess it made me feel slightly intimidated, but it was overwhelming. And also I just -- I didn't know how I was supposed to feel about it. Q. What names do you recall them mentioning to you when they would tell you about their social circle? A. Donald Trump, Bill Clinton, Mike Wallace, people at some that I didn't know. Q. I want to ask you now about the house in Palm Beach where you were spending time with Maxwell and Epstein. Could you please describe for the jury how that house in Palm Beach was decorated. A. It was -- I mean, it was a giant house, and so it had lots of furniture, or at least in my opinion it was lots of furniture, and lots of artwork and sculptures. And there was a lot of, like, memorabilia and pictures, and pictures with famous people and presidents and things like that. Q. What do you remember about the pictures and artwork inside the house in Palm Beach? A. Well, not knowing much about art, I thought some of it was SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068766

305 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 maybe a little bit odd. You know, there were some paintings of, like, naked women or half-naked women and, like, lots of kind of -- or animals, like creepy looking animals. Q. How did you feel when you were spending time inside that house? A. "Intimidated" I guess is the first word I think of. Q. You testified earlier that there came a time when you had sexual contact with Jeffrey Epstein. Again, approximately when was that, the first time? A. In 1994. Q. And again, how old were you? A. Fourteen. Q. Where were you when that happened for the first time? A. In Jeffrey's Palm Beach house. Q. Can you describe for the jury what happened that day. A. Well, Jeffrey was asking me, you know, You really need to focus on what you want to do; you can't be broad. You know, do you want to be an Do you want to do theater? Do you want to be an actress or model? We just sort of discussed that. He said, Well, you know, I know everybody. I know all the agents. I know all the photographers. I know, you know, the owner of Victoria's Secret. So I can make things happen, but you just have to be ready for it. Q. After he said that, what's the next thing that happened? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068767

306 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. The conversation just sort of ended abruptly. It was in his office. And he just took my hand and he said, Follow me. Q. Where did he take you? A. He took me outside in the backyard past the pool to the pool house. Q. Could you please describe for the jury what happened when he took you inside the pool house. A. He took me in the pool house. And on the right-hand side was this couch, futon-looking thing. And he just proceeded to pull me over. And he sat in the corner and he didn't say a word. And he just pulled his pants down. He was wearing sweatpants. And he pulled me on top of himself and he proceeded to masturbate on me. And then he just -- he got up and he went into the bathroom and, like, cleaned himself up, and then acted like nothing happened. Q. What was your reaction when he did that to you? A. Well, I was frozen in fear. I'd never seen a penis before, let alone not seen anything like this. Q. Did you tell anyone that day about what happened to you? A. No. Q. Why not? A. Because I was terrified and felt gross and I felt ashamed. Q. After the incident that you just described, did you continue spending time with Maxwell and Epstein in Palm Beach? A. Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068768

307 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. After that day that you just described, did there ever come a time when you saw Ghislaine Maxwell without her clothes on? A. Yes. Q. Approximately when was that? A. Shortly after the first incident. Q. Could you please describe for the jury what happened that day. A. The three of us were just spending time together hanging out and talking. And then all of a sudden, in that same manner, just abruptly said, you know, Follow me. And we went upstairs. I followed them up this -- felt like a winding staircase, up into Jeffrey's bedroom. Q. Once you got to the bedroom with Epstein and Maxwell that day, could you please describe for the jury what happened next. A. They moved me over to the bed and took their clothes off and started to like sort of, like, fondle each other and sort of, like, kind of casually giggling about it. And I was just standing there. And he asked me to take my top off. And then, you know, sort of just there were hands everywhere. And Jeffrey proceeded to masturbate again. And Ghislaine was like rubbing on him and kissing on him and, you know, fondling. And then that was it. Q. After the incident that you just described, did your visits to Epstein's house in Palm Beach include sexual contact? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068769

308 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. And I just want to be clear about this. For the incident that you just described when you were alone in a room with Epstein and Maxwell, how old were you when that happened for the first time? A. Fourteen. Q. After that day, did your visits to Epstein's house in Palm Beach include sexual contact? A. Yes. Q. I'll ask you now about what happened during those incidents. Were there times when you were alone with Epstein and Maxwell when you were 14? A. Yes. Q. What kinds of things would happen when you were alone with Epstein and Maxwell when you were 14? A. I'm sorry, in what context? Q. When you were 14 years old and there were times where you were alone with Maxwell and Epstein, what kinds of sexual contact would occur during those incidents? A. It would be them leading me to a massage table and showing me how Jeffrey likes to be massaged. Q. Who would tell you how Jeffrey likes to be massaged? A. Ghislaine and Jeffrey. Q. How did he like to be massaged? A. Like, he -- he liked -- like, very hard, like like, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068770

309 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 rubbing his shoulders really hard, and like twisting his nipples hard, and rubbing his feet hard and, like, his head. Q. Where in the house would incidents like this typically happen? A. In a massage room that was off, like, the master bedroom. Q. Did anyone ever give you instructions during incidents like this in the massage room? A. Yes. Q. Who would give you instructions? A. Ghislaine and Jeffrey. Q. What kind of instructions would they give you? A. Just showing me, you know, what he likes, what -- you know, what men like, what women like, you know, sort of touching on breasts and touching his penis. Q. What was Maxwell's demeanor like during these incidents? A. I would say that it seemed very casual, like it was -- like it was very normal, like it was not a big deal. Q. And when she behaved like that, how did that make you feel? A. Well, it made me feel confused because that did not feel normal to me; I'd never seen anything like this or felt any of this, and it was very embarrassing. You know, it's all these mixed emotions. When you're 14, you have no idea what's going on. Q. During these incidents that we've been discussing, did Epstein touch your body? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068771

310 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. Where did Epstein touch your body? A. He would touch-he would touch Q. During these incidents we've been discussing when you were 14, did you touch Epstein's body? A. Yes. Q. Where did you touch his body? A. Everywhere. Q. When you were alone with Maxwell and Epstein when you were 14, did anyone ever use a sex toy? A. Yes. Q. I'm sorry to ask you this, but could you please describe for the jury what would happen during those incidents. A. He liked to, like, use, like, vibrators that were different sizes; and even, like, those -- like -- like the back massagers that were, like, really, you know, painful. Q. During those incidents, what did Epstein do with that back massager? A. He would -- he would put it ven if I said that it hurt. Q. During these incidents, did Maxwell ever touch your body? A. Yes. Q. Where would she touch you? A. I would say mainly Q. Earlier, I believe you said that during these incidents, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068772

LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you touched Epstein everywhere. Can you explain for the jury what you meant by that. A. I meant he -- he wanted to be massaged really from head to toe. He liked his head rubbed, his shoulders, he liked his nipples squeezed, his feet and his penis. Q. Approximately how often did incidents like this occur when you were 14 years old? A. Approximately every visit to his house. Q. Were there ever sexual interactions with Maxwell and Epstein when other people were present as well? A. Yes. Q. Approximately how old were you when that happened for the first time? A. Fourteen or 15. Q. Where would those incidents typically take place? A. In one of Jeffrey's houses. Q. Were there times where you traveled to other houses that Epstein owned? A. Yes. Q. I want to talk with you about that in a few minutes. The incidents you've been describing where other people were present, how would they typically start? A. I'm sorry, can you -- Q. Of course. When there were incidents between you and Maxwell when SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068773

312 LBUVMAX4 - direct other people were present, how did incidents like that 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 typically start? A. It would be other people spending time at the house, sort of hanging out, seemingly casually. And then it was, once again, sort of, it seemed just abruptly everything would stop. And someone, Ghislaine or Jeffrey, would sort of summon everyone to, you know, follow to a room. Q. Where would everyone go? A. To either Jeffrey's bedroom or mainly the massage room. Q. During these incidents where other people were present, what would Maxwell typically do? A. Well, she, along with others, would just start taking their clothes off. And Jeffrey would get on the massage table, and it would just, you know, sort of turn into this orgy. Q. What, if anything -- what, if any, during these sessions? A. My underwear. Q. During incidents like this where other people were present, what kinds of sex acts would occur? A. Kissing, oral sex on each other, oral sex on Jeffrey, full-on intercourse. Q. How often was Maxwell present in the first year that that happened to you? A. I can't give an exact number. Q. Were there times where there were incidents like this where clothing did you wear SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068774

LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 she was not present? A. Yes. Q. Approximately how often would she be present during these incidents? A. I'm sorry, can you explain that? Q. If there were times when she was present and times when she wasn't present, approximately how often would she be present for group sessions like this? A. I don't know. Q. During these incidents where other people were present, were there ever sex toys that were used? A. Yes. Q. What do you remember about that? A. I mean, it was pretty much the same thing: Using vibrators on girls' vaginas. Q. The other people who were in the room during incidents like this, what was their gender? A. Female. Q. Approximately how old were they? A. Older than myself, but I don't know. Q. During these incidents when other people were present, were there any -- were there any particular acts that Epstein particularly liked or requested? A. Sorry. When other people were present? Q. Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068775

314 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't know if there's anything he particularly liked. _ saw different acts, but Q. Again, to be clear, where in the house would incidents like this typically happen? A. The massage room. Q. Could you please describe that room for the jury. A. In which house? Q. In the Palm Beach house. A. Oh. Q. Sorry. A. It was -- it looked like maybe it was light, because it was off the master bathroom, which was sort of -- it had like a beachy feel. Q. What was in the room? A. I don't think I saw anything past the massage table. Q. Did anyone ever call the incidents that you've just described a massage? A. Yes. Q. Who would call it that? A. Jeffrey. Q. Did incidents like this continue when you were 16? A. Yes. Q. How frequently did these incidents occur between when you were 14 and when you were 16? A. The number or -- SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068776

315 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. How often would it happen during those years? A. It would happen almost every visit with him, which would have been every two weeks. MS. MOE: Your Honor, if I could just have one moment. THE COURT: Yes. (Counsel conferred) MS. MOE: Thank you, your Honor. BY MS. MOE: Q. Earlier, you were describing an incident when Maxwell was in the room when you were 14. Just to be clear, during the incidents you've been describing to the jury when you were 14, was Maxwell in the room? A. Yes. Q. And when these incidents would occur when you were 14, was Maxwell in the room? A. At times. Q. And when you were 16, were there times when Maxwell was in the room? A. Yes. Q. Did there ever come a time when you traveled with Jeffrey Epstein or Ghislaine Maxwell? A. Yes. Q. Approximately when did you begin traveling with them? A. At 14 years old. Q. About when did you last travel with them? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068777

316 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. In March of 2001. Q. I want to focus now on the years when you were 14, 15, and 16. About how many times did you travel with them during those years? A. Maybe ten times. Q. Where did you travel with them when you were 14, 15, and 16? A. From Palm Beach to New York City, and also Santa Fe, New Mexico. Q. When you traveled with them to those locations, how did you get there? A. Mainly on Jeffrey's private plane. Q. Did you ever get there another way? A. Yes. Q. And how was that? A. Commercial flights. Q. When you flew in the private jet, did Maxwell ever go with you? A. Yes. Q. How would these trips typically be arranged? A. They would be arranged by Jeffrey's office. Q. Where did you typically stay when you traveled with Maxwell and Epstein? A. At Epstein's house. Q. Did Maxwell ever assist you in making travel arrangements? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068778

317 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. I want to talk about some of the locations that you just mentioned. Did some of those trips include travel to New York? A. Yes. Q. Where did you stay when you traveled with Maxwell and Epstein to New York? A. Epstein's house. Q. Where was that house located? A. New York City. Q. In what borough? A. Do you need the exact address? Q. No, it's okay. Approximately where was it within the city? A. Upper East Side. Q. Thank you. Could you please describe for the jury what the house on the Upper East Side looked like. A. Well, it looked more like a building than a house. It was eight stories, his massive eight-story house building where you walk through these giant doors and then there was, like, another security door to go in. And it had an elevator and it was eight stories. Q. How was the house decorated on the inside? A. It was -- it was very dark, I felt. You know, very, very -- like an old building. Lots of stone, you know, old SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068779

318 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 wood, and lots of, like, fabric wallpaper, like red curtains, lots of artwork, statues, paintings. Q. When you spent time in the house, what, if anything, did you notice about the artwork, the statues, and the paintings? A. I thought some of it was a little creepy personally. There was, you know, like, animals and giant, like, paintings that looked kind of -- I don't know how you would -- how I would describe it, but just felt uncomfortable. Q. the A. was What made you feel uncomfortable about artwork in the house? It all sort of seemed like to have a dark theme, like it kind of, you know, intimidating and dark and, like, animal heads and strange things. Q. the paintings and Did any of the artwork inside the house in New York contain nudity? A. Yeah. Q. A. It What did you notice about that? Paintings of naked women and orgies and things like that. didn't seem very unusual at this point. Q. When you would spend time inside that house in New York, how did you feel when you were inside the house? A. Intimidated. It wasn't a very warm place; you didn't feel very, maybe, safe. I kind of felt like -- you always kind of felt like someone is watching you. You didn't feel free to roam around exactly. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068780

319 LBUVMAX4 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. What rooms in the house did you spend time in when you would stay in the house in New York? A. What rooms would I spend time in? The room that I was given, which was the guest room on the eighth floor, or Jeffrey's bedroom, his bathroom, the massage room, or his office or the kitchen. Q. Earlier, you described having sexual contact with Epstein and Maxwell in Palm Beach. Did that ever happen when you traveled with them? A. Yes. Q. Can you describe for the jury what kinds of sexual acts would happen when you traveled to New York when you were 14, 15, and 16? A. It was a lot of the same. If it wasn't an orgy in the massage room, it was in Jeffrey's bedroom, and that would be mostly me alone with him. Q. What would happen when you were alone with him in the New York house when you were 14, 15, and 16? A. Well, he would get naked and get on his bed. And he would pull me on top of him and ask me to take my clothes off. Do you want me to describe in detail? Q. I'm sorry to ask, but if you could explain for the jury what would happen during these incidents. A. So he would show me what he likes. And basically, he would -- he would use vibrators on me, he would put his fingers SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068781