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UNITED STATES GRAND JURY
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
•
•
-V-
: November 19, 2019 Additional
GHISLAINE MAXWELL
(2018R01618)
APPEARANCE
S:
-x
United States Courthouse
300 Quaroppas Street
White Plains, New York
June 29, 2020
10:04 a.m.
Assistant United States Attorney
Assistant United States Attorney
Acting Grand Jury Reporter
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(Colloquy Precedes)
(Witness Enters Room)
(Time Noted: 10:16 a.m.)
called as a witness, having been duly sworn by
the Foreperson of the Grand Jury, was examined and
testified as follows:
BY MS.
Q.
Good morning.
A.
Morning.
Q.
Can you please state your full name for the
record?
A.
Q.
So I recognize that you are wearing a mask anc
behind Plexiglas. There's a microphone in front of you, it
you could just make an effort to speak into the mic and keep
your voice up that would be great.
A.
No problem.
Q.
Where do you currently work?
A.
The Federal Bureau of Investigation.
Q.
What is your title?
A.
Special agent.
Q.
How long have you worked as a special agent?
A.
About three years, three years now.
Q.
Where are you currently assigned?
A.
I work for the -- on the Violent Crimes against
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Children squad.
Q.
What are your duties and responsibilities as a
special agent on that squad?
A.
We investigate crimes that have to do with child
sexual abuse material, sextortion, exploitation, and
enticement of minors, sex trafficking.
GRAND JUROR. Maybe if she could take the mask
off. I'm having -- is anybody having difficulty
understanding her?
MS.
Thanks for letting me know. Would that
be okay with you if the witness took her mask off?
GRAND JUROR.
We're okay with the Plexiglas,
right?
GRAND JUROR.
Yeah.
MS.
Thanks very much. Thank you.
BY MS.
Q.
All right. So I'm just going to go back and ask
a few of those questions again just to make sure that
everyone can hear. You testified earlier that you're a
special agent with the FBI. Is that correct?
A.
Yes.
Q.
Where are you currently assigned?
A.
I work on the Violent Crimes against Children
squad.
Q.
And what are your duties and responsibilities as a
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special agent on that squad?
A.
We investigate crimes that involve child sexual
abuse material, sextortion, enticement, and exploitation of
minors, sex trafficking, international parental kidnappings.
MS.
Let me just pause here. Can everyone
hear the witness?
GRAND JUROR.
Yes.
MS.
Okay. Thank you. And Special Agent
if you could just try to keep your voice up, I really
appreciate it. It's a little difficult under the
circumstances.
BY MS.
Q.
Have you participated in an investigation of
Ghislaine Maxwell?
A.
Yes, I have.
Q.
Have you spoken to other people, including other
law enforcement officers, about this investigation?
A.
Yes.
4•
Have you reviewed reports and documents prepared
by others regarding this case?
A.
Yes.
Q.
Is your testimony today based in part on those
conversations with other law enforcement officers and
documents that you have reviewed?
A.
Yes.
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MS.
Ladies and gentlemen, let me just give
you a brief instruction. Some of the testimony that you'll
hear today will include what's called hearsay. As you know,
that means that the witness will not be testifying solely
from her own observations, but that she'll also be reporting
to you what others have told her and what she's read in
reports and documents prepared by other people.
Hearsay evidence is admissible in these grand jury
proceedings, and you're free to rely on it in determining
whether there's probable cause to indict the proposed
defendant.
If, however, you would like to hear the testimony
of any other witness, you have the right to request it and
we will make reasonable efforts to bring that witness before
you.
BY MS.
Q.
Special Agent
we placed on the desk in
front of you a PowerPoint that is Grand Jury Exhibit 2,
which we're entering into the record. Do you recognize
this?
A.
Yes.
Q.
What is it?
A.
It's a PowerPoint presentation to assist in
testifying today.
Q.
Did you participate in preparing this exhibit in
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connection with your testimony today?
A.
Yes, I did.
Q.
If you could please turn to the first slide. Who
are the individuals depicted in these photographs?
A.
The picture on the left is Ghislaine Maxwell, and
the picture on the right is Jeffrey Epstein with
Ghislaine Maxwell.
Q.
Based on your participation in this investigation
and your review of public source materials, have Maxwell and
Epstein been photographed together many times over
years?
A.
Yes.
Q.
Based on your participation in this investigation
and your review of public materials, where is Maxwell from?
A.
Maxwell was born in France. She grew up in the
United Kingdom, was educated in Oxford, and is from a
wealthy family.
Q.
Is she a citizen of France, the United Kingdom,
and the United States?
A.
Yes.
Q.
How old is she currently?
A.
58.
Q.
Has the FBI investigated Maxwell and Epstein's
conduct with minors during the 1990's?
A.
Yes
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Q.
Generally speaking, what have you learned about
the relationship between Maxwell and Epstein during the
1990's?
A.
Epstein and Maxwell had a romantic relationship,
and she also worked for him; managing his homes, hiring and
firing individuals.
4•
During that time period, was she one of his
closest associates?
A.
Yes.
4.
During the course of this investigation, have you
learned where Epstein maintained properties in the 1990's?
A.
Yes.
Q.
Where did he maintain properties?
A.
New York, Palm Beach, and New Mexico.
Q.
Turning to the next slide, did he maintain an
address in Manhattan located at 9 East 71st Street?
A.
Yes.
Q.
Does this slide fairly and accurately depict the
residence?
A.
Yes.
Q.
Can you please describe that property for the
grand jury?
A.
It's a seven story home; it's located near Central
Park. It's reportedly the largest residence in Manhattan.
Q.
Based on your participation in this investigation,
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did that house include a room that was used a massage room?
A.
Yes, it did.
Q.
All right. We'll talk more about that later, but
for now, moving on to the other properties. Did he maintain
an address in Palm Beach, Florida, located at 358 El Brillo
Way?
A.
Yes.
Q.
Turning to the next slide. Does this slide fairly
and accurately depict that residence?
A.
Yes, it does.
Q.
Could you please describe that property for the
grand jury?
A.
It's a waterfront estate. It has an in ground
pool and a detached dwelling or pool house on the property
as well.
Q.
And from your participation in this investigation
and your review of other materials, did that house include a
room that was used as a massage room?
A.
Yes.
Q.
Turning to the next property. Did Epstein also
own a ranch in New Mexico?
A.
Yes, he did.
Q.
And turning to the next slide. Was that property
located at 49 Zorro Ranch Road in Stanley, New Mexico?
A.
Yes.
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Q.
Looking at the photograph on this slide, does this
accurately depict that property?
A.
Yes, it does.
Q.
And we've been talking about the properties that
Epstein owned during this time period. Did he also own a
private jet?
A.
Yes.
Q.
Is it fair to say that he was a multimillionaire
during this time period?
A.
Yes.
Q.
During the 1990's did Epstein have an employee
who ran his house in Palm Beach?
A.
Yes, he did.
Q.
What was his job?
A.
His job was making sure that everything in the
house ran smoothly. He referred -- he described that
Epstein liked to have his house run live a five-star hotel;
that everything had to be in its proper place. So he was
responsible for managing that.
Q.
Have you interviewed
A.
Yes.
Q.
How many times?
A.
Twice.
Q.
And is the information you're about to provide
based on your interviews with
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A.
Yes.
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Q.
Did
begin working for Epstein in the early 3
1990's?
A.
Yes, he did.
Q.
And at the time
came to work for Epstein in
Palm Beach, was Epstein dating Ghislaine Maxwell at that
point?
A.
Not at that time.
4.
Was it a few years before Epstein began dating
Maxwell after
started working there?
A.
Yes.
Q.
From what
told you, how did
work change once Maxwell arrived on the scene?
A.
described Epstein as being more pleasant to
work with prior to Maxwell coming into the picture. Once
she came into the picture, he said things became more
secretive. He wasn't allowed to be in the room with guests,
wasn't allowed to talk with them, associate with them. It
became a different environment.
Q.
You talked about some of the rules that were
placed changing. Were there any rule changes about eye
contact once Maxwell began staying in the Palm Beach house.
A.
Yes.
wasn't allowed to make eye contact
with Epstein and others.
Q.
In general, how did he describe what it was like
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to work for Maxwell?
A.
He said she was very demanding; she was on top of
him all the time. He described her as a "bitch."
Q.
Is that the word that he used?
A.
That is the word he used.
Q.
Shifting gears. I want to talk to you about
someone else that you've interviewed during this
investigation. During the course of this investigation,
have you participated in interviews with an individual named
A.
Yes.
Q.
So for these purposes I'm just going to refer to
her as
Is that okay?
A.
Yes.
Q.
How many times have you interviewed
A.
Approximately five times.
Q.
If you could please just page through the next two
slides in front of you. Are these photographs of
A.
Yes.
Q.
Is it your understanding that these photographs
depict
from approximately ages 13 to approximately 17?
A.
Yes, it does.
Q.
Okay. Let's take a look at some of those
photographs. I'm going to publish the next slide. Is
date of birth
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A.
Yes.
Q.
And are these two photographs of
A.
Yes, they are.
Q.
If you could turn to the second slide of
photographs. Are these also photographs of
A.
Yes.
Q.
Based on your participation in this investigation
and your interviews with
where was she living when
she was approximately 14?
A.
She was living in Palm Beach, Florida.
Q.
Who was she living with when she was 14?
A.
Her mother and her siblings.
Q.
What was her whole life like at that time?
A.
At that time, her father had passed away the year
prior, so the family was struggling financially and having
some difficulties.
Q.
What did
father do before he passed away?
What was his profession?
A.
He was involved in
Q.
Was
involved in
A.
Yes, she was.
Q.
Were her siblings?
A.
Yes.
Q.
What kinds of
were they involved in?
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A.
Singing, she was a singer.
Q.
Like what kind of singer?
A.
Opera.
Q.
In the summer of 1994, how old was
A.
She was 13 going on 14.
Q.
You testified earlier that her birthday is in
, so did she turn 14 in
of 1994?
A.
Yes.
Q.
What did she do that summer?
A.
She attended an arts camp at Interlochen Certer
for the Arts.
Q.
And is Interlochen Summer Arts Program located in.
Michigan?
A.
Yes.
Q.
Did
meet Jeffrey Epstein and
Ghislaine Maxwell that summer?
A.
Yes, she did.
Q.
Did she meet them at summer camp?
A.
Yes.
Q.
What did she tell you about that?
A.
She said that she was sitting at a picnic table
with friends when Epstein and Maxwell walked by. They
stopped to talk to her, engaged her in conversation, asked
her if she liked her classes, her teachers. During that
conversation, they found out that she was also from Palm
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Beach and that he said that he gives scholarships to
students.
Q.
How did they leave the conversation? Was there
any contact information exchanged?
A.
They asked for
phone number.
Q.
As part of your investigation, have you attempted
to gather records to corroborate that
Maxwell, and
Epstein were all at that summer camp that summer?
A.
Yes.
Q.
If you could turn to the next slide, please. na
you obtained records from Interlochen for the summer of
1994?
A.
Yes.
Q.
And what are we looking at on this slide?
A.
This shows who -- some of the individuals that
were there -- were present for that camp in '94. On here is
and
Q.
And have you investigated whether Maxwell and
Epstein were also at Interlochen that summer of 1994 as
described?
A.
Yes.
Q.
Based on your review of records from Interlochen,
what is your understanding of Epstein's relationship with
Interlochen?
A.
My understanding was that he was a donor to the
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Q.
1994?
school.
Q.
Did he make any substantial donations?
A.
He did.
Did he donate a lodge to the camp in the summer of 5
A.
Yes, he did.
Q.
Did he have a long standing relationship as a
donor to Interlochen?
A.
Yes.
Q.
Turning to the next slide. Is this an excerpt o:
a letter from Interlochen to Epstein?
A.
Yes, it is.
Q.
And does this letter thank Epstein for donating a
scholarship lodge?
A.
Yes.
Q.
Does it invite Epstein to visit in August of 1994?
A.
Yes.
Q.
In 1994, did Epstein have a private jet?
A.
Yes, he did.
Q.
Have you obtained the flight logs for that jet
A.
Yes.
Q.
Do those logs include passenger lists and the
airport code for the airports that the plane flew into and
out of?
A.
Yes.
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4.
Turning to the next slide. Is this a page of the
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flight logs that you've reviewed?
A.
Yes.
Q.
And on this excerpt of the flight logs where the
red arrow is, is that a log entry showing an August 18, 1994
flight to an airport with the airport code TVC?
A.
Yes.
Q.
Is TVC the airport code for Cherry Capital Airpor -
in Traverse City, Michigan?
A.
Yes, it is.
Q.
car?
About how far is that airport from Interlochen by
A.
It's about 25 minutes give or take.
Q.
And who were the listed passengers on this flight?
A.
Jeffrey Epstein,
(ph.), and
(ph.).
Q.
Turning to the next slide. Is this the same
excerpt but just with a different arrow?
A.
Yes.
Q.
Okay. So a few lines down is there a flight out
of Traverse City just two days later on August 20th, 1994?
A.
Yes.
Q.
And do the passengers listed in the flight out of
Traverse City include the initials G.M.?
A.
Yes, they do.
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Q.
Are those Ghislaine Maxwell's initials?
A.
Yes.
Q.
Have you obtained any records from Interlochen to
indicate that Maxwell was at Interlochen in 1994?
A.
Yes.
4.
If we could turn to the next slide. Can you
please explain for the grand jury what we're looking at on
this slide?
A.
This was a letter from Interlochen explaining
addressed to Maxwell telling her that they had found an
envelope in the lodge that they had been staying in.
Q.
All right. We were talking a few moments ago
about how
described meeting Maxwell and Epstein at
summer camp, and you testified that she provided them with
her phone number. Did
explain to you whether or not
she had any contact with Epstein or Maxwell after she
returned home to Palm Beach?
A.
Yes.
Q.
When was the next time that happened?
A.
Shortly thereafter.
Q.
And how did that occur?
A.
She was invited to his house. So her and her
mother went to Epstein's house to visit.
Q.
What did
tell you about that visit to
Epstein's house with her mother?
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A.
She said it was
wait, can you rephrase that?
Q.
Of course. Did
go to the house by herself
or with her mother?
A.
With her mother.
Q.
Okay. And when they went to the house, what did
they do there?
A.
They had tea.
Q.
Who was there when they had tea at the house?
A.
Epstein and Maxwell.
Q.
What did they discuss as they had tea?
A.
They just talked about her life and, you know,
what she wanted to do.
Q.
Did Epstein make any offers?
A.
He said that he gives scholarships. He likes to
mentor people.
Q.
How did
mother react when Epstein said
this?
A.
She was happy for her daughter and oftentimes
referred to Epstein as
Godfather.
Q.
After that occasion when they went over to the
house, thereafter did
subsequently begin regularly
spending time with Maxwell and Epstein at Epstein's house in
Palm Beach?
A.
Yes.
Q.
And did that start when she was approximately age
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A.
Yes.
Q.
Did it continue until she was about age 17?
A.
Yes, it did.
Q.
And during those years, did she regularly go over
to Epstein's house in Palm Beach and spend time with Maxwell
and Epstein?
A.
Yes.
Q.
What happened in the summer of 1997 when
was 17 and about to turn 18?
A.
She moved to New York City.
Q.
Why did she move to New York City?
A.
She wanted to pursue a career in acting and
modeling.
Q.
We'll talk about that in a moment, but for now I
want to focus on the years you talked about in Palm Beach
from ages 14 to 17 when
would regularly go to
Epstein's house. In the beginning, in the first few months
when she went there, what kinds of things did she do when
she would visit the house when Maxwell and Epstein were
there?
A.
They'd hang out by the pool, he -- they would take
her to the movies, take her shopping. She described the
behavior as grooming.
Q.
When you say grooming, did she explain what sh,
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meant by that?
A.
She meant that they were building a relationship
with her, giving her things, taking her places. And then
usually when the grooming happens, an offender will -- once
they gain that trust, they will make the relationship turn
sexual.
Q.
Now, you testified just a moment ago that
described to you that she felt at this time period that they
were grooming her. Is that right?
A.
Yes.
Q.
Is that something that she realized at the time
when she was 14, or is that something that she's described
to you now?
A.
Something she's described now. She didn't realize
that at the time.
Q.
So we'll talk a little bit more about grooming in
a moment, but just to give context are you familiar with the
term grooming based on your experience investigating crimes
involving a sexual exploitation of minors?
A.
Yes.
Q.
Generally speaking, -- you were touching on this a
moment ago, but if you just could explain in full. What is
grooming?
A.
Grooming is when someone builds a relationship
with a child. They find a vulnerability or a need and then.
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they work on gaining a child's trust, and then oftentime
gaining a parent's trust. Once they have that trust, they
show that in ways that they care about them by giving them
gifts and promises. And then once that's established, they
then turn the relationship sexual, oftentimes making sexual
comments and normalizing the behavior.
4.
Now, during these visits that you've been
describing that
told you about, did
say whether
Epstein ever gave her anything?
A.
Yes, she did.
Q.
What did he give her?
A.
He gave her cash. Sometimes he'd tell her to give
the cash to her mom because he knew that they needed it. He
paid for her voice lessons as well.
Q.
Now, you were describing how
has
characterized these visits now. But based on your
conversations with her, at the time did she feel that these
visits were strange at all?
A.
She thought they were strange, but Maxwell
normalized it for her. She was like a cool older sister and
made comments like this is what grownups do.
Q.
You used the phrase cool older sister. Is that a
phrase that
used to describe how she felt about
Maxwell at the time and what Maxwell was like?
A.
Yes, those are her words.
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Q.
Did there come a time -- these visits when
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saw Maxwell topless by the pool?
A.
Yes.
Q.
What did she tell you about that?
A.
She was a little taken back, but Maxwell just
acted normal.
Q.
Did
tell you about an incident several
months into this arrangement when she was alone with Epstein
in the pool house?
A.
Yes.
Q.
And when they were alone together, did Epstein ask
what she wanted to do with her life?
A.
He did.
Q.
What did she say?
A.
She said she wanted to be an actress and a model.
Q.
How did Epstein respond?
A.
He told her that he was best friends with the
owner of Victoria Secret. Told her that she would have to
have photographs taken and that she got to be comfortable in
her underwear, and not to be a prude. When she asked what
that meant, he pulled her to his lap and masturbated.
Q.
What was her reaction?
A.
She felt paralyzed. She froze.
Q.
After this incident, did
encounters with
Epstein begin to include sexual contact?
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A.
Yes.
Q.
Over time, did the sexual abuse escalate?
A.
It did.
Q.
From what she's described to you, did the abuse
include Epstein digitally penetrating
A.
Yes.
Q.
Did it include Epstein using a vibrator on her?
A.
Yes.
Q.
Did she describe to you that there were times when
Epstein would direct
to massage him while he
masturbated?
A.
Yes.
Q.
Did
explain to you what her memories are
like of the abuse?
A.
Yes.
Q.
What did she say about that?
A.
She said that it happened so often that it all
kinds -- it all runs together for her. That it's hard to
separate out some of the different instances of abuse.
Q.
You were describing how
explained to you
that the abuse began. Did that occur based on what
told you within the first year that she met Epstein and
Maxwell?
A.
Yes.
Q.
Now, did
also describe to you that once this
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abuse started, Epstein would also bring her into his massatl
room in the house?
A.
Yes.
Q.
And were there times where he did this where there
are other women present including Maxwell?
A.
Yes.
Q.
Was
abused during those episodes?
A.
Yes, she was.
Q.
During these group encounters what were
and
the adult women wearing?
A.
They were usually just in their underwear.
Q.
Once they were all in the massage room, how wou..a
these episodes generally start?
A.
They would generally start with one of the girls
massaging Epstein.
was usually massaging his fee-.
Maxwell was kind of teasing the girls; she'd grab the girls'
breasts and she would direct the girls on what to do.
Q.
When these episodes would start, in general was
Epstein generally lying face down on the massage table?
A.
Yes.
Q.
What would happen as things progressed generally
speaking from what she described to you?
A.
When Epstein would decide he was kind of done with
the regular massage, he would turn over to his back and he'd
grab whichever girl he wanted to either touch him or
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whatever girl he wanted to touch.
Q.
Did these episodes include sex acts that over time
in various instances included Epstein masturbating, Epstein
receiving oral sex, and Epstein engaging in intercourse?
A.
Yes.
Q.
You were describing for a moment what
to_
you about Maxwell's role during these group encounters.
Would Maxwell sometimes guide the women and give
instructions about what to do?
A.
Yes, she would.
Q.
What would
typically do during these
episodes?
A.
She would try to not look at Maxwell because she
gave off that sister vibe so it felt weird for her. She
would try to be invisible in that room so they would ignore
her as much as possible.
Q.
In the beginning when
was approximately 14
or 15, would she generally begin by just massaging Epstein's
feet?
A.
Yes.
Q.
Is that something she was told to do?
A.
Yes.
Q.
Did she -- you mentioned that she tried to be
invisible. Was -- I believe that was your testimony?
A.
Yes.
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Q.
And over time -- has she described to you that
over time she believes she became more involved in the
sexual activity which varied in each encounter?
A.
Yes.
Q.
Were there times -- let me rephrase that. How did
you touched on this for a moment, but just to be clear,
how did
describe Maxwell's attitude during these
incidents?
A.
It was very casual. She acted like this was
normal. She gave off that vibe to her and -- yeah.
Q.
Did that make her feel more comfortable with what
was happening?
A.
It did.
Q.
Was
sometimes fully nude during these
episodes?
A.
Yes.
Q.
And during these episodes, did the abuse include
Epstein touching
breast?
A.
Yes.
Q.
Did it include directing
to touch Epstein's
genitals?
A.
Yes.
Q.
Beginning when
was approximately 14, does
she begin to travel with Epstein and Maxwell to New York
City on occasion?
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A.
Yes, she did.
Q.
Was that to the property you testified about
earlier? The townhouse on the Upper East Side?
A.
Yes.
Q.
When
traveled to New York City, did she stay
at Epstein's townhouse in New York City?
A.
Yes, she did.
Q.
Did she recall that Maxwell and Epstein took her
shopping on one of her early trips to New York City?
A.
Yes.
Q.
Did she remember them buying her anything?
A.
She recalled them buying her white cotton
underwear. Her description was that they were, like, little
girls underwear.
Q.
From ages 14 to 17, did Epstein ask
to
periodically fly to New York for weekends at that townhouse
in New York?
A.
I'm sorry, say it again?
Q.
You testified that she began traveling to New York
City at age 14. Did she then periodically travel to New
York City in a similar manner from ages 14 to 17?
A.
Yes.
4•
Were there times when she traveled on those trips
when she flew on Epstein's private jet?
A.
Yes.
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Q.
Did she also sometimes fly commercially?
A.
Yes, she did.
Q.
Was Maxwell sometimes present on the trips to New
A.
Yes.
99
Q.
You testified earlier that
was sexually
abused in Palm Beach. Did she describe to you that she was
also sexually abused on these trips to New York?
A.
Yes, she did.
Q.
Did Maxwell encourage
to go on these trips?
A.
Yes.
Q.
What does
-- what did
tell you about
her memory of how these trips were arranged?
A.
She recalled that Maxwell was usually the one that
would schedule her flights. If she was flying commercially,
she would schedule the flights, sometimes calling her mother
to schedule.
Q.
Was that her general impression of how they were
arranged?
A.
Yes.
Q.
In addition to the trips to New York City that you
just described, did
also remember traveling at least
once to Epstein's ranch in New Mexico?
A.
Yes, she did.
Q.
Did she remember whether or not she was sexually
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abused in New Mexico?
A.
She couldn't recall. She couldn't remember.
Q.
In general, how would
get to the airport in.
Florida when she would fly on Epstein's jet? What did she
describe to you?
A.
Usually a driver
one of Epstein's drivers would
pick her up from her house and take her to the airport.
Q.
Now, you testified earlier that you reviewed
flight records for Epstein's private jet. Is that correct?
A.
Yes.
Q.
And have you reviewed records from the 1990's
see if that there -- whether there's a person named
listed on the records?
A.
Yes.
Q.
Turning to the next slide. Is this an excerpt
from those records?
A.
Yes, it is.
Q.
And does the red arrow point to -- just one
moment. Does the red arrow point to a November 11th, 1996
flight?
A.
Yes, it does.
Q.
And is this a -- does this flight log reflect that
it was a flight from Palm Beach, Florida to Teterboro, New
Jersey?
A.
Yes.
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Q.
Is there a private airfield in Teterboro, New
Jersey?
A.
Yes, there is.
Q.
What's it called?
A.
Teterboro Airport.
Q.
Are the passengers listed on this entry J.E.?
A.
Yes.
Q.
Are the -- do the entries also include
olu
friend,
(ph.), family, III (ph.) child,
(ph.), and
A.
Yes.
Q.
Was
-- based on your awareness of
date of birth and the date of this flight, was
16 on
the date of this flight?
A.
Yes, she was.
Q.
Turning to the next slide. You testified earlier
about Teterboro Airport. What are we looking at on this
slide?
A.
This is directions from Teterboro Airport to
Epstein's residence here in Manhattan.
Q.
So based on your review of this map, if someone
were to fly into Teterboro Airport and travel to New York
City, would they -- would the most natural root be to travel
from Teterboro Airport and crossing into New York through
Manhattan?
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Q.
A.
Yes.
Q.
Turning to the next slide. Is this also an
excerpt from the flight records that you've reviewed?
A.
Yes, it is.
Q.
And does this show a May 9, 1997 flight from
Teterboro, New Jersey to Santa Fe, New Mexico?
A.
Yes, it does.
Q.
G.M.,
And are the passengers listed on this log J.E.,
A.
Yes.
Q.
Based on your knowledge of
birthdate and
the date of this flight, would
have been 16 on the
date of this flight?
A.
Yes, she would've been.
Q.
Turning to the next slide. Is this also an
excerpt from the flight records?
A.
Yes.
And does the red arrow point to a flight entry on 19
May 3rd, 1998?
A.
Yes, it does.
Q.
Based on the airport codes, does this reflect that
there is a flight on that date from Palm Beach, Florida to
Teterboro, New Jersey?
A.
Yes.
Q.
And are the passengers listed on this log J.E.,
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G.M., E.T.,
Glen (ph.),
(ph.),
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(ph.), Manny (ph.),
(ph.)?
A.
Yes.
Q.
Based on your knowledge of
birthdate and
the date of this flight, would
have been 17 on this
date?
A.
Yes.
Q.
Am I correct that you testified earlier that in
addition to sometimes flying on Epstein's private jet, she
also traveled on commercial airlines, is that correct?
A.
Yes, it is.
Q.
Based on your review of these flight logs, does
every flight entry list the name of every single passenger,
or are there times when a passenger is noted female?
A.
There's time where a passenger is just noted
female.
Q.
I'm going to talk to you about two examples of
that. Turning ahead two slides. Looking at slide 18, does
this reflect a January 3rd, 1995 flight where the flight log
says J.E., two females?
A.
Yes, it does.
Q.
And do the two entries below also just list fema_ ,
next to the initials J.E.?
A.
Yes, they do.
Q.
Turning to the next slide, slide 19. Is this
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another example of an entry like that? Focusing on the
entry on February 12th, 1995?
A.
Yes.
Q.
Does that entry also say female?
A.
Yes, it does.
Q.
Now, you testified that
sometimes flew on
commercial airlines and that arrangements for her travel
were made for her to fly commercially for these trips.
that right?
A.
Yes.
Q.
Have you been able to obtain commercial flight
records?
A.
We tried. We were not able to obtain those
records.
Q.
Why is that?
A.
Airlines do not keep records past a certain year.
Q.
Does
recall group sexualized massages
involving Epstein and Maxwell in both the New York and
Florida residences during the time period we've been talking
about?
A.
Yes.
Q.
You testified earlier about the time that Epstein
and Maxwell would spend together and the activities that
they were involved in. During this time period, did
have occasions to talk with Maxwell?
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A.
She -- I'm sorry, can you ask the question again?
Q.
During the -- beginning when she was 14 when she
began spending time with Epstein and Maxwell and through the
years, did
often have conversations with Maxwell about
her life?
A.
Yes.
Q.
Did they talk about that often?
A.
They did.
Q.
Did Maxwell ask
about her family, her
classes, and other aspects of her life?
A.
Yes, she did.
Q.
You testified earlier that just before she turned
18,
moved to New York City. Is that right?
A.
Yes.
Q.
Did she go to school there in New York City for
her senior year?
A.
Yes, she did.
Q.
What school did she go to?
A.
She went to
Q.
What is
A.
They cater to individuals who want to pursue
careers in the arts.
Q.
Have you reviewed records from
A.
Yes.
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Q•
If you could turn to slide 17. Can you please
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explain for the grand jury what we're looking at here?
A.
This is an excerpt from
application to III
On it is listed who is
financially responsible for her, and that is
Jeffrey Epstein.
Q.
From what
told you, did Maxwell encourage
to accept Epstein's financial help?
A.
Yes.
Q.
When
moved to New York City who was she
living with?
A.
She lived with her mother and brother in
Q.
Did Epstein help pay for her rent?
A.
He did.
Q.
During that year, her senior year of high school
when she was in New York City, did
remain in contact
with Epstein?
A.
Yes.
Q.
What was the nature of their contact like during
this time period?
her.
A.
During this time he was still sexually abusing
Q.
Did that continue to occur in his townhouse in
Manhattan that year?
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A.
Yes, it did.
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Q.
What happened at the end of her senior year of
high school?
A.
She moved to Los Angeles to pursue a career in
acting.
Q.
Did she get a job as an actress when she was 18?
A.
She did.
Q.
Has
lived in Los Angeles and worked as an
actress on television ever since then?
A.
Yes.
Q.
After she moved to Los Angeles did she continue
being in touch with Epstein?
A.
For a short period of time.
Q.
Did she ultimately break contact with him?
A.
Yes, she did.
Q.
Is
currently pursuing a civil lawsuit
against Maxwell and Epstein's estate?
A.
Yes.
Q.
Have you talked with
about whether when she
was a teenage girl when all of this was happening whether
she told anyone that she was being sexually abused?
A.
Yes, she said she didn't tell anyone. She te_
like she couldn't. She -- the -- nothing was talked about
outside of that room, so it made it so that she couldn't
talk about it. And then she also -- her mother is Middle
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Eastern, and her mother raised her that women are supposed
to do what they're told even if someone is beating you.
And when she was 13 and her father passed, she was
-- she went to a guidance counselor at school to talk about
it, and her mother found out about it and smacked her. So
she felt like she couldn't talk to anyone about it.
Q.
Did
mother encourage her to accept
Epstein's financial assistance?
A.
Yes, she did.
Q.
Have you become aware that in 2005, police
officers from the Palm Beach Police Department executed a
search warrant at Epstein's house at the El Brillo Way
address in Palm Beach?
A.
Yes.
Q.
Have you reviewed some of the materials seized
during the search?
A.
Yes.
Q.
Did they find massage tables and sex toys?
A.
Yes, they did.
Q.
Did they find any photographs of
A.
Yes.
Q.
Was one of the photographs signed by
A.
Yes, it was.
Q.
Did it say
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A.
Yes.
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Q.
During your interviews with
did
tell
you how she felt about Epstein and Maxwell in the '90's when
she was a young girl?
A.
She did. She expressed that she felt like they
loved her, she felt like they were her family. That they
supported her and that she felt she was made to feel like
that she needed to be grateful to them.
Q.
Okay. Did she tell you that she felt like they
were trying to help her?
A.
Yes.
Q.
Have you talked with
about how she feels
about this now?
A.
Yes.
Q.
What was
demeanor like when she described
to you what Epstein and Maxwell had done to her?
A.
She was upset. She recognized that now, it's
affected her life to a great degree. She's struggled in
relationships with opening up to people and trusting people,
both personal and professional relationships.
Q.
Did she tell you that she struggled to tell anyone
what had happened to her for most of her adulthood?
A.
Yes.
Q.
When was the first time that you interviewed
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A.
Last fall.
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Q.
Was that the first time she'd ever reported this
to law enforcement?
A.
Yes, it was.
Q.
Now, you testified earlier about your interviews
with
who worked at Epstein's Palm Beach house.
Did he remember a girl named
coming to the house
during that time?
A.
Yes, he did.
Q.
Did he recall
Maxwell, and Epstein being in
the Palm Beach house together?
A.
Yes.
Q.
What was his understanding of why
was there?
A.
He thought that Epstein was helping her, that'
what Epstein had told him, and
had told him that
Epstein was helping her.
Q.
Did he ever observe Epstein interacting with
physically?
A.
Yes.
Q.
What did he see?
A.
He saw Epstein kiss
the bottom.
Q.
cheek and pat her on
Did he have any knowledge about what was happening
with Epstein or Maxwell when he wasn't present?
A.
He didn't.
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Q.
Did
ever recall picking up
from her
house?
A.
Yes.
Q.
And when he would pick her up from her house,
would he then bring her back to the Palm Beach house:
A.
Yes.
Q.
Did he remember who in general would tell him to
pick up
from her house?
A.
Maxwell would be the one to tell him to pick her
up.
Q.
Did he recall ever driving
to the movies?
A.
Yes.
Q.
What did he tell you about that?
A.
That it would usually be Epstein, Maxwell, anc
They'd go to the movies and it would usually be late
at night.
Q.
Did he tell you about what his memory was about
how old
was?
A.
He said she was young and that he knew that
because he had picked her up from school and that he knew
she was too young to drive.
Q.
Switching gears. I want to talk to you about a
different aspect of your interviews with
Based
on what he told you about his job duties, were there ever
times when he would have to clean Epstein's massage room?
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A.
Yes.
Q.
What did he tell you about that?
A.
He said that he found sex toys in the massage room
and he had to wash them afterwards.
Q.
Aside from those experiences, was he aware of
there being sex toys in the house?
A.
Yes. There was a basket of sex toys that were
kept in Maxwell's closet.
Q.
Did
stop working for Epstein in
approximately 2002?
A.
Yes.
Q.
Was he told that he was being replaced?
A.
Yes.
Q.
And was he generally aware that the person who
replaced him was much younger?
A.
Yes.
Q.
Did
tell you that a few months after he
left working for Epstein he became suicidal because of
issues in his marriage?
A.
Yes.
Q.
Did he tell you that he went to Epstein's house
and tried to take Epstein's gun?
A.
Yes, he did.
Q.
Did he tell you he took several thousand dollars?
A.
Yes.
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Q.
Did Epstein discover this and confront him about
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it?
A.
Yes, he did.
Q.
Did
admit to Epstein and the police what
he'd done?
A.
Yes.
Q.
Did Epstein also tell the police his gun was
missing?
A.
Yes.
Q.
Were there any charges filed?
A.
No.
Q.
Was he ever arrested?
A.
I don't believe so.
Q.
And did Epstein pursue any charges about this
incident?
A.
No, he didn't pursue anything.
Q.
Have you interviewed one of Epstein's former
pilots?
A.
Yes.
Q.
Is that pilot named
A.
Yes.
Q.
Was he one of the pilots for Epstein's private jet
in the 1990's?
A.
Yes.
Q.
Did he remember
traveling on the je
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in the 90's?
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A.
He remembered her traveling, but he didn't
remember specifics.
Q.
So just to be clear, is your testimony that he
didn't remember the specific dates of the flights, but he
remembered her traveling on the jet during the 1990's?
A.
Yes.
Q.
And did he remember
specifically as
a person who traveled?
A.
Yes.
Q.
Did you discuss with him the flight records that
we talked about earlier that lists a person named
passenger?
A.
Yes.
Q.
Did he have a specific memory of those exact
flights?
A.
No.
Q.
But was he aware of any other
jet besides
in the 1990's?
A.
No, no other
at that time.
Q.
Earlier when we were looking at Interlochen
attendance records for the summer of 1994, you noted tha
•
right?
as
flying on the
was one of the names on that record. Is that
A.
Yes.
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Q.
Is that
A.
Yes.
Q.
Have you interviewed
A.
Yes, I have.
Q.
Did he tell you that he remembered
talking
that summer at camp about having met Jeffrey Epstein?
A.
Yes.
Q.
Did he tell you that he remembered
going
over to Epstein's house in Palm Beach when they were in high
school?
A.
Yes.
Q.
Did he remember that
would often talk about
spending time with Maxwell and Epstein during this time?
A.
Yes.
Q.
Did he remember
telling him when they were
in high school about at least one trip to New York City that
she took with Epstein?
A.
Yes.
Q.
Did he remember
describing Epstein's
townhouse in Manhattan?
A.
Yes.
Q.
And does he remember
talking often about
Ghislaine Maxwell?
A.
Yes.
Q.
Now, based on your interviews with
did he
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tell you whether he knew back then when they were in high
school whether
was being sexually abused by Epstein?
A.
He didn't know back then.
Q.
Did III ever meet Ghislaine Maxwell?
A.
Yes, he did.
Q.
What did he remember about that?
A.
He remembered Epstein, Maxwell, and
being
near a movie theatre and he was approximately 16 at the time
and
would've been 15, and just the little bit of
interaction they had. And then after that,
had told
him that Maxwell had said something to the effect I could
teach
a thing or two.
Q.
Is that something that he remembers
telling
him back then that Maxwell had said?
A.
Yes.
Q.
During the course of this investigation, have you
participated with interviews with an individual named
A.
Yes.
Q.
So for today's purposes I'm just going to refer to
her as
How many times have you interviewed
A.
Approximately twice.
Q.
Now, does
know
Have they
ever met as far as you know?
A.
As far as I know, no.
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Q.
Turning to the next slide. Are these photographs
of
when she was in high school?
A.
Yes.
Q.
And is her date of birth
A.
Yes.
Q.
When
was approximately 16 and a junior in
high school, where was she living?
A.
She was living in Arizona with her mother.
Q.
Does she have any siblings?
A.
An older sister.
Q.
What did her older sister do?
A.
Her older sister lived -- worked for Epstein.
Q.
Where did she work for Epstein?
A.
Here in New York.
Q.
Did there come a time in approximately December
1995 when
had a phone conversation with her sister
about traveling to New York City?
A.
Yes.
Q.
What did they discuss?
A.
They discussed her coming to New York and meetinc
Epstein.
Q.
What did her sister tell
about why she
should meet Epstein?
A.
She said that he could help her with college.
Q.
And did she say -- did the sister say whether the
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sister wanted her to meet Epstein or did she say whether
Epstein wanted to meet
A.
Epstein wanted to meet
Q.
Now, let me just pause here. You testified that
this happened in approximately December of 1995. Just for
context, the years that we were talking about with
was that 1994 through 1997?
A.
Yes.
4.
So is this approximately the same time period
while what you described
telling you happened?
A.
Yes.
Q.
So in January of 1996, did
fly on a
commercial airline to New York City to spend a weekend with
her sister and meet Jeffrey Epstein?
A.
Yes.
Q.
Did she tell you that?
A.
Yes.
Q.
During the trip, did
tell you that she met
Epstein at his townhouse in New York City?
A.
Yes, she did.
Q.
Did she tell you that Epstein discussed her plan.,,
for college applications and offered to help her?
A.
Yes.
Q.
What was
first impression of
Jeffrey Epstein?
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A.
She was very impressed by him.
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Q.
What did she -- what was her impression based on
this conversation of what Epstein was going to do for her?
A.
That he was going to help her with her future
plans for college.
Q•
During that trip to New York City, did she stay at
Epstein's townhouse or at her sister's apartment?
A.
Her sister's apartment.
Q.
During that trip, did she tell you that she saw
Epstein a second time when he took
the movies?
A.
Yes.
Q.
and her sister to
What did she tell you happened at the movies?
A.
She said that they were sitting in the theatre and
Epstein was between
and her sister, and Epstein put
his hand on her leg, he rubbed her arm and held hands with
her.
Q.
From what she told you what was her impression
about whether her sister could see what was going on?
A.
She felt like her sister couldn't see.
Q.
What was her reaction to this happening?
A.
She was uncomfortable.
Q.
After the movie did she tell her sister what had
happened?
A.
No, she didn't.
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Q.
Did she say why not?
A.
She said that she knew
-- her sister really
liked Epstein and that Epstein could help them, so she
didn't tell her.
Q.
After this trip did
go back home to
A.
Yes.
Q.
Did Epstein contact her afterwards?
A.
Yes.
Q.
Did he discuss with her her ongoing college plans?
A.
Yes, he did.
Q.
Did he invite her to a weekend at his ranch in New
Mexico in the spring of 1996?
A.
Yes.
Q.
Was she 16 at the time?
A.
Yes, she was.
Q.
From what she told you, what was
impression of who would be on this trip to New Mexico?
A.
She knew Maxwell would be there.
Q.
Did she -- was she told anyone else was going to
be present during this trip?
A.
She said that there would be, like, other students
her -- kids her age.
Q.
And what was her understanding of who these other
kids were and why they'd be there? Sorry, let me
A.
Rephrase.
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Q.
-- rephrase the questions. You testified that she
was told that on this trip that there would be other
students. Was she under the impression that there would be
other young students like her on the trip who were also
being mentored by Epstein?
A.
Yes.
Q.
Now, you testified just a moment ago that she was
also told that Maxwell would be there. Are you referring to
Ghislaine Maxwell?
A.
Yes.
Q.
At the point that she was told that
Ghislaine Maxwell would be on this trip, had she ever met
Ghislaine Maxwell?
A.
No, she hadn't.
Q•
Had she heard her sister talk about
Ghislaine Maxwell?
A.
Yes.
Q.
How did -- from what she described to you, how did
her expectation that Maxwell would be on this trip make her
feel about the trip?
A.
It made her comfortable. Her sister had talked
highly of Maxwell.
Q.
Did
tell you that she flew to New Mexico
that spring when she was 16?
A.
Yes.
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Q.
Did she meet Ghislaine Maxwell when she arrived in
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New Mexico?
A.
Yes, she did.
Q.
How did she describe Maxwell's demeanor and
attitude when she met her?
A.
She described Maxwell as being very charming. She
gave her a tour of the house and Maxwell took
shopping, which made her feel special.
Q.
What does she remember talking about with
Ghislaine Maxwell?
A.
They talked about school, homework, trips.
Q.
Did she talk with her about applying to college?
A.
Yes.
Q.
Did she talk about her classes in high school?
A.
Yes.
Q.
Did she talk with her about the homework that she
had to do that weekend?
A.
Yes.
Q.
Did she talk with Maxwell about her family?
A.
Yes.
Q.
Did she talk with her about her home life and
living with her mother?
A.
Yes.
Q.
From what
told you, when she got there who
else was at the ranch besides Ghislaine Maxwell and
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Jeffrey Epstein?
A.
It was just them.
4.
Was it just the three of them the entire weekend
of the visit?
A.
Yes.
Q.
Were there any other school kids there?
A.
No.
Q.
When they were at the ranch, from what
told
you, did Maxwell say anything to
about massages?
A.
Yes.
Q.
Did she say anything to her about foot massages?
A.
Yes.
Q.
What did
tell you about that?
A.
Maxwell told
to give Epstein a foot massage,
and then she showed her and instructed her how to do it.
was a little uncomfortable, but Maxwell was joking
around so she just followed her lead.
Q.
Did
tell you what Maxwell and Epstein took
her to the movies that weekend?
A.
Yes.
Q.
What did she tell you about that trip to t
movies?
A.
She said that when they went outside the theatre
Maxwell was joking around and pulled Epstein's pants down a
little bit. And then once they went inside the theatre,
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Epstein -- when they were sitting down, Epstein touched
leg, he rubbed her arm, held her hand. And this
time he --
felt that he wasn't trying to hide it from
Maxwell.
Q.
What was
reaction to all of this?
A.
She was uncomfortable.
Q.
During the same weekend, was there another
occasion when Maxwell talked about massages?
A.
Yes.
Q.
What happened?
A.
Maxwell had asked
if she ever had a massage,
and Maxwell told her she could give her one. So
was
on her back and Maxwell had pulled the sheet down exposing
her chest, she was nude from the top up, and proceeded to
massage around her chest and breast area.
Q.
From what
told you when she was describing
to you what you just described to the grand jury, how did
she feel while this was happening?
A.
She felt really uncomfortable.
Q.
Did
also tell you about an incident that
happened one morning when she was in New Mexico?
A.
Yes.
Q.
What did she tell you happened?
A.
She said she was in bed and Epstein came into the
room and told her that he wanted to cuddle. So he laid down
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54
next to her and spooned her. She told him she had to go tc
the bathroom to get out of the situation.
Q•
What was her reaction to that when Epstein got
into her bed?
A.
She was uncomfortable. She didn't know what to
do.
Q.
Did
go back home to
when the weekend
was over?
A.
Yes, she did.
Q.
Did she tell anyone when she got home about what
happened?
A.
No.
Q.
Is that for the same reason you described earlier?
A.
Yes.
Q.
Did Epstein end up paying for
to go on a
trip to Thailand that summer?
A.
Yes.
Q.
Did
have any contact with Maxwell or Epstein
after that trip?
A.
Not that she recalled.
Q.
When you interviewed
what was her demeanor
like when she described her interactions with
Jeffrey Epstein and Ghislaine Maxwell?
A.
She became upset, emotional.
Q.
Is
currently pursuing a civil lawsuit
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against Maxwell and Epstein's estate?
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A.
Yes, she is.
Q.
What does
do for a living now?
A.
She's a psychologist who works with trauma
victims.
Q.
During the course of this investigation, have you
interviewed someone named
A.
Yes.
Q.
For today's purposes, I'm just going to refer to
her as
How many times have you interviewed
approximately?
A.
Approximately three times.
Q.
Turning to the next slide. Is this a photograph
of
that she provided to you?
A.
Yes.
Q.
And did she tell you that this was taken when she
was in -- approximately 16 or 17 years old?
A.
Yes.
Q.
Is
date of birth
A.
Yes.
Q.
Did
grow up in England?
A.
Yes, she did.
Q.
Did she tell you that there came a point when she
met Ghislaine Maxwell when she was about 17?
A.
Yes.
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Q.
How did she tell you that they met?
A.
She said they met through a mutual friend.
Did she tell you that this would've happened in 4
around 1994 or 1995?
A.
Yes.
Q.
And is that within the same time period that we've
been talking about today?
A.
Yes.
Q.
What happened after she was introduced to
Ghislaine Maxwell from what she told you?
A.
She said Maxwell treated her like they were
sisters. Her quote was, "like naughty school girls" is how
Maxwell treated with -- her.
Q.
Did she tell you that Maxwell seemed to
immediately take an interest in her?
A.
Yes.
Q.
Did she tell you that they began spending time
together in London?
A.
Yes.
Q.
And just to be clear, was Maxwell in her 30's
while this was happening?
A.
Yes.
Q.
Did Maxwell -- did
ever remember Maxwell
ever talk about having a boyfriend named Jeffrey Epstein?
A.
Yes.
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What did she tell
about that?
A.
Maxwell told
that Epstein was going to
like her.
Q.
Did there come a time when she was 17 that
described that Maxwell introduced her to Jeffrey Epstein?
A.
Yes.
Q.
How did she describe that occurring?
A.
Epstein had flown to London. He was at Maxwell's
residence in London and Maxwell had called
over. So
went over and when she got there, Maxwell was saying
to Epstein kind of -- the words
used was giving him
a resume of her attributes. Saying she's so pretty, she's
so strong, and then Maxwell asked her to give Epstein a
massage.
Q.
Now, you testified just a moment ago that Maxwell
-- that
described to you that Maxwell asked her to
give Epstein a massage during this first meeting. Is that
correct?
A.
Yes.
Q.
Did Maxwell say to her in sum and substance since
you're so strong I'd appreciate it if you give Jeffrey a
massage because he needs a massage every day or I get in
trouble?
A.
Yes, she said that.
Q.
Is that what
said to you in sum and
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substance?
A.
Yes.
Q.
When that happened, did
remember Maxwell
leading her to a room in the house?
A.
Yes.
Q•
What happened?
A.
When
went in the room, Epstein was in a
robe. He took his robe off and she started massaging him,
and then he touched
penis.
Q.
What does
did this?
A.
Don't be frigid.
Q.
and pulled her hand to his
remember Epstein saying when he
What was her reaction to this happening from what
she told you?
A.
She was taken back by it.
Q.
When this episode ended and
left the room
did she tell you that she remembered Maxwell being just
outside the room when she left?
A.
Yes.
4•
Did she remember Maxwell saying to her, did you
have fun? Did he like it?
A.
Yes.
Q.
Does she remember Maxwell calling her several days
afterwards or at some short period of time afterwards?
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A.
Yes, she did.
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Q.
Did
remember Maxwell saying to her on the
phone call in sum and substance, well, aren't you a clever
girl, Jeffrey was very impressed?
A.
Yes.
Q.
Shortly after this incident, does she remember
Maxwell asking her to come back over to the house?
A.
Yes.
Q.
And when she got there did she tell you she
remembered Maxwell saying to her, in substance, thank God
you're here; if it's not you or someone it falls to me?
A.
Yes.
4•
Does she remember Maxwell bringing her up the
stairs to the house on that occasion?
A.
Yes, she did.
Q.
What does she remember happening when Maxwell
opened the door to the room?
A.
Epstein was standing there nude.
4•
Does she remember Maxwell then saying I'll leave
you guys to it?
A.
Yes.
Q.
After these first two encounters, did Epstein and
Maxwell invite
to travel with them to Palm
Beach, U.S. Virgin Islands, Paris, and New York for the next
several years?
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A.
Yes, they did.
Q.
Does she remember whether these trips began before
or after her 18th birthday?
A.
She couldn't remember specifically.
Q.
Before these trips started, you were describing
earlier when
told you about the time that she spent
with Maxwell when they first met when she was 17. Is that
right?
A.
Yes.
Q.
During these conversations when she would spend
time with Maxwell, did
remember talking with her
about her life and her family, and her personal
circumstances with Maxwell?
A.
Yes.
Q.
Now, you testified a moment ago that
told
you that at some point she began traveling with Maxwell and
Epstein, and she wasn't sure whether or not whether these
trips started before she turned 18. Is that right?
A.
Yes.
Q.
Did
describe to you that Epstein sexually
abused her during these trips, typically in the context of a
sexualized massage?
A.
Yes, he did.
Q.
Did Epstein give her money?
A.
Yes.
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Q.
Did she tell you that he would give her cash?
A.
Yes.
Q.
Did she describe to you that the abuse included,
among other things, Epstein groping her and using a massager
device on her genitals?
A.
Yes.
Q.
And was the massager device like a vibrator?
A.
Yes, it was.
Q.
From what
told you, was Maxwell in the
room during these encounters?
A.
Maxwell wasn't in the room.
Q.
What did she tell you would typically happen when
left the room after these episodes; was Maxwell
typically nearby?
A.
Yes. She was usually right near the room.
Q.
Does she remember Maxwell asking her, after she'd
leave the room from one of these sessions, 'how was it, is
he happy?'
A.
Yes.
Q.
Did she also tell you that she remembers Maxwell
telling her at some point, in sum and substance, 'you know
how he is when he's not happy and you know what makes him
happy, he has to have sex all the time, he's like a super
hero?'
A.
Yes, she said that.
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Q.
Did
tell you about an incident that
occurred after she turned 18 in Palm Beach when she was
staying at the Palm Beach house?
A.
Yes.
Q.
Did the incident she described to you involve a
school-girl outfit?
A.
Yes, it did.
Q.
Could you please describe for the grand jury what
told you about that incident?
A.
said that Maxwell had shown her to a
bedroom and on the bed was a school-girl outfit and Maxwell
told her when --
confronted her about it and Maxwell
said 'well, I thought it would be adorable if you gave
Jeffrey his tea in this.' So
felt like she had to
put it on so she put it on, took Epstein his tea, and
Epstein then slapped her on the buttocks and reached under
the skirt and touched her.
Q.
What was her demeanor like when she described this
incident to you?
A.
She was crying; she was very upset.
Q.
When
described seeing the school-girl
outfit and talking to Maxwell about it, did she remember
Maxwell telling her 'don't be so frigid?'
A.
Yes.
Q.
Does she remember that later in the day, after she
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had delivered Epstein his tea and he assaulted her, does she
remember Maxwell telling her 'I heard you did well?'
A.
Yes.
Q.
During the years that
was in contact with
Maxwell and Epstein did she remember whether Maxwell would
ever ask her if she knew any other girls who could massage
Epstein?
A.
Yes.
Q.
Does she remember Maxwell saying, in sum and
substance, 'do you know anyone who can give him a blow job
today; I don't feel like it?'
A.
Yes.
Q.
Does she remember Maxwell saying, when she asked
her to bring other girls, that they have to look young at
least?
A.
Yes.
Q.
From your conversations with
did she tell
you whether or not she ever brought any other girls?
A.
didn't bring any girls.
Q.
Did she tell you why not?
A.
She didn't want anyone else to go through that.
Q.
From your interviews with
did she tell you
that there came a time when she was in her early 20s when
she stopped traveling with Maxwell and Epstein?
A.
Yes.
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Q.
Was she struggling with substance abuse at tha
point?
A.
Yes, she was.
Q•
Did she tell you that she got sober in her 20s?
A.
Yes, she did.
Q.
What is her current profession?
A.
She runs a non-profit for people who struggle with
addiction and trauma.
Q.
Did
provide you with several emails that
she exchanged with Epstein in the early 2000s?
A.
Yes, she did.
Q.
And were those emails very friendly in tone?
A.
Yes, they were.
Q.
What did she say to you when you talked with her
about those emails?
A.
She said she didn't, at the time, want to
acknowledge what was going on to her; that looking back on
it's different.
Q.
Did your squad at the FBI execute a search warrant
at Jeffery Epstein's townhouse in Manhattan in July 2019?
A.
Yes.
Q.
Did you personally participate in the search of
Epstein's residence?
A.
Yes, I did.
Q.
Did the townhouse include a massage room?
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A.
Yes.
Q.
Have you yourself been in that massage room?
A.
Yes, I have.
Q.
Could you please describe for the grand jury what
that massage room looked like?
A.
It was dark. It had dark draperies covering the
windows. There was a massage table. There were oils.
There was a hand-held massager in there along with
handcuffs, a whip, and along the walls were nude photographs
of young females.
Q.
I believe you testified a moment ago tha-
told you that there was a time when Maxwell
asked her to wear a school-girl outfit for Epstein when they
were in Palm Beach. Did you find a school-girl outfit in
Epstein's New York townhouse?
A.
Yes, we did.
Q.
Where did you find it?
A.
It was found in a room next to the massage room.
Q.
And to be clear, did the FBI find sex toys during
the search?
A.
Yes.
Q.
What was found?
A.
Butt plugs, dildo, vibrators.
Q.
We've talked about three minor girls today,
and
is that right?
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A.
Yes.
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Q.
Have you reviewed the proposed indictment, marked
Grand Jury Exhibit 1?
A.
Yes, I have.
Q.
Is
the individual referred to as Victim 1 in
the proposed indictment?
A.
Yes.
Q.
Is
the individual referred to as Victim 2 in
the proposed indictment?
A.
Yes.
Q.
Is
the individual referred to as Victim 3
in the indictment?
A.
Yes.
Q.
During all of Maxwell's interactions with the
victims when they were underage girls, based on the
timeframe and your knowledge of Maxwell's birth date, was
she in her 30s?
A.
Yes, she was.
Q.
Just one moment. All right. Switching gears.
Have you become aware that in or about 2016 Maxwell gave
sworn testimony in a civil deposition in connection with a
lawsuit?
A.
Yes.
Q.
Could you please explain for the grand jury what
is a deposition?
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A.
It is a statement made under oath.
Q.
And in the course of civil litigation is it common
for witnesses or the parties of the lawsuit to give a
deposition under oath where they testify about the substance
of the case?
A.
Yes.
Q.
And is deposition testimony live and in person and
under oath?
A.
Yes.
Q.
Is a court reporter present when a deposition
takes place?
A.
Yes.
Q.
Now before we talk about Maxwell's deposition
testimony, I want to talk with you about the lawsuit that
the testimony was about.
Have you become aware that in or
about 2015 an individual named
filed a
lawsuit against Ghislaine Maxwell here in the Southern
District of New York?
A.
Yes.
Q.
And was
suing Maxwell for defamation?
A.
Yes, she was.
Q.
Was the lawsuit captioned
against
Ghislaine Maxwell with Docket Number 15-CV-7433 here in the
Southern District of New York?
A.
Yes.
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Q.
Generally speaking, in broad strokes, what was the
lawsuit about? What was the claim that
was bringing
against Maxwell?
A.
had stated that she had been sexually
abused by Epstein and Maxwell as a minor. Maxwell came
forward publically and called her a liar. So
her for defamation.
MS.
So just a small legal instruction on
this topic. Ladies and gentleman, I instruct you that the
allegations in the lawsuit are not being presented to you as
evidence that those incidents occurred. I instruct you that
you should not consider those allegations for their truth;
instead, the circumstances of the lawsuit are being
presented to you so that you can consider the context of the
case and the circumstances under which Maxwell made
statements under oath.
BY MS.
Q.
Turning back to the deposition. Did Maxwell's
deposition take place over two different days?
A.
Yes.
Q.
On both days did she give testimony in Manhattan?
A.
Yes, she did.
Q.
Is that where the deposition took place?
A.
Yes.
Q.
And on both days was Maxwell sworn under oath?
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Yes.
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Q.
If you could flip through the remaining slides in
the presentation. Do those slides contain true and accurate
excerpts of the transcript of that deposition?
A.
Yes.
Q.
Turning to the next slide, is this the cover page
of the transcript of the first deposition that took place on
April 22, 2016?
A.
Yes.
Q.
And does it have the case caption on it?
A.
Yes, it does.
Q.
Turning to the next slide, is this an excerpt from
the transcript?
A.
Yes.
Q.
I imagine the grand juries can't read it from
their seats so if you could read it with me, I'll read the
questions and if you could read the answers.
Question: "Did Jeffrey Epstein have a scheme to
recruit underage girls for underage massages?"
And it appears there was an objection from the
lawyer.
Question: "If you know."
A.
Answer: "I don't know what you are talking about."
Q.
Just to be clear with the question and answer, is
the answer here Maxwell's testimony?
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A.
Yes.
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Q.
Just to be clear, you testified earlier that
participated in sexualized massages with Epstein and
Maxwell; is that right?
A.
Yes.
Q.
And
was a minor when that occurred?
A.
Yes.
Q.
And did you also testify earlier that Maxwell --
that
told you that Maxwell asked her to
give Epstein massages when she was a minor?
A.
Yes.
Q.
If you could turn to the next slide, please.
this another excerpt from that same deposition?
A.
Yes, it is.
Q.
All right. I'll read the question and you can
read the answer.
Question: "List all the people under the age of 18
that you've interacted with at any of Jeffrey Epstein's
properties?"
A.
Maxwell's answer: "I'm not aware of anybody that I
interacted with, other than obviously
who was 1.7
at this point."
Q.
Just to be clear, you testified earlier about two
girls under the age of 18 who interacted with Maxwell at
Epstein's properties; is that correct?
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A.
Yes.
Q.
And those individuals were
and
who told you that, correct?
A.
Yes, that's correct.
Q.
Turning to the next slide, is this the cover page
of the transcript from the deposition that took place on
July 22, 2016?
A.
Yes.
Q.
And again, was this Maxwell giving testimony as
part of the testimony under oath here in Manhattan?
A.
Yes.
Q.
If you could please turn to the next slide. Is
that an excerpt -- are these two excerpts from that
deposition?
A.
Yes.
Q.
Again, I'll read the questions if you could please
read the answers.
Question: "Were you aware of the presence of sex
toys or devices used in sexual activities in Mr. Epstein's
Palm Beach house?"
There's an objection from the lawyer.
A.
Maxwell's answer: "No, not that I recall."
Q.
"Do you know whether Mr. Epstein possessed sex
toys or devices used in sexual activities?"
There's an objection from the lawyer.
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A.
Maxwell's answer: "No."
Q.
Just to be clear, you testified earlier that
told you he found sex toys in the massage room
in Palm Beach and also that he had seen that Maxwell had a
basket of sex toys in her closet there; is that correct?
A.
Yes, that's correct.
Q.
And is it correct that you testified earlier that
Epstein had used a vibrator on
is that
correct?
A.
Yes, that's correct.
Q.
And did you also testify earlier that
told you he did that, as well?
A.
Yes, that's correct.
Q.
And did you also testify earlier that sex toys
were found by the police in the Palm Beach house in 2005; is
that right?
A.
Yes.
Q.
And did you also testify earlier that the FBI
found sex toys in Epstein's New York City townhouse in 2019?
A.
Yes, that's correct.
Q.
If you could please turn to the next slide. This
is on page 27. Is this -- are these also excerpts from that
same deposition?
A.
Yes.
Q•
Again, I'll read the questions if you could please
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read the answers.
Questions: "Other than yourself, and the blonde
and brunette that you have identified as having been
involved in three-way sexual activities, with whom did
Mr. Epstein have sexual activities?"
There's an objection from the lawyer.
A.
Maxwell's answer: "I wasn't aware that he was
having sexual activities with anyone when I was with him
other than myself."
Q.
Question: "I want to be sure that I'm clear, is i-
your testimony that in the 1990s and 2000s you were not
aware that Mr. Epstein was having sexual activities with
anyone other than yourself and the blonde and brunette on
those few occasions when they were involved with you?"
A.
Maxwell's answer: "That is my testimony. That is
correct."
Q.
Have you reviewed the deposition transcript --
A.
Yes.
Q.
-- in full? Now, the excerpt we just read has a
reference to a blonde and brunette. Are those individuals
completely different from the individuals we've been talking
about today?
A.
Yes.
Q.
Just to be clear, is it correct that you testified
earlier that
and
told you that Epstein
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sexually abused them repeatedly; is that correct?
A.
Yes.
Q.
And did you also testify earlier that Maxwell was
occasionally present when Epstein was abusing
based
on what she told you?
A.
Yes, that's correct.
Q.
Turning to the next slide, is this also an excerpt
from the same deposition?
A.
I'm sorry?
Q.
I'm so sorry. Turning to the next slide, on page
28, is this also an excerpt from the same deposition?
A.
Yes.
Q.
Thank you. Okay. Again, if we could read that
together I'll take the question if you could take the
answer.
Question: "Let's just tie that down. Is it your
testimony that you've never given anybody a massage?"
A.
Maxwell's answer: "I have not given anyone a
massage."
Q.
"You never gave Mr. Epstein a massage; is that
your testimony?"
A.
Maxwell's answer: "That is my testimony."
Q.
"You never gave
a massage; is that
your testimony?"
A.
Maxwell's answer: "I never gave
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massage."
2
Q.
Just to be clear, as you testified earlier, is it
3
correct that
told you that Maxwell gave her a
4
massage when they were in New Mexico?
5
A.
Yes.
6
Q.
Have you told the grand jury everything that you
7
know about this case or have you just answered the questions
8
that I've asked?
9
A.
I've just answered the questions you've asked.
10
Q.
And when you testified about the documents that
11
you reviewed or the conversations that you had with others,
12
were you testifying to the exact words used or just the
13
substance of the documents or conversations?
14
A.
The substance?
15
Q.
And are you willing to return to the grand jury if
16
the grand jury has any further questions for you?
17
A.
Yes.
18
MS.
With the Foreperson's permission I'd
19
ask that the witness be excused at this time.
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FOREPERSON.
You're excused.
21
MS.
Thank you.
22
(Witness Excused)
23
(Time Noted: 11:41 a.m.)
24
(Colloquy Follows)
25
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area 301-261-1902
Balt. & Annap. 410-974-0947
GM_GLSDNY_00000205
EFTA00008705
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area 301-261-1902
Balt. & Annap. 410-974-0947
GM_GLSDNY_00000206
EFTA00008706
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CERTIFICATE
I hereby certify that the foregoing is a true and
accurate transcription, to the best of my skill and ability,
from my electronic notes of this proceeding.
July 6, 2020
Date
Acting Grand Jury Reporter
Free State Reporting, Inc.
FREE STATE REPORTING, INC.
Court Reporting Transcription
D.C. Area 301-261-1902
Balt. & Annap. 410-974-0947
GM_GLSDN Y_00000207
EFTA00008707
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