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120 LBUCmaxl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Trial New York, N.Y. November 30, 2021 8:50 a.m. HON. ALISON J. NATHAN, APPEARANCES DAMIAN United States Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM -and- RENATO STABILE Also Present: District Judge , FBI NYPD Sunny Drescher, Paralegal, U.S. Attorney's Office Ann Lundberg, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068582 121 LBUCmaxl 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: Looks like we have everybody. Matters to take up, counsel. MS. COMEY: Nothing from the government, your Honor. MR. EVERDELL: Nothing, your Honor, but note we have put the folders under the chairs as we agreed yesterday. THE COURT: And the government has seen -- well, I guess you didn't see them, but you are aware of them? MS. COMEY: We have seen the outside of the folders, your Honor. THE COURT: Mr. Everdell, there are two folders. MR. EVERDELL: There is one folder with two documents. THE COURT: One folder with two documents. And then, as we discussed, he'll direct us as necessary to make sure everybody can follow along. I think the only thing I wanted to raise is that, assuming the timing works out, I would like to speak with the juror who had the trip planned, with the court reporter present, of course, to see if there is additional information about the ability to change that plan to make sure it's not weighing on my mind. Without objection to that? MS. COMEY: No objection, your Honor. MR. EVERDELL: No objection, your Honor. THE COURT: So if they're here a little on the early side, I'll do that before, otherwise I'll do it at the break. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068583 122 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. STERNHEIM: Judge, I have an issue I would prefer to raise at sidebar very quickly. THE COURT: Okay. (Continued on next page) (Pages 123 to 125 SEALED) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068584 EFTA00068585 EFTA00068586 EFTA00068587 126 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (In open court) THE COURT: I'll note I received a report from the district executive office that, once again, today, everyone who's appearing to watch the trial is being accommodated, either in this court or in the overflow courtrooms. There are empty seats available for everybody who wishes to observe the public trial. With that, anything else before we wait for the jurors? MS. COMEY: No, thank you, your Honor. MR. EVERDELL: No, your Honor. THE COURT: Thank you so much. (Continued on next page) (Pages 127 to 129 SEALED) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068588 EFTA00068589 EFTA00068590 EFTA00068591 130 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (In open court) THE COURT: I spoke to the juror with the travel plans and the information is that dates can't be changed and they can't cancel and it would be of some significant hardship. The juror is, I think, more concerned about the spouse's reaction. At one point, they did say, "If I have to proceed, I can. I understand." On the other hand, they mentioned some level of distraction and concern. So, I'll hear your suggestion. MR. PAGLIUCA: Your Honor, I understood that the Court was going to -- there were two options the Court was considering. One was seeing if the juror could change plans, and if that didn't work, the Court was considering breaking for the juror's anticipated vacation. That's what I understood the Court to say. If the juror can't change the plans, our preference would be, not frankly that we want to delay the trial, but my preference would be to keep the juror and accommodate the juror's travel plans, your Honor. MS. COMEY: Your Honor, the government's preference would be to keep the trial moving, keep the trial days as scheduled, and excuse the juror if those days become necessary for this case. THE COURT: Just to be clear about what we're talking about. So given the holiday, we're not going to sit the 23rd SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068592 131 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 or the 24th, and it's the weekend, Christmas weekend, 25th, 26th. The juror would be gone the 27th, 28th, would not make sense to return for one day of that week. So, really, it would be a 10-day break in the trial. I don't think that makes sense, Mr. Pagliuca. I know I mentioned that, but I'm not sure I had that fully in mind at the time, and that's practically what we would be talking about. MR. PAGLIUCA: I appreciate that, your Honor. Again, I frankly don't want to delay this trial. The intention here is, first, I don't know which juror this is, and that would make a difference in my analysis here, frankly. THE COURT: I mean, to be candid, that's why I'm not telling you, because -- I'm not telling either side because 1 think under the veil of ignorance is a better place for everybody to be. MR. PAGLIUCA: Let me be more specific, your Honor. I'm not asking to know the specific juror, but what would make a large difference to me is whether this person is in the alternate pool versus the main pool of jurors. I would have less of a problem excusing the juror if the juror was in the alternate pool as opposed to the main pool. And the reason 1 say that is we carefully exercised peremptory challenges in this case, both to the main pool and the alternate pool. Had we understood that if this juror's plans couldn't be changed, we would have made a different choice while the entire venire SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068593 132 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 was still available and we would have gone with the choice of seating the one juror, the number I don't remember off the top of my head, but the one juror who had dropped off of the alternate pool as opposed to doing something else. That would have been the choice we would have made at that point. THE COURT: But you actually had that option with this information available to you yesterday. The government supported that move of having seven alternates and you declined that option. So even with the information that we might face this issue, you chose not to go that route. MR. PAGLIUCA: But, your Honor, my view, that's because we understood that the Court was not going to excuse the juror. That was my clear understanding. The transcript says whatever it says. THE COURT: Fair enough. It was not with a 10-day pause in the trial in mind, and I suppose the new information is the juror telling me that there is some level of distraction as a result of this concern, which was not what was indicated yesterday when the discussion was that they would make every effort to try to move it. Having apparently now made that effort, they can't move it. MR. PAGLIUCA: I understand, your Honor. I think my position is clear and the Court will do as the Court sees fit. THE COURT: I don't want to do a 10-day break in the middle of the trial. That doesn't make sense. I think, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068594 133 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 really, the option is just to encourage them to take a last shot at any effort to move it, but I think we're going to end up in the same place. I'm wishing we had kept that additional juror. I think I have to excuse the juror. I'll have a discussion in which I just say one more time, is there anything else to explore regarding cancellation or moving it, and if the answer to that is no, I think I will excuse the juror. I'll step down. (Continued on next page) (Pages 134 to 136 SEALED) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068595 EFTA00068596 EFTA00068597 EFTA00068598 137 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (In open court) THE COURT: I had an additional conversation with the juror. He was confident there was no way to move it. He said he could cancel it, they would lose money, it was a burden, he was distracted by it, so I had to excuse juror number 58. All our other jurors are here. They're just finishing up settling in. So we can proceed as soon as Ms. brings them out. Anything to take up? MS. COMEY: No, thank you, your Honor. MR. EVERDELL: No, your Honor. THE COURT: I think they'll be ready momentarily. So I'll sit. MS. COMEY: Your Honor, would you like the witness in the witness box? THE COURT: That would be great. Thank you. (Witness present) We need about two more minutes. (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068599 138 LBUCmax1 - direct 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: Thank you, members of the jury. I hope you had a pleasant evening. Thank you so much for being here ready to go on time. I greatly appreciate it. We will resume with the direct examination of Mr. Mr. , I remind you are under oath. THE WITNESS: Thank you, your Honor. THE COURT: Ms. Comey, you may proceed. MS. COMEY: Thank you, your Honor. , resumed. DIRECT EXAMINATION CONTINUED BY MS. COMEY: Q. Good morning, Mr. A. Good morning, Ms. Comey. Q. I'd like to pick up where we left off yesterday talking about Mr. Epstein's employees and his office. THE COURT: Ms. Comey, could you adjust the microphone a little bit higher. MS. COMEY: Yes. Thank you, your Honor. Is this better? THE COURT: Yes, that's better. MS. COMEY: Thank you, your Honor. Q. Mr. , I'd like to pick up where we left off yesterday talking about Mr. Epstein's office and his employees. A. Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068600 139 LBUCmaxl - direct Q. Based on your interactions with and observations of 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Mr. Epstein's employees, where in the hierarchy did Ms. Maxwell fall? A. Ms. Maxwell was number 2. It was definitely Mr. Epstein was a big number 1. Q. What makes you say that Ms. Maxwell was the number 2 in your experience? A. She was the one that pretty much handled most of the finance, my expenses, spending in the office. Q. What, if any, assistants did Mr. Epstein have, other than Ms. Maxwell? A. As far as secretaries or personal assistants, is that what you mean? Q. Personal assistants. A. He had an array of personal assistants, almost like professional shoppers, because there was a lot of items that needed to be purchased for all of the properties that were being acquired. So there were several people that were personal assistants. Q. How about Ms. Maxwell, did she have personal assistants? A. Yes, I would consider Ms. Maxwell a personal assistant. Q. My question was, did Ms. Maxwell have her own personal assistants. A. Oh, I see. Yes, she had assistants, as well. Q. What were the names of some of the personal assistants you SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068601 140 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 LBUCmax1 - direct remember? A. Throughout the entire or we're talking 1994 to '04? Q. Yes. A. The first one that comes to mind would be Then there was another woman named , the last name escapes me. Those are the two that are coming to mind right away. Q. About when did you meet A. It had to have been the late '90s to my recollection. Q. What did look like between when you first met her and the mid 2000s? A. She looked the same except for different hair lengths and maybe a little different hair color. MS. COMEY: Ms. Drescher, I would like to please pull up for the witness, the parties, and the Court Government Exhibits 327 and 310, please. Q. Mr. , do you recognize these? A. Yes, I do. Q. What are they? A. The photo on the left is Ms. with the green dress. And then to the right in the photo, it's actually a photo of myself at the front of the aircraft. Then there is Mr. Epstein. And that's also in the photo. MS. COMEY: Your Honor, the government offers these two exhibits in evidence. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068602 141 LBUCmaxl - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. EVERDELL: No objection. THE COURT: Government Exhibit 327 and 310 are admitted. You may publish. (Government's Exhibits 327, 310 received in evidence) MS. COMEY: Thank you, your Honor. BY MS. COMEY: Q. While Ms. Drescher puts these up on the screen for the jury, Mr. , could you tell us, for Government Exhibit 310, the photo on the right, could you tell us what we see in that photo? A. In that photo, that's the one with the aircraft in it? Q. Yes. A. That appears to be a photo of -- it was probably the late '90s, mid to late '90s, Mr. Epstein purchased that twin engine Cessna 421, and he had a runway at the ranch. So that photo appears to be taken at the ranch at one of the ends of the runway, judging by the square, you know, the asphalt bottom with the square on top there, because it was a dirt runway and at the end of the runway, there was an asphalt base to turn the aircraft around. But in the photo, obviously, it's a picture of me with the luggage and Mr. Epstein and Ms. MS. COMEY: Thank you. We can take that down, Ms. Drescher. I would like to now pull up for the witness, the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068603 142 LBUCmaxl - direct Court, and the parties Government Exhibits 334 and 335, please. 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 recognize these, Mr. A. Yes, I do. Q. Who do we see starting in Government Exhibit 334, the one on the left? A. The one on the left is a picture of Ms. Maxwell and to the right of her is a photo of Ms. Q. How about Government Exhibit 335, who do we see in that exhibit? A. The same, Ms. Maxwell on the left and Ms. on the right. MS. COMEY: Your Honor, the government offers these in evidence. MR. EVERDELL: No objection. THE COURT: Government 334 and 335 are admitted and you may publish. (Government's Exhibits 334, 335 received in evidence) MS. COMEY: Thank you, your Honor. Ms. Drescher, could we please put those up for the jury. We can take those down. Thank you. Q. Mr. , about when do you recall first visiting Mr. Epstein's ranch in New Mexico? A. I believe the ranch -- his ranch was purchased in approximately 1994. I'd call it the mid '90s. Q. About how often did you visit that ranch during your SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068604 143 LBUCmax1 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 employment with Mr. Epstein? A. I visited that ranch every visit that Mr. Epstein had to the ranch. Q. And about how often did Mr. Epstein go to the ranch? A. It wasn't that often. Certainly not enough. It was probably, maybe five, six times a year. Q. What was that ranch called? A. It was called Zorro Ranch. MS. COMEY: Ms. Drescher, would you please pull up Government Exhibit 328 for the witness, the Court, and the parties. Q. Do you recognize this? A. Yes, I do. Q. What is it? A. That is a photo of the entrance driveway to Mr. Epstein's main property on Zorro Ranch. Q. Is this a fair and accurate depiction of a portion of Mr. Epstein's property in New Mexico? A. Yes, it is. MS. COMEY: Your Honor, the government offers this in evidence. publish. MR. EVERDELL: No objection. THE COURT: Government 328 is admitted and you may (Government's Exhibit 328 received in evidence) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068605 114 LBUCmax1 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. COMEY: Thank you, your Honor. Ms. Drescher, could we please show this to the jurors. BY MS. COMEY: Q. While that's up, Mr. , would you please describe the ranch property that Mr. Epstein owned in New Mexico. A. The property in general, the whole -- Q. Yes, please, the whole property. A. The whole property. You started entering the ranch off of Highway 41 in Stanley, New Mexico. So you drove down a dirt road approximately a half mile and you would enter an area which the ranch called the Ranch Central, and that housed many buildings. Just to the left, there were two homes, and that was mainly for the ranch staff that lived on the ranch for support. So there were two homes to the left. To the right, there was a small office for the ranch. And then you continued, you're still in the Ranch Central area. And then you went still further into the ranch, probably a hundred feet. And then on the right side, there was a building that had rooms, there was approximately five bedrooms with a western motif on the outside. And that would be for whether it be, the -- any of the guests that would have came on the aircraft to stay, the chef, the pilots all still stayed there. And then it was a motel style building. And then across the street from that, there was a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068606 145 LBUCmaxl - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 firehouse with a fire engine, and that also had several garages for all the maintenance for the ranch. And then to the right of that, there was a greenhouse for growing vegetables, et cetera. And then across the street from the greenhouse, there was a stable with a stable area that housed -- it had to have been 10 to 15 horses. That was the ranch central area. And then you continued through Ranch Central and continued up a dirt road approximately, I don't know, it had to have been two or three miles and you got to a Y in the road where if you went to the left -- I'll take you to the left first. Once you got to the Y in the road, you took a left and actually you're going to pass by, during that drive, a runway we had on the property, which, as you saw, the twin-engine Cessna was parked on. So we had a runway and a hangar to house the aircraft. So you pass the runway and you continued up the road to -- it was called the lodge. It was actually the first home site that was selected to build the main house, and that was a triple-wide trailer that also had a western faux facade built around it. Once you went past the triple-wide lodge, you went about, you know, maybe a thousand yards and there was a log cabin that was built up on the cliff, because both the lodge and the log cabin were on cliffs that overlooked the ravine to the north. And we go back to the Y in the road that brought you SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068607 146 LBUCmaxl - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 past the runway. You continued up that road where you saw the photo with the Z on the entrance. That was the main entrance to the main house. And then the main house was built eventually on that cliff overlooking the ravine. (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068608 117 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. COMEY: Q. In total approximately how many acres was Mr. Epstein's ranch? A. It was approximately 10,000 acres. I know there was some state land included in it, but everybody said it was around 10,000 acres. Q. And all of the structures you just described, were they all located on that property owned by Mr. Epstein? A. Yes. Q. Have you been inside the main house on the ranch property? A. Yes, I have. Q. For what purpose? A. Several purposes. A lot of the times -- it was on occasion I would meet with Mr. Epstein and discuss future aircraft maintenance or purchases for the aircraft. And then other times would be to pick up and drop off luggage. And that was another residence that I installed a lot of the home theater and audio equipment. He was an audiophile, so he liked very high-quality music; so I installed a home theater, like I had done at the other properties as well. MS. COMEY: Ms. Drescher, can we please pull up Government Exhibits 323 and 706 for the witness, the Court, and the parties. Q. Mr. , do you recognize these? A. Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068609 148 LBUVMAX2 - 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 are they? A. Those are exterior photos of the main house at Zorro Ranch. Q. Are these fair and accurate depictions of the exterior of the main house on Mr. Epstein's Zorro Ranch? A. Yes, they are. MS. COMEY: Your Honor, the government offers these in evidence. MR. EVERDELL: No objection. THE COURT: Government 323 and 706 are admitted and you may publish. (Government's Exhibits 323, 706 received in evidence) MS. COMEY: Thank you, your Honor. Q. While Ms. Drescher shows those to the jury, I'd like to ask you, Mr. to please describe the interior of this main residence. A. Okay. As you come into the entrance, I'll take you to the front door, since it's a quite large property. You entered in the front door, and I'll take it starting to the left. If you enter the main door at the front of the house, you made a left, and the house was actually a square house with an open courtyard in the middle that had access to the sun. So it was a -- virtually a square house that circled the courtyard in the middle. So we make a left, and that brought you down a hallway. And the first room you came to was the main living SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068610 149 LBUVMAX2 - direct room, which was tremendous in size; it had to have been 200 feet by 50 feet, and it had an extremely large picture window 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that overlooked the ravine or the house -- where the house you know, to take advantage of the view. Inside that room had a tremendous stereo system that I installed. And then came out of that living room and you continued down the hallway. At the corner of that library with a desk in it where also housed an impressive audio was, we you hallway there was Mr. Epstein's he spent most of his time, and system. You came out of that room and that led you -- now you're on the -- you're still walking down circling the house. That brought you into what was the dining room for the house. And he didn't use it as a dining room actually; we made that into a movie theater room with a projector that came down. So that was actually the home theater of the house. And you continued through that room. That brought you into a butler's pantry. And then from the butler's pantry, you went into the main kitchen, which also had a dining room table. Once you went through the kitchen, that brought you to another room, which was kind of a morning room, just a small little family room off to the kitchen. As you continue around, there was a staircase that would -- I'll take you downstairs first. You went downstairs. And that brought you to a gym and an indoor swimming pool that also led to the outside patio. Once you came -- I'll bring you SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068611 150 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 back up the stairs. We're on the main level. And then there was another staircase that brought you upstairs that housed the master bedroom, as well as approximately three -- three or four guest bedrooms upstairs. Q. When you first visited this ranch, was the main house you just described completed? A. No, it was not. Q. About when was construction on this main house completed? A. It was under construction for a while, that's why he had the triple-wide trailer to stay during the construction. But I would estimate probably late '90s, maybe 2000 is when the house got finished. Q. And so in the mid to late '90s, when you visited the ranch, where did Mr. Epstein stay? A. He would stay up at the lodge or the triple-wide mobile home I described. Q. Could you describe what the interior of that triple-wide lodge looked like. A. Sure. As I mentioned, it was a triple-wide trailer that had a wood western facade built around it to make it a little more attractive than just a mobile home. Once you went in the front door, there was a large wooden deck in the front of the house like you would see in a western movie. And you went in the front door, you walked into the living room which had a fireplace to the left. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068612 151 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 And then if you continued past the living room and made your left turn to the left side of the home, that was the master bedroom. And then you came back into the living room you continued straight ahead from the entrance door, that brought you into a kitchen that led to a large outside deck that overlooked the ravine. And then you came back into the kitchen, and to the right side of the house there were -- there was a small -- or a family room to the right side and also there was two guest bedrooms there. Q. Did the inside of this structure look like a trailer? A. Not the way it was decorated. It was very high-end. Q. What airport did you fly to when Mr. Epstein was staying on this ranch? A. Typically, depending upon what aircraft he selected, if we were flying the Gulfstream, which is a smaller, lighter aircraft, we would use Santa Fe, New Mexico Airport. And if we were flying the Boeing, which is a large airliner, we would fly into Albuquerque due to weight restrictions. Q. I'd like to turn now to Mr. Epstein's Paris property. About when do you remember first visiting Mr. Epstein's apartment in Paris? A. It had to have been maybe the late '90s, Ms. Comey. I couldn't really narrow it down, but it had to have been in the '90s, I would -- yes. Q. About how many times did you visit that apartment while SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068613 152 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 working for Mr. Epstein? A. Not as much as the other properties. On occasion I would go to pick up luggage and drop off luggage at that place. But I would almost say every trip, but we didn't go to Paris that often, so I'll even go as far as saying most every trip. Q. Other than to pick up luggage, did you go to that apartment for any other reason? A. Yeah. I also did some audio work on the home theater that he had in the Paris apartment as well. MS. COMEY: Ms. Drescher, could we please pull up Government Exhibit 705 for the witness, the Court, and the parties. Q. Mr. , do you recognize this? A. Yes. Q. What is it? A. That is the exterior of the Paris apartment. Q. Is this a fair and accurate depiction of the exterior of the building in which Mr. Epstein's apartment was located? A. That is correct, yes, it is. MS. COMEY: Your Honor, the government offers this in evidence. MR. EVERDELL: No objection. THE COURT: GX-705 is admitted and you may publish. (Government's Exhibit 705 received in evidence) MS. COMEY: Thank you, your Honor. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068614 153 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ms. Drescher, would you please show that to the jury. Q. And while that's up, Mr. would you please describe what the inside of this apartment looked like. A. I believe it was on the second or third floor, we're going back a little ways. But it was -- once you went in the front door, it was a little on the unique side. It was a very long type of apartment. Once you went in the front door, there was an entrance foyer. And if you continued straight through that foyer, it would take you into the kitchen. And then to the left of the kitchen, I think, led down to a hallway with some guest bedrooms. Once you came back to the kitchen, to the right there was a dining room. And then to the right of the dining room there was Mr. Epstein's office where he had a home theater set up in his office as well. And then once you came out back into the foyer, I believe if you went to the right, it took you to either more guest bedrooms, and definitely the master bedroom was down the hallway. Q. When Mr. Epstein stayed at this apartment, what airport did you fly out of? A. We flew into Paris-LeBourget. Q. Turning now to Mr. Epstein's island, about when did you first visit that island? A. It was approximately mid to late -- late '90s. Q. And what was that island called? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068615 154 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Little St. James. Q. About how often did you visit Little St. James during your employment for Mr. Epstein? A. Every time we went to the St. Thomas U.S. Virgin Islands, where the island was located. Q. About how often did you fly Mr. Epstein to the U.S. Virgin Islands? A. Had been every week, every ten days, if we weren't elsewhere in the world, but it was a regular destination. Q. And why did you go to the island each time Mr. Epstein went to the Virgin Islands? A. I also flew the helicopter. So when Mr. Epstein would arrive at St. Thomas main airport, I would go get the helicopter and then pick him up and the passengers and fly them to Little St. James Island, as well as, you know, taking luggage and also picking up luggage at the island. And also a very large home theater was installed at that residence as well. Q. Did you install large home theaters in all of Mr. Epstein's residences? A. Yes, I did. Q. Other than helicopter, how else could you get to Little St. James? A. The other option would be boat. MS. COMEY: Ms. Drescher, can we please pull up SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068616 155 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Government Exhibit 346 for the witness, the Court, and the parties. Q. Mr. , do you recognize that? A. Yes. Q. What is it? A. That is an aerial view of Little St. James Island. Q. And does that fairly and accurately depict Little St. James Island? A. Yes, it does. MS. COMEY: Your Honor, the government offers this in evidence. MR. EVERDELL: No objection. THE COURT: Government 346 is admitted. You may publish. (Government's Exhibit 346 received in evidence) MS. COMEY: Thank you, your Honor. We can take that down. Thank you, Ms. Drescher. I'd like to go now to Government Exhibit 308 for the witness, the Court, and the parties please. Q. Mr. , do you recognize this? A. Yes, I do. Q. What is it? A. That is an aerial view of the main property on Little St. James Island. Q. Is this a fair and accurate depiction of a portion of SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068617 156 LBUVMAX2 - direct Mr. Epstein's private island? A. Yes, it is. MS. COMEY: Your Honor, the government offers this in 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 evidence. MR. EVERDELL: No objection. THE COURT: Government 308 is admitted. You may publish. (Government's Exhibit 308 received in evidence) MS. COMEY: Thank you, your Honor. Q. And while Ms. Drescher puts that up for the jury, Mr. , could you tell us what we see in this photograph please? A. That is the main house which appears to be -- and it's located on the north side of the island. But it's a photo of the main house structure on the island. MS. COMEY: I'd like now, please, to go to Government Exhibit 326 for the witness, the Court, and the parties. Q. Mr. , do you recognize this? A. Yes, I do. Q. What is it? A. That is also an aerial view of Little St. James Island's main property home site. Q. And is this a fair and accurate depiction of a portion of Jeffrey Epstein's private island? A. Yes, it is. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068618 157 LBUVMAX2 - direct MS. COMEY: Your Honor, the government offers this in evidence. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. EVERDELL: No objection. THE COURT: GX-326 is admitted. You may publish. (Government's Exhibit 326 received in evidence) MS. COMEY: Thank you, your Honor. Q. And while Ms. Drescher puts this up for the jury, Mr. , would you please tell us what we see in this photograph. A. As far as describing the home or the property? Q. Yes. Could you tell us what we see in the top right-hand corner first and then tell us what we're seeing on the property. A. Oh, gotcha. The top right-hand corner was the boat dock, if you were to arrive by boat. So that was the entrance for guests to arrive by boat. And then if you continued down the highway there, you can't see the helipad, the helipad is still south of that structure. Once you were there, you could take -- you would walk up to the main house up on the top of the hill. Q. Thank you. MS. COMEY: We can take that down. And now, Ms. Drescher, can you please pull up Government Exhibit 703 for the witness, the Court, and the parties. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068619 158 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Mr. , do you recognize this? A. Yes, I do. Q. What is it? A. That is a photo of Little St. James Island. Q. Is this a fair and accurate depiction of an aerial view of the entirety of Little St. James Island? A. Yes, it is. MS. COMEY: Your Honor, the government offers this in evidence. MR. EVERDELL: No objection. THE COURT: Government's 703 is admitted. You may publish. (Government's Exhibit 703 received in evidence) MS. COMEY: Thank you, your Honor. Q. While Ms. Drescher puts this up for the jury, Mr. I want to ask you, did Mr. Epstein own this entire island that we see here? A. To my knowledge, yes. Q. And could you walk us through in a little more detail a description of the island and the property on it. A. Okay. I guess I'll start at the top of the photo. There was a building there that was a library. It used to have a gold dome on it, but that was actually a library inside that building. And then we come down to the right side of the photo, you could see a small pool on the right side of the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068620 159 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 photo which was -- which they call the flag -- or the flagpole pool, which was a tremendous-size pool which also had a cabana built. And that was another office that Mr. Epstein spent a lot of his time working on the phone and computers. And then we're coming down through the beach area. Right dead center of the island you'll see a little blue roof, that was the gym. And inside the gym had a tremendous audio system for working out. There was a large gym inside there. And then you come down further from -- further down -- or you're heading down back to the main house structure, to the left you see a wide open grass area, that was the helipad that if we -- if you arrived by helicopter. Coming further down from that, there are several buildings to the left, you see a blue one, a white one. That housed all of the construction equipment, tractors, dump trucks and such, support equipment for the island. And then we're going to come down further from that to the right. We'll come all the way down to the main house structure which also has a large swimming pool. The house was quite unique. It was pretty much a home that was exploded out, that each building was a room of a house; that guest bedrooms were their own bunaglows. So the kitchen was its own building, the living room was its own building, the master bedroom was its own building. So in order to walk from one to another, you actually walked outside. So SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068621 160 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 it was kind of what I considered like an exploded house. Q. When Mr. Epstein was staying on this island, what airport did you fly into and out of? A. We flew into the main airport in St. Thomas, U.S. Virgin Islands. I believe it's called Charlotte Amalie. MS. COMEY: We can take that down. Thank you, Ms. Drescher. Q. Mr. , what, if any, of Ms. Maxwell's residences did you visit during your employment? A. I think I've been to all of her residence. Q. Could you walk us through each of them chronologically, starting with the first, please. A. Yes. The first time I met Ms. Maxwell, she was in a smaller apartment. We're going back 30 years, so I don't really remember the streets. But then the second apartment I remember a little more, a little more obviously better, which I believe was on 84th Street, which was a nice three-bedroom apartment. And she was there for several years. I did set up a home theater in that apartment as well. And then eventually she purchased a brownstone townhouse, I believe, which was on 65th Street. Q. About when do you remember Ms. Maxwell moving from the smaller apartment to the apartment around 84th Street? A. Had to have been the mid '90s. I don't really have a good, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068622 161 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 accurate estimation on that. Q. And about when do you remember her moving into the brownstone townhouse you mentioned? A. I'd only be guessing if I said the 2000s, but I don't have an exact era. It had to have been in the 2000s, I believe. Q. In what borough were all three of those residences? A. They were in Manhattan. Q. Why did you go to those residences? A. It was -- it was still luggage; we would actually go there to pick up luggage for the flights. I would actually go there sometimes to get an expense report signed. And then also at the brownstone I did -- she had the sixth floor up there that had a home theater that I installed with a flat screen TV, so I would occasionally go there and support, you know, help tune and adjust that. Q. Would you please describe the interior of Ms. Maxwell's brownstone townhouse. A. I believe it was a five or six-story building or home. Yo. entered the front door, it brought you into a courtyard or I should say an entrance foyer. And then once you started -- you walk up the first stairs to the first -- to the first level you got to, that was kind of the living room and also had the kitchen. So in the front of the house of the brownstone was the living room, then there was a dining room, and then further back of that was the kitchen. And then you went to the next SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068623 162 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 level, the second and third floors, I believe were the guest bedrooms and the master bedroom. And then once you got to the top, which, if memory serves me correctly, might have been the fifth floor where we installed a home theater for her. Q. Switching gears. Between 1991 and 2004, what planes did you fly for Mr. Epstein? A. From '91 to 2004? Q. Yes. A. The first aircraft was a Hawker Siddeley, what's called an HS125. Mr. Epstein purchased that. He had that aircraft from '91 till 1994. And then in 1994, he sold that aircraft and he purchased a Gulfstream, which is called the G2B. And he had the Gulfstream from 1994 up until 2000, when he added another aircraft, is when he bought the Boeing 727. And he continued to keep both of those aircraft. So we flew both aircraft, the Boeing and the Gulfstream, up until 2004, to the date you mentioned. MS. COMEY: Ms. Drescher, would you please pull up Government Exhibits 311 and 312 for the witness, the Court, and the parties. Q. Mr. , do you recognize these? A. Yes. Q. What are they? A. That is the first aircraft Mr. Epstein purchased, which is the Hawker Siddeley 125. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068624 163 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Are these both fair and accurate depictions of that aircraft? A. Yes, they are. MS. COMEY: Your Honor, the government offers both of these exhibits in evidence. MR. EVERDELL: No objection. THE COURT: Without objection, Government 311, 312 are admitted, and you may accomplish. (Government's Exhibits 311, 312 received in evidence) MS. COMEY: Thank you, your Honor. You can take those down. Thank you, Ms. Drescher. Q. Mr. , about how many helicopters do you remember Mr. Epstein owning between 1994 and 2004? A. During that time frame, up until 2004, it was probably the first helicopter he purchased, one helicopter. Q. And when did Mr. Epstein purchase that helicopter? A. Give or take a year, probably the year 2000, '99 to 2000. MS. COMEY: Ms. Drescher, would you please pull up Government Exhibits 344 and 345 for the witness, the Court, and the parties. Q. Mr. , do you recognize these? A. Yes, I do. Q. What are they? A. That is a photo of Mr. Epstein's first helicopter he purchased. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068625 16.1 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Do both of these exhibits fairly and accurately depict that helicopter? A. Yes, they do. MS. COMEY: Your Honor, the government offers these in evidence. MR. EVERDELL: No objection. THE COURT: 344 and 345 government exhibits are admitted. You may publish. (Government's Exhibits 344, 345 received in evidence) MS. COMEY: Thank you, your Honor. Q. And while Ms. Drescher puts those up, I'll ask you, Mr. , what did Mr. Epstein use these -- this helicopter for? A. It was mainly to get from St. Thomas to Little St. James, rather than taking the boat ride. Q. Who do you remember flying this helicopter? A. Myself, Ms. Maxwell flew the helicopter with me, and I also had some contract pilots that were based in St. Thomas that assisted flying the helicopter as well. Q. About how many times do you remember Ms. Maxwell flying this helicopter? A. Many times. It would be hard to put a number on it. Any time -- several -- many times. It's hard to put a number on it. MS. COMEY: We can take those down. Thank you. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068626 165 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Between approximately 1994 and 2000, what plane did you fly most frequently for Mr. Epstein? A. From 1994 to 2000, that would be it would have been all been the Gulfstream G2B. MS. COMEY: Ms. Drescher, would you please pull up Government Exhibits 336 and 315 for the witness, the Court, and the parties. Q. Mr. , do you recognize these? A. Yes, I do. Q. What are they? A. The photo on the left is a photo of the Gulfstream G28 that has the white stripe on it, the black aircraft. The white aircraft in the photo is -- I don't -- nothing to do with Mr. Epstein. And then the photo on the right is another photo of the Gulfstream G2B with Mr. Epstein standing in front of it. MS. COMEY: Your Honor, the government offers these in evidence. publish. MR. EVERDELL: No objection. THE COURT: 336 and 315 are admitted and you may (Government's Exhibits 315, 336 received in evidence) Q. While Ms. Drescher puts these up for the jury, would you please describe what the interior of the G2B looked like, please. A. As you walk up the entrance stairs to the aircraft, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068627 166 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 obviously if you make a left turn, that would bring you into the cockpit. You made a right turn, brought you into the passenger compartment. And as soon as you got into the passenger compartment, there were four large captain's chairs. They were baseball glove leather in color. This aircraft had a burgundy carpet. Once you get past the four chairs, you're continuing walking to the rear of the aircraft. There was a conference table to the right that had two chairs as well. And then further aft, as you continue walking to the back of the aircraft, there was a couch or a divan inside there. And then once you went past the couch divan, there was a galley or what you would call kitchen inside the aircraft. And as you went further past that was the bathroom for the aircraft. And then further back than that is the luggage compartment. Q. What, if any, barrier was there on this aircraft between the pilots and the passengers? A. Between the pilots and the passengers there was a door that could be shut. Q. And when you flew this plane for Mr. Epstein, was that door open or shut during flight? A. We always had the door closed. It's much quieter with the door closed as well. Q. So were you able to observe what the passengers were doing when you flew this plane? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068628 167 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. No, I could not. Q. Between approximately 2001 and 2004, which of Mr. Epstein's planes did you fly most frequently? A. Between 2001 and 2004, it was a combination of both the Boeing 727 and the G2B, depending upon his choice of what aircraft he wanted to fly. But mostly during that time frame we were flying the Boeing 727. MS. COMEY: Ms. Drescher, would you please pull up Government Exhibits 302 and 301 for the witness, the Court, and the parties. Q. Mr. , do you recognize these? A. Yes, I do. Q. What are they? A. Those are two photos of the Boeing 727 that Mr. Epstein owned. MS. COMEY: Your Honor, the government offers these in evidence. MR. EVERDELL: No objection. THE COURT: 302 and 301, government exhibits, are admitted. You may publish. (Government's Exhibits 301, 302 received in evidence) MS. COMEY: Ms. Drescher, after you've shown both of these, I'd ask just to put up Government Exhibit 301 for the jury, please. Q. While she's doing that, Mr. , would you please SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068629 168 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 describe what the inside of this plane looked like. A. Sure. The best way to describe it, it was kind of like a recreational vehicle inside; it wasn't like a typical airliner would look. You went in the front entrance door which is located at the forward part of the aircraft. You walked upstairs. And if you continued straight ahead, it went into the first bathroom, which we considered the crew bathroom; so there was a lavatory up in front. And then if you made a left turn, brought you into the cockpit. Now we're still at the entrance and now we're going to walk to the back of the airplane. You went through -- as soon as you got to the first compartment, there was like a large living room that had one, two, three -- it had three couches or divans. And then it had several captain chairs inside there. Once you went from that first compartment, you're continuing walking to the back of the aircraft, in the middle there was a galley or kitchen like you would find in a home. It was a full decked-out kitchen. And then once you went further past the kitchen, there was what we call the round room. There was a couch or a divan in the middle of the aircraft that was actually round or circular. And once you went past that, there was what we called the red room, which had Mr. Epstein's office that also had a red couch or divan and his office desk. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068630 169 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 And then once you continue further walking to the back of the aircraft, there was the master bedroom that had a queen-size bed and two captain's chairs inside there. And then you're still walking to the back of the aircraft, there was the master -- the master lavatory or the bathroom in the rear of the aircraft. MS. COMEY: Ms. Drescher, would you please pull up Government Exhibit 303 for the witness, the Court, and the parties. Q. Mr. , do you recognize this? A. Yes. Q. What is it? A. That is actually the round room I described with the round couch or divan inside it. And then further in the photo you could see the red couch which was his office. And further after that led into the bedroom. Q. Is this a fair and accurate depiction of a portion of the interior of Jeffrey Epstein's Boeing 727? A. Yes, it is. MS. COMEY: Your Honor, the government offers this in evidence. MR. EVERDELL: No objection. THE COURT: Government 303 is admitted. You may publish. (Government's Exhibit 303 received in evidence) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068631 170 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. While Ms. Drescher puts that up, will you please describe once again what we see in this photograph, Mr. A. That's the middle of the aircraft or where actually the emergency exits are located. When you say describe it -- Q. What we're seeing in the foreground and the background, the jurors weren't able to see the photograph when you were describing it. A. Oh, I'm sorry. Gotcha. I thought I just explained it. I'm going to repeat myself. So this is the round couch, round divan that was in the middle of the aircraft. And then as you see in the photo, the red couch or divan, which was Mr. Epstein's office and which -- to the right side of that, which is not in the photo, there was a large desk. And then in the foreground, way in the back are the two captain's chairs that are actually across from the master bed in the back of the aircraft. MS. COMEY: We can take that down. Thank you, Ms. Drescher. Q. What, if any, barrier was there between the pilots and the passengers on the Boeing 727? A. On the Boeing, each compartment had its own doors, so you can seclude each compartment or even the cockpit from the passengers. Q. During flight in the Boeing 727, was the cockpit door opened or closed? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068632 17i LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. It was always closed. Q. So were you able to observe the passengers on the flights you piloted on that plane? A. No. Q. What records did you keep as a pilot for Mr. Epstein? A. We kept two documents, one was a flight log and the other was a passenger manifest. Q. And when you say "we," who do you mean? A. I meant myself and the other pilot. Q. And who was that? A. David Rogers. Q. You mentioned a flight log and a passenger manifest. Did you complete one for each flight you piloted for Mr. Epstein? A. Yes, I did. Q. What is contained in a flight log? A. A flight log is a document that is pretty much married to the aircraft; it's the history of how many hours the aircraft has on it, how many times the aircraft has landed, each engine has its own total time that's recorded, as well as how many times it was cycled, meaning turned on or off. Q. Will that flight log have any information about the passengers onboard for a particular flight? A. No, it will not. Q. How about the passenger manifest, what information goes into a passenger manifest? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068633 172 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. A passenger manifest is a document that we recorded what time we actually took off and landed. It had the date of the flight, it had the exact time of departure and arrival, and it also had a column for the name of the passengers that were on the aircraft. Q. Who completed the passenger manifest for each flight that was piloted for Mr. Epstein? A. Whoever was captain on the aircraft that day would complete that form. Q. What does it mean to be captain? A. To be captain would be to fly in the left seat and be in total control of the aircraft. Q. How long after each flight did the captain complete the passenger manifest? A. It was done immediately after the aircraft, within an hour. Q. Between approximately 1994 and 2004, what did you do with the passenger manifests that you personally completed? A. They would acquire them. After about 30 days, I would take them to the main office in New York and then drop them off. Q. Did you keep a copy for yourself? A. No, I did not. Q. If you did not know the name of a particular passenger on a flight, how will you indicate the presence of that passenger in a passenger manifest? A. I tried to be as accurate as I could. If I didn't know a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068634 173 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 passenger name, I wanted to put whether they were male or female, the passenger -- as a pilot's standpoint, it's more important how many people and how much they weigh compared to a person's name. We tried to be as accurate as we could. So if I didn't know a name, I put whether they were male or female. Q. And remind us why you wouldn't necessarily know the name of everyone on your plane? A. It wasn't my first priority. Most of the time Mr. Epstein would, you know, indicate or introduce us to the passengers, but it just wasn't -- it wasn't the first thing, you know, on anybody's mind. Occasionally he would introduce and sometimes he wouldn't. We would try to gather their name if we asked them, if we had the time to ask them. But we tried to do the best we could is to get everybody's name. Q. During your employment with Mr. Epstein, did you ever fly to the airport in Traverse City, Michigan? A. Yes, I did. Q. About what years do you remember making those trips to Michigan? A. Definitely in the '90s is the best I could come up with. It was in the '90s. Q. During what season do you remember taking those trips to Michigan? A. I don't remember it being cold, because I know it gets pretty cold up there. It had to have been summer or, you know, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068635 174 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 maybe close to fall when cherry season was happening because _ think that's the cherry capital. Q. When traveling to Traverse City, Michigan, where, if anywhere, do you remember picking up Mr. Epstein's luggage? A. I can only recall one time that Mr. Epstein had called or somebody notified me to pick up the luggage in the lobby of the Interlochen School of Music. Q. About when was that? A. I don't have an accurate date. I could only say the '90s. Q. And what is Interlochen? A. I believe it's a school for gifted children that are talented musicians, singers, etc., world-renowned type of school. Q. How many, if any, female passengers who flew on Mr. Epstein's plane do you remember who were singers? A. I can recall one. MS. COMEY: At this time, your Honor, I'd like to read a stipulation into the record, if I may. THE COURT: What is the identification number? MS. COMEY: It's Government Exhibit 1004. THE COURT: Mr. Everdell, without objection? Go ahead. MR. EVERDELL: No objection, your Honor. THE COURT: Okay. You may read Government Exhibit 1004, the stipulation. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068636 175 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. COMEY: Thank you, your Honor. It is hereby stipulated and agreed that Government Exhibit 11 is a true and correct certified copy of a birth certificate reported to the New York Department of State. Government Exhibit 11 accurately reflects the date of birth of the person named on the certificate. Government Exhibit 12 is a true and correct copy of -t birth certificate reported to the Rhode Island Department of Health. Government Exhibit 12 accurately reflects the date of birth of the person named on the certificate. Government Exhibit 13 is a true and correct certified copy of a birth certificate reported to the Missouri Department of Health and Senior Services. Government Exhibit 13 accurately reflects the date of birth of the person named on the certificate. Government Exhibit 14 is a true and correct certified copy of a birth certificate reported to Sacramento County, California. Government Exhibit 14 accurately reflects the date of birth of the person named on the certificate. Government Exhibit 15 is a true and correct certified copy of a birth certificate reported to the Massachusetts Department of Public Health. Government Exhibit 15 accurately reflects the date of birth of the person named on the certificate. Government Exhibit 16 is a true and correct copy of -t SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068637 176 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 birth certificate reported to the general registrar -- register office of England and Wales. Government Exhibit 16 accurately reflects the date of birth of the person named on the certificate. It is further stipulated and agreed that this stipulation, marked as Government Exhibit 1004, and Government Exhibits 11, 12, 13, 14, 15, and 16 may be received in evidence at trial. At this time, your Honor, the government offers all of the exhibits I just named. THE COURT: Mr. Everdell. MR. EVERDELL: No objection. THE COURT: Without objection and on stipulation, Government Exhibit 1004 is admitted, as are Government Exhibit 11, 12, 13, 14, 15, and 16. (Government's Exhibits 11, 12, 13, 14, 15, 16, 1004 received in evidence) MS. COMEY: Your Honor, I would note that the parties have agreed that Government Exhibits 11 through 16 would be submitted under seal. And I would ask for authorization to have the jurors pick up their binders of sealed exhibits so that we may look at one of those in a moment. THE COURT: Okay. And the sealing is consistent with my ruling that some of the witnesses are able to testify under pseudonyms. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068638 177 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. COMEY: Yes, your Honor. THE COURT: Okay. And the specific direction to the jury is to pick up the binder now or not yet? MS. COMEY: Pick up the binder now, but don't turn anywhere in the binder yet. THE COURT: Okay. Mr. Everdell, without objection? MR. EVERDELL: That's fine, your Honor. THE COURT: Members of the jury, there's a binder under your seat. Please just pick it up, but don't open it until specifically directed. Thank you. MR. EVERDELL: Your Honor, also they shouldn't pick up the folder. THE COURT: They should not. There's a folder there as well, and you should not pick up the folder yet, just the binder. Surprises under your seats. MS. COMEY: Your Honor, I would also ask the witness to please pick up the binder in front of him. THE COURT: Okay. Please do, Mr. MS. COMEY: At this time I'd like to ask for the jury and the witness to just turn silently to Government Exhibit 12 and take a look at that. THE COURT: We're not going to put these on the screens. copies. MS. COMEY: That's correct, your Honor. All paper SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068639 1 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: Thank you. MS. COMEY: And your Honor, we have a hard copy for the Court, if that would be useful. THE COURT: That would help. Thank you. MS. COMEY: May Ms. Drescher approach? THE COURT: Please. And you've asked, Ms. Comey, to turn to again? MS. COMEY: Government Exhibit 12, your Honor. THE COURT: Okay. So please just turn to Government Exhibit 12. Everybody there? Not yet. MS. COMEY: I see a hand from a juror. THE COURT: You need glasses. We're going to get them. Hang on a second. Ms. will ask you where she can find them for you. Just a moment. Members of the jury, please don't turn to other exhibits until expressly instructed, but you may look at Government Exhibit 12 in the binder. (Pause) THE COURT: Thank you, Ms. . GX-12. MS. COMEY: Yes. Thank you, your Honor. BY MS. COMEY: Q. Now, Mr. , without saying the name out loud, would you please look at the first and last name on this exhibit. A. Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068640 179 LBUVMAX2 - direct Q. Is the first and last name on that document the name of the female singer you remember being a passenger on Mr. Epstein's plane? 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. EVERDELL: Objection. Leading. THE COURT: I'll allow it. Go ahead. Q. You can answer or I'm happy to ask the question again if you need me to. A. Yes. Q. To be clear, is that the first and last name of the female singer you remember being a passenger on Mr. Epstein's plane? A. Yes, it is. MS. COMEY: We can set that aside. Thank you. And your Honor, we don't need those binders for the jurors anymore for this witness. THE COURT: All right. Members of the jury, you can close the binder and put it back under your chair, please, until given further instruction. Thank you so much. Q. Mr. , I'm going to refer to that person whose name we just looked at as please. A. Okay. Q. Do you remember meeting A. Approximately mid to late '90s. Q. Do you remember the exact year as you sit here today? A. No, I do not. , and I would ask you to do the same, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068641 180 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Did anyone ever tell you how old was? A. No. Q. Do you know how old was when you met her? A. No, I didn't. Q. How did you meet A. Mr. Epstein brought her to the cockpit and introduced her to me. Q. What, if anything, stands out in your mind about demeanor when you met her that day? A. Just a mature woman with some piercing powder blue eyes. Q. About how many times do you recall seeing on Mr. Epstein's plane? A. At least one, the time that Mr. Epstein introduced. Q. Do you remember where you were going that day? A. I do not. Q. Do you remember where you were coming from? A. Yes. Q. Do you remember where you were coming from that day? A. Yes, we were departing West Palm Beach Airport. Q. What, if any, passenger with the first name do you remember flying on Mr. Epstein's plane? A. I do remember at least one person named Q. And what was that person's full name? A. It was Q. About when did you meet SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068642 181 LBUVMAX2 - direct 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Had to have been mid to late '90s. Q. Do you remember the exact year? A. I do not. Q. What did look like? A. A shorter woman with dirty blond hair. Q. Did anyone ever tell you how old was when you met her? A. No. Q. Do you know how old she was when you met her? A. No, I did not. Q. About how many times do you remember seeing as a passenger on Mr. Epstein's private planes? A. She was on the airplane a couple times. I couldn't guess the quantity, but definitely more than once. MS. COMEY: May I have a moment, your Honor? THE COURT: You may. (Counsel conferred) MS. COMEY: Nothing further, your Honor. THE COURT: Okay. Mr. Everdell, you may proceed with the cross-examination. MR. EVERDELL: Thank you, your Honor. At this point, with the Court's permission, I would put a binder up in the witness box. THE COURT: Okay. MS. COMEY: Your Honor, to be clear, I have not seen SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068643 182 LBUVMAX2 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 what's inside this binder. MR. EVERDELL: This is in case we need to refer the witness to something. THE COURT: So you may bring it forward. Before the witness is directed to look at any document, you'll show it to the government. MR. EVERDELL: Yes. If we're going to refer to anything, we will refer what it is to the government so they can see it before we have the witness open the binder. THE COURT: Okay. MS. COMEY: Thank you, your Honor. THE COURT: Thank you. MR. EVERDELL: May I approach, your Honor? THE COURT: You may. MR. EVERDELL: May I remove my mask, your Honor? THE COURT: You may, Mr. Everdell. CROSS-EXAMINATION BY MR. EVERDELL: Q. Good morning Mr. A. Good morning, Mr. Everdell. Q. I'm going to ask you a few questions about what you just testified to on direct. A. Okay. Q. Now, you testified that you started working as a pilot for Jeffrey Epstein in about 1991; is that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068644 183 LBUVMAX2 - 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 you were hired, along with your friend that right? A. That's correct. Q. Now, when you started in 1991, was the chief pilot and you were the co-captain? A. That is correct. Q. But that changed, I think, in about 2000; is that right? A. That is correct, approximately. Q. At that point you became the chief pilot and became the co-captain? A. That's correct. Q. And you continued to work for Epstein as his chief pilot until about 2019? A. Correct. Q. So you were a pilot for Jeffrey Epstein for almost 30 years from 1991 to 2019; is that right? A. That is correct. Q. And in that time, I think you testified that you flew several different planes for him; is that right? A. That is correct. MR. EVERDELL: If we could call up what is already in evidence as Government's Exhibit 311. THE COURT: 311 you said? MR. EVERDELL: 311, your Honor. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068645 124 LBUVMAX2 - 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: Okay. You may. MR. EVERDELL: And we can display that for the jurors. THE COURT: You may. Q. Do you see that, Mr. A. Yes, I do. Q. We saw that before. That's the Hawker Siddeley jet, right? A. Correct. Q. And that was used from about '91 -- 1991 to 1994; is that right? A. That's correct. MR. EVERDELL: Okay. We can take that down. Q. So you no longer flew the Hawker after about '94? A. No, the aircraft was sold after '94. Q. And there was another aircraft you mentioned, the Gulfstream, the G2B, right? A. Correct. MR. EVERDELL: If we can pull up what's already in evidence as Government's Exhibit 315. THE COURT: You may. MR. EVERDELL: Display that for the jurors as well. Q. Do you see that, Mr. A. Yes. Q. We saw that before, right, that is the Gulfstream jet with Mr. Epstein in front of it; is that right? A. Correct. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068646 185 LBUVMAX2 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Okay. And he got that, your recollection is, sometime around 1994? A. Correct. MR. EVERDELL: All right. We can take that down. Q. And you've also mentioned that he eventually got the Boeing 727? A. Correct, in 2000. Q. That was roughly around 2000? A. Correct. MR. EVERDELL: If we can display what's already in evidence as Government's Exhibit 301. THE COURT: You may. MR. EVERDELL: And show that to the jurors as well. Q. That was -- that is the Boeing 727; correct? A. That is correct. MR. EVERDELL: Okay. You can take that down. Q. You occasionally flew other planes for him as well? A. Yes. Q. I think we saw in one of the photos, I won't call it up, but there was a small Cessna? A. Yes. Q. But from about 1994, after Mr. Epstein sold the Hawker, till about 2001 or 2000, I think is your recollection, when he bought the Boeing, you flew primarily the Gulfstream? A. That is correct. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068647 186 LBUVMAX2 - 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 from 2000 onwards or till 2004 or five, you were flying both the Gulfstream and the Boeing? A. That's correct. Q. Now, in the period from 1991, when you were first hired, to 2005, you flew numerous flights for Epstein? A. Correct. Q. Would it be accurate to say that you flew over 1,000 flights during that time period? A. I'd have to look at my records, but it was probably close to that, yes. Q. Give or take? A. Give or take, yes. Q. That's a lot of flights. A. We consider it more in hours than flights, but Q. Understood. And Epstein would frequently have other passengers on these flights, right? A. Yes. Q. And many of these passengers were female; correct? A. Correct. Q. And sometimes you saw the passengers, right? A. Yes. Q. There were times when you, I think, stood at the entrance of the plane near the cockpit when the passengers arrived and you might have greeted them? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068648 187 LBUVMAX2 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Sometimes. Q. There were times when Epstein or Ghislaine introduced you to passengers? A. Correct. Q. There were times when the plane and the passengers had to clear customs, right, and the pilots and the passengers would have to get out of the plane and clear customs to do that? A. Yes, that's correct. Q. And you'd see the passengers then too? A. Sure. Q. Okay. And there were times when the passengers came up to the cockpit before takeoff and you might have met some of them then? A. Occasionally that would happen, sure. Q. Okay. Now, you testified that the cockpit doors for the Gulfstream and the Boeing were always closed during the flights while you were in the air; is that right? A. Yes. Q. But you left the door open to the cockpit as you were getting the plane ready for takeoff before you took off, right? A. Yes. Q. As you were in the cockpit, if you were looking back through the cockpit door, you could see the passengers in the entranceway if you wanted to, right? A. Most of them, yes. It wasn't a clear view to every seat in SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068649 188 LBUVMAX2 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the aircraft, but, yeah, I could see the passengers. Q. There were several ways that you could have observed and did observe the passengers that came onto his planes? A. Yeah, if I looked over my shoulder; correct, yes. Q. Or those other ways we discussed? A. At the entrance, yes. Q. Now, of the female passengers on these planes that you observed, you occasionally saw young girls who were traveling with their family members, isn't that right? A. There was some time when adults would bring their children onboard, sure. Q. But you never saw a female you thought was under the age of 18 who was not with her family, right? A. Correct. No. Q. And apart from those times when you saw young girls traveling with their family members, you never saw any female on the plane who looked to you to be under the age of 20, isn't that right? A. Well, that's correct, yeah, I didn't notice anybody of a younger nature without an adult or, you know, a parent. Q. So in the roughly thousand or so, give or take, flights that you flew for Epstein from 1994 -- or 1991, I should say, to 2005, you never once saw a female on any of the planes who looked under the age of 20, apart from the ones who were traveling with their family members? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068650 189 LBUVMAX2 - 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. I didn't know anybody's, you know, exact age or age at all really. Q. But none of them appeared to you to be under 20? A. Correct. Q. Was that -- I didn't hear. A. Yes, that's correct, yes. Q. Now, that includes the woman that we have been referring to as ; correct? A. Correct. I didn't know her age. Q. And she did not appear to you to be under the age of 20? A. I didn't know her exact -- I didn't know her age at all. But to my -- she looked like a woman. Q. She looked like a mature woman, I believe was your testimony before; is that right? A. Sure. Yes. Q. Okay. And it also includes the woman you referred to as A. Yes. Q. She also did not look below the age of 20 to you? A. I didn't know her age, but she didn't -- she didn't look young. I mean, wherever you decipher is the definition of "young," but she -- she was a woman in my category. (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068651 190 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. EVERDELL: Q. She was a woman? A. Yes. Q. Mr. , in all these flights that you flew, the several hundred to a thousand flights that you piloted for Mr. Epstein in this time period, you also never saw any kind of sexual activity occur on the planes; isn't that right? A. I never saw any sexual activity, no. Q. And you certainly never saw anyone engaging in sex acts with underage girls on the plane? A. Absolutely not. Q. In fact, you never saw anyone engaging in sex acts with any of the women on the flights period; right? A. That is correct. Q. Now, you testified, I think we already established this, that when you were flying, in flight, the cockpit doors were closed? A. That is correct. Q. So if the cockpit doors were closed, you couldn't necessarily see what was going on in the cabin during the flights; right? A. Not at all, no. Q. But you were never instructed by Epstein or anyone else that you were not allowed to leave the cockpits during the flights; is that correct? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068652 191 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's correct. Mr. Epstein invited us, that if we had to go to the bathroom, that we were welcome to walk to the back of the aircraft. Q. So he invited you to come anywhere you wanted to, even including in the back of the aircraft to use the restroom if you wanted to? A. Exactly. Yes, because there are times that if you have to use the restroom, like now. Q. We can take a break. A. I was hoping for a break in between. Am I the only one? THE COURT: Jury, I think it's time for our midmorning break. Why don't you finish the question and then we'll take a break. MR. EVERDELL: Yes, your Honor. Q. I'll just ask the question. He invited you to use the restroom at the back of the plane whenever you needed to? A. Yes, he offered, if we needed to use the restroom, to feel free to come into the back of the aircraft to use the restroom. Q. One last question before we break. To do that, you had to walk through the cabin to the back of the plane and go through the rooms of the plane to get to the restroom; isn't that right? A. If we were in the Gulf Stream, yes. In the Boeing, we had our own lavatory up front. But in the Gulf Stream, like, you're talking about from '94 to 2000, we would walk down the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068653 192 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 middle of the aircraft because the bathroom was at the absolute rear, correct. THE COURT: Members of the jury, we'll take our midmorning break. See you in about 10 minutes. (Continued on next page) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Thank you. EFTA00068654 193 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) Everyone may be seated, the witness may step down for the break. (Witness not present) Are there matters to take up before the break? MS. COMEY: No, your Honor. MR. EVERDELL: No, your Honor. MS. STERNHEIM: Judge, may I just ask, it's very cold in here, can the temperature be risen just a little? THE COURT: I'm sweating. MS. STERNHEIM: Sorry. THE COURT: We'll get it raised. This is my light weather robe. We'll get it raised. MS. STERNHEIM: Thank you. THE COURT: I apologize. We'll see you in about 10. (Recess) THE COURT: Matters to take up, counsel? MS. COMEY: No, your Honor. MR. EVERDELL: No, your Honor. THE COURT: We can bring the witness back into the box. Mr. Everdell, do you have a time estimate? I won't hold you to it. MR. EVERDELL: Do you have an estimate for how long I've been going so far? I could probably -- SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068655 194 LBUCmax3 - cross THE COURT: 20 minutes. MR. EVERDELL: I'd say maybe another hour or so. THE COURT: Okay. Ms. Sternheim, I have asked for 4 them to raise the temperature. 5 MS. STERNHEIM: Thank you, Judge. Feels better 6 already. 7 (Continued on next page) 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068656 195 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: Please be seated. I hope you had a pleasant and timely break, members of the jury. Thank you for your continued attention and diligence. Mr. Everdell, you may continue with your cross examination of Mr. . And Mr. , I remind you that you are under oath. You may proceed. MR. EVERDELL: Thank you, your Honor. BY MR. EVERDELL: Q. Welcome back, Mr. A. Thank you. Q. Trust you're feeling more comfortable? A. Oh, much better. Q. Very good. Do you recall when we left off, we were talking about going to the restroom on the airplanes? A. Yes. Q. And I think you said that you were allowed, you were permitted and even invited to walk through the Gulf Stream to the back of the plane to use the restroom there if you needed to? A. That's correct. Q. So Mr. Epstein never told you, for example, you have to stay in the cockpit during the flight? A. Absolutely not. Q. Now if he were engaging in sex acts with underage girls in SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068657 196 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the plane and he didn't want you to see that, he probably would have said something to you about that, wouldn't he? MS. COMEY: Objection, your Honor. THE COURT: Overruled. You may answer. A. Can you repeat the question. Q. Sure. If Mr. Epstein were engaging in sex acts with underage girls on his planes and he didn't want you to see it, he probably would have told you that you couldn't leave the cockpit during the flight; isn't that right? A. That's correct. Q. And he never told you that you could never mingle with the passengers; right? A. No, not at all. Q. In fact, you recounted how you did interact with the passengers on occasion; right? A. Absolutely on occasion, sure. Q. In fact, you were never given any rules about how you could or could not interact with the passengers; right? A. No, I was never told what to do with the passengers or what not to do. Q. And you were never given any rules about how you could interact with the other members of his staff or his assistants; isn't that right? A. That is correct, never. Q. Now, you did say that every once in a while you would leave SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068658 197 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the cockpit to use the restroom? A. Correct. Q. And you did that both on the Gulf Stream and on the Boeing; is that correct? A. Yes. Q. The Gulf Stream bathroom, you said, was in the back of the plane; right? A. Yes. Q. And the Boeing bathroom was near the cockpit but outside the cockpit; is that right? A. Exactly, yes. Q. So if you went to the bathroom in the Boeing, you could still see the cabin where the passengers were, at least the first cabin? A. If the door was open. Each section of the aircraft had a door and typically the doors were open. Q. Well, in any of those trips to the restroom, you never saw any sexual activity on the plane? A. No, I never did. Q. And you had also, I think, occasion go to get coffee in the galley kitchen; is that right? A. In the Boeing, yes. I would go to the middle of the aircraft to get a cup of coffee on occasion, sure. Q. And as you said in the Boeing, the galley kitchens is in the middle of the aircraft; is that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068659 198 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's correct. Q. So you would have to walk through at least that first cab':-: of passengers? A. That's correct. Q. And on those trips you took to get coffee in the galley kitchen, you never saw any sexual activity going on then, did you? A. No, never. Q. Now, after the flight landed, I believe it was part of the pilot's job to help clean up the cabin and straighten up a bit; isn't that right? A. Yes, it is. Q. And when you did that, you never saw anything like clothes strewn about the cabin; is that right? A. No, never. Q. You never saw any sex toys left in the cabin? A. Never. Q. You never saw anything like used condoms? A. Absolutely not. Q. You never saw anything that gave you the impression that any kind of sexual activity was taking place on the plane with anyone; is that right? A. That is correct, I never, no. Q. So sitting here today, based on what you observed, you have no reason to believe that Epstein or anyone else was engaging SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068660 199 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in sexual activity with underage girls on the flights you piloted; isn't that right? A. Correct. Q. Mr. , I want to ask you some questions about how the flights were scheduled and set up. Okay? A. Sure. Q. Now, before a flight was scheduled, you and needed to be alerted ahead of time that Epstein needed to fly somewhere; isn't that right? A. Yes. Q. I think you said typically you get about a day's notice; isn't that right? A. That's correct. Q. And several different people would call you to schedule these flights; is that right? A. Yes. Q. And in the 1990s, focusing on that time period, you would occasionally get calls from Epstein himself to schedule flights? A. He would call on occasion, yes. Q. And every once in a while, you'd get a call from Ghislaine, as well? A. Sure. Q. But during that time period, it was usually Epstein's secretary or one of his other assistants in New York who would SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068661 200 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 call you to schedule the flights; isn't that right? A. It would be a variety. Whoever got the message would pass it along to us, correct. Q. Right. And I think you said that in the 1990s, you didn't have cellphones; right? A. Correct. It was a beeper, pager. Q. Beeper. This was over 20 years ago at this point; right? A. Coming in on 30, but yes, correct. Q. Coming in on 30. That's before everybody owned a cellphone; correct? A. Yes. Q. But you did have the beepers? A. Yes. Q. And you and would get a message on your beeper; right? A. Yes. Q. And you would call back Epstein's office, usually; right? A. Yes. Q. Because that's usually where the call came from, isn't it? A. That's correct. That was the number that would appear for departure. Q. And you would talk to Epstein's secretary or assistant or whoever was going to schedule that flight? A. Correct. Q. Now, occasionally, you said you talked to Ghislaine about SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068662 201 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 this, about scheduling? A. Occasionally Ghislaine would reach out. Several people would reach out. Whoever Jeffrey told, hey, get the plane ready, that's the person that contacted me. Q. It was usually the case, if you spoke to Ghislaine about flight, she was going to be traveling on that flight? A. Most of the time, sure. Q. And in the 2000s now, fast forwarding to a later time period, you spoke to different people about scheduling flights; isn't that right? A. Yeah, whoever would get the message, correct. It would be different people. Q. Well, one person you spoke to in the 2000s was ; isn't that right? A. That's correct. Q. And was Epstein's secretary? A. That's correct. Q. And she worked in Epstein's New York office? A. That is correct. Q. Do you recall what number you used to call her on? A. Yes, the main office number. Q. Do you remember what that number was? A. Yes, I do. Q. What was it? A. 212-750-9895. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068663 202 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 the person I think you spoke most often to about scheduling flights in the 2000s was not , it was ; isn't that right? A. She would also schedule flights, yes. Q. You met , you said? A. Yes, I have. MR. EVERDELL: If we can pull up for the members of the jury and everyone else Government Exhibit 327, which is already admitted. Q. That's isn't it? A. That is , yes. Q. Now, you say you think you met her sometime in the early 2000s; is that right? A. It could have been late '90s. Again, we're 20, 21 years ago, but yeah, it was late '90. It could have been 2000. - remember Ms. obviously flying on the Boeing, which would have been 2000 and later. Yeah, it was late '90s. It's the best I could do as far as recollection. Q. Well, isn't it true that she first flew on one of Epstein's planes in September of 2001? A. I believe she -- well, she probably did because she was around in '01 when the Boeing was there. I haven't gotten any -- I don't have any documentation or -- but yes. MR. EVERDELL: Let me see if there is something that might refresh your recollection. I would like to pull up just SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068664 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 for the Court, the deputy, and for the witness 3527-07 at page 86. I'll repeat for clarity that's 3527-007 at page 86. THE COURT: Let me know when you're ready, Ms. Comey. MS. COMEY: I'm there. Thank you, your Honor. THE COURT: Thank you. BY MR. EVERDELL: Q. Mr. , if I could direct your attention to the sixth entry down on that list you're looking at. If you could just take a look at that. Just see if that refreshes your recollection about the first time flew. A. Is that the September 3rd date you're looking? Q. I'm asking, does that refresh your recollection? A. Well, it's a document of a regularly scheduled route. Obviously it's not my logbook. It was normal -- there was a typical routing that we would fly. It's the best I could say, but it would appear to be the -- it doesn't refresh of any, you know, certainty, but sure, that would be a date that we would do a trip like that. Q. Okay. So I'll just rephrase. , to the best of your recollection, was flying on Epstein's planes in the early 2000s? A. Yes. Correct. MR. EVERDELL: You can take that down. Q. Now, that is around the time when Epstein excuse me. When became Epstein's personal assistant; isn't SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068665 204 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that right? A. I didn't know what her exact job detail was. I mean, I considered her position or her title, you know, throughout the same as far as to being Mr. Jeffrey's assistant or Ms. Maxwell's assistant, just that she was there as an employee. Q. Your recollection is that she was an employee who worked with Epstein; is that fair to say? A. Yeah. Exactly, yes. Q. But you're a little unclear exactly what her role was? A. Correct. Q. But she certainly did some work for Epstein in the time she worked in his office? A. Exactly, yes. Q. Do you recall, she was married to right: A. Later in life, I believe she got married to Q. So you said that would call you to arrange the flight departures? A. Sometimes, sure, yes. Q. And by that point in the 2000s or the early 2000s, you had cellphones; right? A. Correct. Q. So , when she did call you, would call your cellphone to arrange a flight; is that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068666 205 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. In fact, you spoke to so often at that point that you had her number on speed dial in your phone; isn't that right? A. Most likely, yes. Q. Do you recall what phone number was? A. I do not. MR. EVERDELL: Let me show you something, see if it refreshes your recollection. I want to call up 3527-001, we'll go to the third page. That is just for the Court, the deputy, and the witness, please. MR. EVERDELL: May I proceed, your Honor? THE COURT: Yes. MS. COMEY: Thank you. Q. Mr. , do you have that document in front of you? A. Yes, I do. Q. Do you see just sort of maybe a third of the way down from the top of the page, there is an entry there. Does that refresh your recollection on what phone number was? A. Her number wasn't embranded in my mind as a memory, but the number does come back to me as being cellphone number. Q. So the number, was it A. That's correct, yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068667 206 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: Thank you. You can take that down. Q. So in the 2000s, that's the number you would speak to on about arranging flights? A. Correct. Q. Now, regardless of who you spoke to about scheduling flights, when you were told that Epstein needed to fly somewhere, you would need to be given certain information about the flight; correct? A. Sure. Q. Like, for example, you would need to be given the date of when Epstein wanted to fly? A. Correct. Q. You would need to be given roughly the time of departure: A. Yes. Q. And you would need to be given the destination where you're going to fly; right? A. Yes. That would be helpful, yes. Q. You might want to follow a flight plan or something like that? A. Yes. Q. But you wouldn't necessarily be told who was going to be going on the flight; right? A. Not at all. Q. If you had someone who was particularly important that was going to be on the flight, you might be told ahead of time? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068668 207 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. So, for example, I believe former president Bill Clinton flew on Epstein's planes a few times in the 2000s; isn't that right? A. Yes, he did. Q. So if he were going to be on the flight, you might be told that information in advance? A. Yes. Q. Because you might want to make sure the plane looked nice? A. Exactly. Q. You might want to invite some special caterer? A. Sure. Q. But otherwise, you might not know who would be traveling on the flight at all; is that right? A. Correct. Q. And even when the passengers arrived at the airport, even then, you wouldn't necessarily meet all the passengers; right? A. No, not at all. Q. A lot of the time you didn't meet them? A. Correct. Q. Sometimes you were just given their names? A. Yes. Q. And you wouldn't always be given all of their names; right? A. Correct. Q. Sometimes you would just be given a first name? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068669 208 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. Sure. Q. But even if you weren't told all the names or you didn't have all the names, you did try to keep track of how many people were on the plane; right? A. That's correct. Q. Because as you mentioned before in testimony, pilots need to fill out a passenger manifest for each flight; right? A. They don't have to on general aviation. It was more for weight and balance. It was my understanding we kept passenger information more for tax reasons on who flew on the aircraft in the early days. Might not be the case at this point, but we still tried to keep as accurate records, if we could, even if it wasn't necessary. Q. Fair enough. So but you did try to keep passenger manifests for flights on Epstein's planes? A. Absolutely, yes. Q. And a manifest, I think you described, among other things, contains the list of the passenger names if you have them; is that right? A. That's correct. Q. And if you didn't know their names, you might put in something like one female or one male or one passenger to note a named passenger? A. Exactly. We tried to at least identify the sex rather than just put one passenger. So that's why we had put male or SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068670 209 LBUCmax3 - cross 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 female if we didn't catch a name. Q. Obviously, if you did know the name or it was a person you recognized from before, you would put their name on the manifest? A. Absolutely. Q. And you said that it was important to keep track of the head count, which is why you wanted to know how many people were on the plane; right? A. That is correct. Q. Now, you said weight was also a consideration; is that right? A. It's a consideration on some aircraft, not the kind that we're flying, but it's something that should take into account or as far as how heavy luggage is. But it is a consideration as a pilot to know how much something weighs as far as luggage and/or passenger. Q. And that's if you're flying a small plane, for example, you need to know the weight of the passengers? A. Exactly, yes. Q. But for the planes you were flying for Epstein, particularly the Gulf Stream and the Boeing, you didn't need to know the weight for those planes; right? A. It was not necessary, no. It's, like I said, more of a head count, but yeah, it's not a factor in these type of aircraft. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068671 210 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. Right, because the Boeing, as we saw it, it's huge; right? A. Correct. Q. And the Gulf Stream is not a little prop plane, it has a jet engine; right? A. Correct. It's not power challenged, correct. Q. So it wasn't your practice to ask passengers their weight before they boarded? A. No, absolutely not. Q. Now, it was sometimes the case, wasn't it, that if one of Epstein's friends or acquaintances or family members needed to go to the same place he was flying, he would take them on his plane; right? A. I'm sure on occasion. I don't know for a fact, but sure, if we were going to the same place, he may extend an invitation for somebody to come along. Q. He did have friends and family members and other people traveling on his plane? A. That is correct, yes. I see what you're saying. Q. It's like offering a lift in your car, except it's a jet? A. Correct, yes. Q. You call these people tagalongs; right? A. Yeah, there is several names, sure, but tagalongs or extra guest. Q. Now, in those cases, if the person or the tagalong was not a regular traveler, you might not know their name? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068672 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's correct. Q. Or you might just be given their first name? A. Correct. Q. Not be given a name at all? A. Correct. Q. So that's an example of where you might put one female, one male? A. That is correct, yes. Q. Now, the manifest, you testified that you kept the manifest; right? A. Yes. Q. And then eventually you gave them to the New York office? A. Correct. Q. I think you sent them, if I recall, to someone named in New York; is that right? A. Yes. Q. You did not send them to Ghislaine, though; isn't that right? A. No, they went to the main office, whether it be haven't heard that name in a long time. That was a memory refreshed. Thank you. Q. My pleasure. So you have no reason to believe that Ghislaine was reviewing these manifests; right? A. No, Ms. Maxwell had nothing to do with the passenger manifests. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068673 212 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 from your perspective, you had no reason to believe that Ghislaine would hav