EFTA00008631

2 3 UNITED STATES GRAND JURY 4 SOUTHERN DISTRICT OF NEW YORK 5x UNITED STATES OF AMERICA • 6 -V- : November 19, 2019 Additional 7 GHISLAINE MAXWELL 8 (2018R01618) -x 9 10 United States Courthouse 300 Quaroppas Street 11 White Plains, New York 12 June 29, 2020 10:04 a.m. 13 14 APPEARANCE S: 15 Assistant United States Attorney 16 17 Assistant United States Attorney 18 19 20 21 22 23 Acting Grand Jury Reporter 24 25 FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000131 EFTA00008631 06/29/20 (Colloquy Precedes) 2 (Witness Enters Room) 3 (Time Noted: 10:16 a.m.) 4 called as a witness, having been duly sworn by 5 the Foreperson of the Grand Jury, was examined and 6 testified as follows: 7 BY MS. 8 Q. Good morning. 9 A. Morning. 10 Q. Can you please state your full name for the 11 record? 12 A. 13 Q. So I recognize that you are wearing a mask anc 14 behind Plexiglas. There's a microphone in front of you, it 15 you could just make an effort to speak into the mic and keep 16 your voice up that would be great. 17 A. No problem. 18 Q. Where do you currently work? 19 A. The Federal Bureau of Investigation. 20 Q. What is your title? 21 A. Special agent. 22 Q. How long have you worked as a special agent? 23 A. About three years, three years now. 24 Q. Where are you currently assigned? 25 A. I work for the -- on the Violent Crimes against FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_OOOOO132 EFTA00008632 06/29/20 1 Children squad. 2 Q. What are your duties and responsibilities as a 3 special agent on that squad? 4 A. We investigate crimes that have to do with child 5 sexual abuse material, sextortion, exploitation, and 6 enticement of minors, sex trafficking. 7 GRAND JUROR. Maybe if she could take the mask 8 off. I'm having -- is anybody having difficulty 9 understanding her? 10 MS. Thanks for letting me know. Would that 11 be okay with you if the witness took her mask off? 12 GRAND JUROR. We're okay with the Plexiglas, 13 right? 14 GRAND JUROR. Yeah. 15 MS. Thanks very much. Thank you. 16 BY MS. 17 Q. All right. So I'm just going to go back and ask 18 a few of those questions again just to make sure that 19 everyone can hear. You testified earlier that you're a 20 special agent with the FBI. Is that correct? 21 A. Yes. 22 Q. Where are you currently assigned? 23 A. I work on the Violent Crimes against Children 24 squad. 25 Q. And what are your duties and responsibilities as a FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000133 EFTA00008633 06/29/20 1 special agent on that squad? 2 A. We investigate crimes that involve child sexual 3 abuse material, sextortion, enticement, and exploitation of 4 minors, sex trafficking, international parental kidnappings. 5 MS. Let me just pause here. Can everyone 6 hear the witness? 7 GRAND JUROR. Yes. 8 MS. Okay. Thank you. And Special Agent 9 if you could just try to keep your voice up, I really 10 appreciate it. It's a little difficult under the 11 circumstances. 12 BY MS. 13 Q. Have you participated in an investigation of 14 Ghislaine Maxwell? 15 A. Yes, I have. 16 Q. Have you spoken to other people, including other 17 law enforcement officers, about this investigation? 18 A. Yes. 19 4• Have you reviewed reports and documents prepared 20 by others regarding this case? 21 A. Yes. 22 Q. Is your testimony today based in part on those 23 conversations with other law enforcement officers and 24 documents that you have reviewed? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000134 EFTA00008634 06/29/20 MS. Ladies and gentlemen, let me just give 2 you a brief instruction. Some of the testimony that you'll 3 hear today will include what's called hearsay. As you know, 4 that means that the witness will not be testifying solely 5 from her own observations, but that she'll also be reporting 6 to you what others have told her and what she's read in 7 reports and documents prepared by other people. 8 Hearsay evidence is admissible in these grand jury 9 proceedings, and you're free to rely on it in determining 10 whether there's probable cause to indict the proposed 11 defendant. 12 If, however, you would like to hear the testimony 13 of any other witness, you have the right to request it and 14 we will make reasonable efforts to bring that witness before 15 you. 16 BY MS. 17 Q. Special Agent we placed on the desk in 18 front of you a PowerPoint that is Grand Jury Exhibit 2, 19 which we're entering into the record. Do you recognize 20 this? 21 A. Yes. 22 Q. What is it? 23 A. It's a PowerPoint presentation to assist in 24 testifying today. 25 Q. Did you participate in preparing this exhibit in FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000135 EFTA00008635 06/29/20 6 connection with your testimony today? 2 A. Yes, I did. 3 Q. If you could please turn to the first slide. Who 4 are the individuals depicted in these photographs? 5 A. The picture on the left is Ghislaine Maxwell, and 6 the picture on the right is Jeffrey Epstein with 7 Ghislaine Maxwell. 8 Q. Based on your participation in this investigation 9 and your review of public source materials, have Maxwell and 10 Epstein been photographed together many times over 11 years? 12 A. Yes. 13 Q. Based on your participation in this investigation 14 and your review of public materials, where is Maxwell from? 15 A. Maxwell was born in France. She grew up in the 16 United Kingdom, was educated in Oxford, and is from a 17 wealthy family. 18 Q. Is she a citizen of France, the United Kingdom, 19 and the United States? 20 A. Yes. 21 Q. How old is she currently? 22 A. 58. 23 Q. Has the FBI investigated Maxwell and Epstein's 24 conduct with minors during the 1990's? 25 A. Yes FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000136 EFTA00008636 06/29/20 Q. Generally speaking, what have you learned about 2 the relationship between Maxwell and Epstein during the 3 1990's? 4 A. Epstein and Maxwell had a romantic relationship, 5 and she also worked for him; managing his homes, hiring and 6 firing individuals. 7 4• During that time period, was she one of his 8 closest associates? 9 A. Yes. 10 4. During the course of this investigation, have you 11 learned where Epstein maintained properties in the 1990's? 12 A. Yes. 13 Q. Where did he maintain properties? 14 A. New York, Palm Beach, and New Mexico. 15 Q. Turning to the next slide, did he maintain an 16 address in Manhattan located at 9 East 71st Street? 17 A. Yes. 18 Q. Does this slide fairly and accurately depict the 19 residence? 20 A. Yes. 21 Q. Can you please describe that property for the 22 grand jury? 23 A. It's a seven story home; it's located near Central 24 Park. It's reportedly the largest residence in Manhattan. 25 Q. Based on your participation in this investigation, FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000137 EFTA00008637 06/29/20 6 did that house include a room that was used a massage room? 2 A. Yes, it did. 3 Q. All right. We'll talk more about that later, but 4 for now, moving on to the other properties. Did he maintain 5 an address in Palm Beach, Florida, located at 358 El Brillo 6 Way? 7 A. Yes. 8 Q. Turning to the next slide. Does this slide fairly 9 and accurately depict that residence? 10 A. Yes, it does. 11 Q. Could you please describe that property for the 12 grand jury? 13 A. It's a waterfront estate. It has an in ground 14 pool and a detached dwelling or pool house on the property 15 as well. 16 Q. And from your participation in this investigation 17 and your review of other materials, did that house include a 18 room that was used as a massage room? 19 A. Yes. 20 Q. Turning to the next property. Did Epstein also 21 own a ranch in New Mexico? 22 A. Yes, he did. 23 Q. And turning to the next slide. Was that property 24 located at 49 Zorro Ranch Road in Stanley, New Mexico? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000138 EFTA00008638 06/29/20 9 Q. Looking at the photograph on this slide, does this 2 accurately depict that property? 3 A. Yes, it does. 4 Q. And we've been talking about the properties that 5 Epstein owned during this time period. Did he also own a 6 private jet? 7 A. Yes. 8 Q. Is it fair to say that he was a multimillionaire 9 during this time period? 10 A. Yes. 11 Q. During the 1990's did Epstein have an employee 12 who ran his house in Palm Beach? 13 A. Yes, he did. 14 Q. What was his job? 15 A. His job was making sure that everything in the 16 house ran smoothly. He referred -- he described that 17 Epstein liked to have his house run live a five-star hotel; 18 that everything had to be in its proper place. So he was 19 responsible for managing that. 20 Q. Have you interviewed 21 A. Yes. 22 Q. How many times? 23 A. Twice. 24 Q. And is the information you're about to provide 25 based on your interviews with FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000139 EFTA00008639 06/29/20 1D A. Yes. 2 Q. Did begin working for Epstein in the early 3 1990's? 4 A. Yes, he did. 5 Q. And at the time came to work for Epstein in 6 Palm Beach, was Epstein dating Ghislaine Maxwell at that 7 point? 8 A. Not at that time. 9 4. Was it a few years before Epstein began dating 10 Maxwell after started working there? 11 A. Yes. 12 Q. From what told you, how did 13 work change once Maxwell arrived on the scene? 14 A. described Epstein as being more pleasant to 15 work with prior to Maxwell coming into the picture. Once 16 she came into the picture, he said things became more 17 secretive. He wasn't allowed to be in the room with guests, 18 wasn't allowed to talk with them, associate with them. It 19 became a different environment. 20 Q. You talked about some of the rules that were 21 placed changing. Were there any rule changes about eye 22 contact once Maxwell began staying in the Palm Beach house. 23 A. Yes. wasn't allowed to make eye contact 24 with Epstein and others. 25 Q. In general, how did he describe what it was like FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GUDNYJODOOPM EFTA00008640 06/29/20 11 1 to work for Maxwell? 2 A. He said she was very demanding; she was on top of 3 him all the time. He described her as a "bitch." 4 Q. Is that the word that he used? 5 A. That is the word he used. 6 Q. Shifting gears. I want to talk to you about 7 someone else that you've interviewed during this 8 investigation. During the course of this investigation, 9 have you participated in interviews with an individual named 10 11 A. Yes. 12 Q. So for these purposes I'm just going to refer to 13 her as Is that okay? 14 A. Yes. 15 Q. How many times have you interviewed 16 A. Approximately five times. 17 Q. If you could please just page through the next two 18 slides in front of you. Are these photographs of 19 A. Yes. 20 Q. Is it your understanding that these photographs 21 depict from approximately ages 13 to approximately 17? 22 A. Yes, it does. 23 Q. Okay. Let's take a look at some of those 24 photographs. I'm going to publish the next slide. Is 25 date of birth FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000141 EFTA00008641 06/29/20 12 A. Yes. 2 Q. And are these two photographs of 3 A. Yes, they are. 4 Q. If you could turn to the second slide of 5 photographs. Are these also photographs of 6 A. Yes. 7 Q. Based on your participation in this investigation 8 and your interviews with where was she living when 9 she was approximately 14? 10 A. She was living in Palm Beach, Florida. 11 Q. Who was she living with when she was 14? 12 A. Her mother and her siblings. 13 Q. What was her whole life like at that time? 14 A. At that time, her father had passed away the year 15 prior, so the family was struggling financially and having 16 some difficulties. 17 Q. What did father do before he passed away? 18 What was his profession? 19 A. He was involved in 21 Q. Was involved in 22 A. Yes, she was. 23 Q. Were her siblings? 24 A. Yes. 25 Q. What kinds of were they involved in? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_OOOOO142 EFTA00008642 06/29/20 A. Singing, she was a singer. 2 Q. Like what kind of singer? 3 A. Opera. 4 Q. In the summer of 1994, how old was 5 A. She was 13 going on 14. 6 Q. You testified earlier that her birthday is in 7 , so did she turn 14 in of 1994? 8 A. Yes. 9 Q. What did she do that summer? 10 A. She attended an arts camp at Interlochen Certer 11 for the Arts. 12 Q. And is Interlochen Summer Arts Program located in. 13 Michigan? 14 A. Yes. 15 Q. Did meet Jeffrey Epstein and 16 Ghislaine Maxwell that summer? 17 A. Yes, she did. 18 Q. Did she meet them at summer camp? 19 A. Yes. 20 Q. What did she tell you about that? 21 A. She said that she was sitting at a picnic table 22 with friends when Epstein and Maxwell walked by. They 23 stopped to talk to her, engaged her in conversation, asked 24 her if she liked her classes, her teachers. During that 25 conversation, they found out that she was also from Palm FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_OOOOO143 EFTA00008643 06/29/20 14 Beach and that he said that he gives scholarships to 2 students. 3 Q. How did they leave the conversation? Was there 4 any contact information exchanged? 5 A. They asked for phone number. 6 Q. As part of your investigation, have you attempted 7 to gather records to corroborate that Maxwell, and 8 Epstein were all at that summer camp that summer? 9 A. Yes. 10 Q. If you could turn to the next slide, please. na 11 you obtained records from Interlochen for the summer of 12 1994? 13 A. Yes. 14 Q. And what are we looking at on this slide? 15 A. This shows who -- some of the individuals that 16 were there -- were present for that camp in '94. On here is 17 and 18 Q. And have you investigated whether Maxwell and 19 Epstein were also at Interlochen that summer of 1994 as 20 described? 21 A. Yes. 22 Q. Based on your review of records from Interlochen, 23 what is your understanding of Epstein's relationship with 24 Interlochen? 25 A. My understanding was that he was a donor to the FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000144 EFTA00008644 06/29/20 school. 2 Q. Did he make any substantial donations? 3 A. He did. 4 Q. Did he donate a lodge to the camp in the summer of 5 1994? 6 A. Yes, he did. 7 Q. Did he have a long standing relationship as a 8 donor to Interlochen? 9 A. Yes. 10 Q. Turning to the next slide. Is this an excerpt o: 11 a letter from Interlochen to Epstein? 12 A. Yes, it is. 13 Q. And does this letter thank Epstein for donating a 14 scholarship lodge? 15 A. Yes. 16 Q. Does it invite Epstein to visit in August of 1994? 17 A. Yes. 18 Q. In 1994, did Epstein have a private jet? 19 A. Yes, he did. 20 Q. Have you obtained the flight logs for that jet 21 A. Yes. 22 Q. Do those logs include passenger lists and the 23 airport code for the airports that the plane flew into and 24 out of? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_OOOOO145 EFTA00008645 06/29/20 16 4. Turning to the next slide. Is this a page of the 2 flight logs that you've reviewed? 3 A. Yes. 4 Q. And on this excerpt of the flight logs where the 5 red arrow is, is that a log entry showing an August 18, 1994 6 flight to an airport with the airport code TVC? 7 A. Yes. 8 Q. Is TVC the airport code for Cherry Capital Airpor - 9 in Traverse City, Michigan? 10 A. Yes, it is. 11 Q. About how far is that airport from Interlochen by 12 car? 13 A. It's about 25 minutes give or take. 14 Q. And who were the listed passengers on this flight? 15 A. Jeffrey Epstein, (ph.), and (ph.). 17 Q. Turning to the next slide. Is this the same 18 excerpt but just with a different arrow? 19 A. Yes. 20 Q. Okay. So a few lines down is there a flight out 21 of Traverse City just two days later on August 20th, 1994? 22 A. Yes. 23 Q. And do the passengers listed in the flight out of 24 Traverse City include the initials G.M.? 25 A. Yes, they do. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000146 EFTA00008646 06/29/20 i Q. Are those Ghislaine Maxwell's initials? 2 A. Yes. 3 Q. Have you obtained any records from Interlochen to 4 indicate that Maxwell was at Interlochen in 1994? 5 A. Yes. 6 4. If we could turn to the next slide. Can you 7 please explain for the grand jury what we're looking at on 8 this slide? 9 A. This was a letter from Interlochen explaining 10 addressed to Maxwell telling her that they had found an 11 envelope in the lodge that they had been staying in. 12 Q. All right. We were talking a few moments ago 13 about how described meeting Maxwell and Epstein at 14 summer camp, and you testified that she provided them with 15 her phone number. Did explain to you whether or not 16 she had any contact with Epstein or Maxwell after she 17 returned home to Palm Beach? 18 A. Yes. 19 Q. When was the next time that happened? 20 A. Shortly thereafter. 21 Q. And how did that occur? 22 A. She was invited to his house. So her and her 23 mother went to Epstein's house to visit. 24 Q. What did tell you about that visit to 25 Epstein's house with her mother? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000147 EFTA00008647 06/29/20 18 A. She said it was wait, can you rephrase that? 2 Q. Of course. Did go to the house by herself 3 or with her mother? 4 A. With her mother. 5 Q. Okay. And when they went to the house, what did 6 they do there? 7 A. They had tea. 8 Q. Who was there when they had tea at the house? 9 A. Epstein and Maxwell. 10 Q. What did they discuss as they had tea? 11 A. They just talked about her life and, you know, 12 what she wanted to do. 13 Q. Did Epstein make any offers? 14 A. He said that he gives scholarships. He likes to 15 mentor people. 16 Q. How did mother react when Epstein said 17 this? 18 A. She was happy for her daughter and oftentimes 19 referred to Epstein as Godfather. 20 Q. After that occasion when they went over to the 21 house, thereafter did subsequently begin regularly 22 spending time with Maxwell and Epstein at Epstein's house in 23 Palm Beach? 24 A. Yes. 25 Q. And did that start when she was approximately age FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000148 EFTA00008648 06/29/20 19 14? 2 A. Yes. 3 Q. Did it continue until she was about age 17? 4 A. Yes, it did. 5 Q. And during those years, did she regularly go over 6 to Epstein's house in Palm Beach and spend time with Maxwell 7 and Epstein? 8 A. Yes. 9 Q. What happened in the summer of 1997 when 10 was 17 and about to turn 18? 11 A. She moved to New York City. 12 Q. Why did she move to New York City? 13 A. She wanted to pursue a career in acting and 14 modeling. 15 Q. We'll talk about that in a moment, but for now I 16 want to focus on the years you talked about in Palm Beach 17 from ages 14 to 17 when would regularly go to 18 Epstein's house. In the beginning, in the first few months 19 when she went there, what kinds of things did she do when 20 she would visit the house when Maxwell and Epstein were 21 there? 22 A. They'd hang out by the pool, he -- they would take 23 her to the movies, take her shopping. She described the 24 behavior as grooming. 25 Q. When you say grooming, did she explain what sh, FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000149 EFTA00008649 06/29/20 20 1 meant by that? 2 A. She meant that they were building a relationship 3 with her, giving her things, taking her places. And then 4 usually when the grooming happens, an offender will -- once 5 they gain that trust, they will make the relationship turn 6 sexual. 7 Q. Now, you testified just a moment ago that 8 described to you that she felt at this time period that they 9 were grooming her. Is that right? 10 A. Yes. 11 Q. Is that something that she realized at the time 12 when she was 14, or is that something that she's described 13 to you now? 14 A. Something she's described now. She didn't realize 15 that at the time. 16 Q. So we'll talk a little bit more about grooming in 17 a moment, but just to give context are you familiar with the 18 term grooming based on your experience investigating crimes 19 involving a sexual exploitation of minors? 20 A. Yes. 21 Q. Generally speaking, -- you were touching on this a 22 moment ago, but if you just could explain in full. What is 23 grooming? 24 A. Grooming is when someone builds a relationship 25 with a child. They find a vulnerability or a need and then. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000150 EFTA00008650 06/29/20 21 1 they work on gaining a child's trust, and then oftentime 2 gaining a parent's trust. Once they have that trust, they 3 show that in ways that they care about them by giving them 4 gifts and promises. And then once that's established, they 5 then turn the relationship sexual, oftentimes making sexual 6 comments and normalizing the behavior. 7 4. Now, during these visits that you've been 8 describing that told you about, did say whether 9 Epstein ever gave her anything? 10 A. Yes, she did. 11 Q. What did he give her? 12 A. He gave her cash. Sometimes he'd tell her to give 13 the cash to her mom because he knew that they needed it. He 14 paid for her voice lessons as well. 15 Q. Now, you were describing how has 16 characterized these visits now. But based on your 17 conversations with her, at the time did she feel that these 18 visits were strange at all? 19 A. She thought they were strange, but Maxwell 20 normalized it for her. She was like a cool older sister and 21 made comments like this is what grownups do. 22 Q. You used the phrase cool older sister. Is that a 23 phrase that used to describe how she felt about 24 Maxwell at the time and what Maxwell was like? 25 A. Yes, those are her words. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_0000015 I EFTA00008651 06/29/20 22 Q. Did there come a time -- these visits when 2 saw Maxwell topless by the pool? 3 A. Yes. 4 Q. What did she tell you about that? 5 A. She was a little taken back, but Maxwell just 6 acted normal. 7 Q. Did tell you about an incident several 8 months into this arrangement when she was alone with Epstein 9 in the pool house? 10 A. Yes. 11 Q. And when they were alone together, did Epstein ask 12 what she wanted to do with her life? 13 A. He did. 14 Q. What did she say? 15 A. She said she wanted to be an actress and a model. 16 Q. How did Epstein respond? 17 A. He told her that he was best friends with the 18 owner of Victoria Secret. Told her that she would have to 19 have photographs taken and that she got to be comfortable in 20 her underwear, and not to be a prude. When she asked what 21 that meant, he pulled her to his lap and masturbated. 22 Q. What was her reaction? 23 A. She felt paralyzed. She froze. 24 Q. After this incident, did encounters with 25 Epstein begin to include sexual contact? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_OOOOO152 EFTA00008652 06/29/20 23 A. Yes. 2 Q. Over time, did the sexual abuse escalate? 3 A. It did. 4 Q. From what she's described to you, did the abuse 5 include Epstein digitally penetrating 6 A. Yes. 7 Q. Did it include Epstein using a vibrator on her? 8 A. Yes. 9 Q. Did she describe to you that there were times when 10 Epstein would direct to massage him while he 11 masturbated? 12 A. Yes. 13 Q. Did explain to you what her memories are 14 like of the abuse? 15 A. Yes. 16 Q. What did she say about that? 17 A. She said that it happened so often that it all 18 kinds -- it all runs together for her. That it's hard to 19 separate out some of the different instances of abuse. 20 Q. You were describing how explained to you 21 that the abuse began. Did that occur based on what 22 told you within the first year that she met Epstein and 23 Maxwell? 24 A. Yes. 25 Q. Now, did also describe to you that once this FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000153 EFTA00008653 06/29/20 24 abuse started, Epstein would also bring her into his massatl 2 room in the house? 3 A. Yes. 4 Q. And were there times where he did this where there 5 are other women present including Maxwell? 6 A. Yes. 7 Q. Was abused during those episodes? 8 A. Yes, she was. 9 Q. During these group encounters what were and 10 the adult women wearing? 11 A. They were usually just in their underwear. 12 Q. Once they were all in the massage room, how wou..a 13 these episodes generally start? 14 A. They would generally start with one of the girls 15 massaging Epstein. was usually massaging his fee-. 16 Maxwell was kind of teasing the girls; she'd grab the girls' 17 breasts and she would direct the girls on what to do. 18 Q. When these episodes would start, in general was 19 Epstein generally lying face down on the massage table? 20 A. Yes. 21 Q. What would happen as things progressed generally 22 speaking from what she described to you? 23 A. When Epstein would decide he was kind of done with 24 the regular massage, he would turn over to his back and he'd 25 grab whichever girl he wanted to either touch him or FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000154 EFTA00008654 06/29/20 95 1 whatever girl he wanted to touch. 2 Q. Did these episodes include sex acts that over time 3 in various instances included Epstein masturbating, Epstein 4 receiving oral sex, and Epstein engaging in intercourse? 5 A. Yes. 6 Q. You were describing for a moment what to_ 7 you about Maxwell's role during these group encounters. 8 Would Maxwell sometimes guide the women and give 9 instructions about what to do? 10 A. Yes, she would. 11 Q. What would typically do during these 12 episodes? 13 A. She would try to not look at Maxwell because she 14 gave off that sister vibe so it felt weird for her. She 15 would try to be invisible in that room so they would ignore 16 her as much as possible. 17 Q. In the beginning when was approximately 14 18 or 15, would she generally begin by just massaging Epstein's 19 feet? 20 A. Yes. 21 Q. Is that something she was told to do? 22 A. Yes. 23 Q. Did she -- you mentioned that she tried to be 24 invisible. Was -- I believe that was your testimony? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000155 EFTA00008655 06/29/20 26 Q. And over time -- has she described to you that 2 over time she believes she became more involved in the 3 sexual activity which varied in each encounter? 4 A. Yes. 5 Q. Were there times -- let me rephrase that. How did 6 you touched on this for a moment, but just to be clear, 7 how did describe Maxwell's attitude during these 8 incidents? 9 A. It was very casual. She acted like this was 10 normal. She gave off that vibe to her and -- yeah. 11 Q. Did that make her feel more comfortable with what 12 was happening? 13 A. It did. 14 Q. Was sometimes fully nude during these 15 episodes? 16 A. Yes. 17 Q. And during these episodes, did the abuse include 18 Epstein touching breast? 19 A. Yes. 20 Q. Did it include directing to touch Epstein's 21 genitals? 22 A. Yes. 23 Q. Beginning when was approximately 14, does 24 she begin to travel with Epstein and Maxwell to New York 25 City on occasion? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000156 EFTA00008656 06/29/20 27 A. Yes, she did. 2 Q. Was that to the property you testified about 3 earlier? The townhouse on the Upper East Side? 4 A. Yes. 5 Q. When traveled to New York City, did she stay 6 at Epstein's townhouse in New York City? 7 A. Yes, she did. 8 Q. Did she recall that Maxwell and Epstein took her 9 shopping on one of her early trips to New York City? 10 A. Yes. 11 Q. Did she remember them buying her anything? 12 A. She recalled them buying her white cotton 13 underwear. Her description was that they were, like, little 14 girls underwear. 15 Q. From ages 14 to 17, did Epstein ask to 16 periodically fly to New York for weekends at that townhouse 17 in New York? 18 A. I'm sorry, say it again? 19 Q. You testified that she began traveling to New York 20 City at age 14. Did she then periodically travel to New 21 York City in a similar manner from ages 14 to 17? 22 A. Yes. 23 4• Were there times when she traveled on those trips 24 when she flew on Epstein's private jet? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000157 EFTA00008657 06/29/20 99 Q. Did she also sometimes fly commercially? 2 A. Yes, she did. 3 Q. Was Maxwell sometimes present on the trips to New 1 York? 5 A. Yes. 6 Q. You testified earlier that was sexually 7 abused in Palm Beach. Did she describe to you that she was 8 also sexually abused on these trips to New York? 9 A. Yes, she did. 10 Q. Did Maxwell encourage to go on these trips? 11 A. Yes. 12 Q. What does -- what did tell you about 13 her memory of how these trips were arranged? 14 A. She recalled that Maxwell was usually the one that 15 would schedule her flights. If she was flying commercially, 16 she would schedule the flights, sometimes calling her mother 17 to schedule. 18 Q. Was that her general impression of how they were 19 arranged? 20 A. Yes. 21 Q. In addition to the trips to New York City that you 22 just described, did also remember traveling at least 23 once to Epstein's ranch in New Mexico? 24 A. Yes, she did. 25 Q. Did she remember whether or not she was sexually FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000158 EFTA00008658 06/29/20 29 abused in New Mexico? 2 A. She couldn't recall. She couldn't remember. 3 Q. In general, how would get to the airport in. 4 Florida when she would fly on Epstein's jet? What did she 5 describe to you? 6 A. Usually a driver one of Epstein's drivers would 7 pick her up from her house and take her to the airport. 8 Q. Now, you testified earlier that you reviewed 9 flight records for Epstein's private jet. Is that correct? 10 A. Yes. 11 Q. And have you reviewed records from the 1990's 12 see if that there -- whether there's a person named 13 listed on the records? 14 A. Yes. 15 Q. Turning to the next slide. Is this an excerpt 16 from those records? 17 A. Yes, it is. 18 Q. And does the red arrow point to -- just one 19 moment. Does the red arrow point to a November 11th, 1996 20 flight? 21 A. Yes, it does. 22 Q. And is this a -- does this flight log reflect that 23 it was a flight from Palm Beach, Florida to Teterboro, New 24 Jersey? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000159 EFTA00008659 06/29/20 30 Q. Is there a private airfield in Teterboro, New 2 Jersey? 3 A. Yes, there is. 4 Q. What's it called? 5 A. Teterboro Airport. 6 Q. Are the passengers listed on this entry J.E.? 7 A. Yes. 8 Q. Are the -- do the entries also include olu 9 friend, (ph.), family, III (ph.) child, 10 (ph.), and 11 A. Yes. 12 Q. Was -- based on your awareness of 13 date of birth and the date of this flight, was 16 on 14 the date of this flight? 15 A. Yes, she was. 16 Q. Turning to the next slide. You testified earlier 17 about Teterboro Airport. What are we looking at on this 18 slide? 19 A. This is directions from Teterboro Airport to 20 Epstein's residence here in Manhattan. 21 Q. So based on your review of this map, if someone 22 were to fly into Teterboro Airport and travel to New York 23 City, would they -- would the most natural root be to travel 24 from Teterboro Airport and crossing into New York through 25 Manhattan? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000160 EFTA00008660 06/29/20 31 A. Yes. 2 Q. Turning to the next slide. Is this also an 3 excerpt from the flight records that you've reviewed? 4 A. Yes, it is. 5 Q. And does this show a May 9, 1997 flight from 6 Teterboro, New Jersey to Santa Fe, New Mexico? 7 A. Yes, it does. 8 Q. And are the passengers listed on this log J.E., 9 G.M., 10 A. Yes. 11 Q. Based on your knowledge of birthdate and 12 the date of this flight, would have been 16 on the 13 date of this flight? 14 A. Yes, she would've been. 15 Q. Turning to the next slide. Is this also an 16 excerpt from the flight records? 17 A. Yes. 18 Q. And does the red arrow point to a flight entry on 19 May 3rd, 1998? 20 A. Yes, it does. 21 Q. Based on the airport codes, does this reflect that 22 there is a flight on that date from Palm Beach, Florida to 23 Teterboro, New Jersey? 24 A. Yes. 25 Q. And are the passengers listed on this log J.E., FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000161 EFTA00008661 06/29/20 32 G.M., E.T., Glen (ph.), (ph.), 2 (ph.), Manny (ph.), (ph.)? 3 A. Yes. 4 Q. Based on your knowledge of birthdate and 5 the date of this flight, would have been 17 on this 6 date? 7 A. Yes. 8 Q. Am I correct that you testified earlier that in 9 addition to sometimes flying on Epstein's private jet, she 10 also traveled on commercial airlines, is that correct? 11 A. Yes, it is. 12 Q. Based on your review of these flight logs, does 13 every flight entry list the name of every single passenger, 14 or are there times when a passenger is noted female? 15 A. There's time where a passenger is just noted 16 female. 17 Q. I'm going to talk to you about two examples of 18 that. Turning ahead two slides. Looking at slide 18, does 19 this reflect a January 3rd, 1995 flight where the flight log 20 says J.E., two females? 21 A. Yes, it does. 22 Q. And do the two entries below also just list fema_ , 23 next to the initials J.E.? 24 A. Yes, they do. 25 Q. Turning to the next slide, slide 19. Is this FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000162 EFTA00008662 06/29/20 33 another example of an entry like that? Focusing on the 2 entry on February 12th, 1995? 3 A. Yes. 4 Q. Does that entry also say female? 5 A. Yes, it does. 6 Q. Now, you testified that sometimes flew on 7 commercial airlines and that arrangements for her travel 8 were made for her to fly commercially for these trips. 9 that right? 10 A. Yes. 11 Q. Have you been able to obtain commercial flight 12 records? 13 A. We tried. We were not able to obtain those 14 records. 15 Q. Why is that? 16 A. Airlines do not keep records past a certain year. 17 Q. Does recall group sexualized massages 18 involving Epstein and Maxwell in both the New York and 19 Florida residences during the time period we've been talking 20 about? 21 A. Yes. 22 Q. You testified earlier about the time that Epstein 23 and Maxwell would spend together and the activities that 24 they were involved in. During this time period, did 25 have occasions to talk with Maxwell? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000163 EFTA00008663 06/29/20 34 A. She -- I'm sorry, can you ask the question again? 2 Q. During the -- beginning when she was 14 when she 3 began spending time with Epstein and Maxwell and through the 4 years, did often have conversations with Maxwell about her life? 6 A. Yes. 7 Q. Did they talk about that often? 8 A. They did. 9 Q. Did Maxwell ask about her family, her 10 classes, and other aspects of her life? 11 A. Yes, she did. 12 Q. You testified earlier that just before she turned 13 18, moved to New York City. Is that right? 14 A. Yes. 15 Q. Did she go to school there in New York City for 16 her senior year? 17 A. Yes, she did. 18 Q. What school did she go to? 19 A. She went to 20 Q. What is 21 A. They cater to individuals who want to pursue 22 careers in the arts. 23 Q. Have you reviewed records from 24 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000164 EFTA00008664 06/29/20 35 Q• If you could turn to slide 17. Can you please 2 explain for the grand jury what we're looking at here? 3 A. This is an excerpt from application to III 4 On it is listed who is 5 financially responsible for her, and that is 6 Jeffrey Epstein. 7 Q. From what told you, did Maxwell encourage 8 to accept Epstein's financial help? 9 A. Yes. 10 Q. When moved to New York City who was she 11 living with? 12 A. She lived with her mother and brother in 13 14 Q. Did Epstein help pay for her rent? 15 A. He did. 16 Q. During that year, her senior year of high school 17 when she was in New York City, did remain in contact 18 with Epstein? 19 A. Yes. 20 Q. What was the nature of their contact like during 21 this time period? 22 A. During this time he was still sexually abusing 23 her. 24 Q. Did that continue to occur in his townhouse in 25 Manhattan that year? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000165 EFTA00008665 06/29/20 35 A. Yes, it did. 2 Q. What happened at the end of her senior year of 3 high school? 4 A. She moved to Los Angeles to pursue a career in acting. 6 Q. Did she get a job as an actress when she was 18? 7 A. She did. 8 Q. Has lived in Los Angeles and worked as an 9 actress on television ever since then? 10 A. Yes. 11 Q. After she moved to Los Angeles did she continue 12 being in touch with Epstein? 13 A. For a short period of time. 14 Q. Did she ultimately break contact with him? 15 A. Yes, she did. 16 Q. Is currently pursuing a civil lawsuit 17 against Maxwell and Epstein's estate? 18 A. Yes. 19 Q. Have you talked with about whether when she 20 was a teenage girl when all of this was happening whether 21 she told anyone that she was being sexually abused? 22 A. Yes, she said she didn't tell anyone. She te_ 23 like she couldn't. She -- the -- nothing was talked about 24 outside of that room, so it made it so that she couldn't 25 talk about it. And then she also -- her mother is Middle FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000166 EFTA00008666 06/29/20 1 Eastern, and her mother raised her that women are supposed 2 to do what they're told even if someone is beating you. 3 And when she was 13 and her father passed, she was 4 -- she went to a guidance counselor at school to talk about 5 it, and her mother found out about it and smacked her. So 6 she felt like she couldn't talk to anyone about it. 7 Q. Did mother encourage her to accept 8 Epstein's financial assistance? 9 A. Yes, she did. 10 Q. Have you become aware that in 2005, police 11 officers from the Palm Beach Police Department executed a 12 search warrant at Epstein's house at the El Brillo Way 13 address in Palm Beach? 14 A. Yes. 15 Q. Have you reviewed some of the materials seized 16 during the search? 17 A. Yes. 18 Q. Did they find massage tables and sex toys? 19 A. Yes, they did. 20 Q. Did they find any photographs of 21 A. Yes. 22 Q. Was one of the photographs signed by 23 A. Yes, it was. 24 Q. Did it say FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000167 EFTA00008667 06/29/20 A. Yes. 2 Q. During your interviews with did tell 3 you how she felt about Epstein and Maxwell in the '90's when 4 she was a young girl? 5 A. She did. She expressed that she felt like they 6 loved her, she felt like they were her family. That they 7 supported her and that she felt she was made to feel like 8 that she needed to be grateful to them. 9 Q. Okay. Did she tell you that she felt like they 10 were trying to help her? 11 A. Yes. 12 Q. Have you talked with about how she feels 13 about this now? 14 A. Yes. 15 Q. What was demeanor like when she described 16 to you what Epstein and Maxwell had done to her? 17 A. She was upset. She recognized that now, it's 18 affected her life to a great degree. She's struggled in 19 relationships with opening up to people and trusting people, 20 both personal and professional relationships. 21 Q. Did she tell you that she struggled to tell anyone 22 what had happened to her for most of her adulthood? 23 A. Yes. 24 Q. When was the first time that you interviewed 25 FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000168 EFTA00008668 06/29/20 39 A. Last fall. 2 Q. Was that the first time she'd ever reported this 3 to law enforcement? 4 A. Yes, it was. 5 Q. Now, you testified earlier about your interviews 6 with who worked at Epstein's Palm Beach house. 7 Did he remember a girl named coming to the house 8 during that time? 9 A. Yes, he did. 10 Q. Did he recall Maxwell, and Epstein being in 11 the Palm Beach house together? 12 A. Yes. 13 Q. What was his understanding of why was there? 14 A. He thought that Epstein was helping her, that' 15 what Epstein had told him, and had told him that 16 Epstein was helping her. 17 Q. Did he ever observe Epstein interacting with 18 physically? 19 A. Yes. 20 Q. What did he see? 21 A. He saw Epstein kiss cheek and pat her on 22 the bottom. 23 Q. Did he have any knowledge about what was happening 24 with Epstein or Maxwell when he wasn't present? 25 A. He didn't. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000169 EFTA00008669 06/29/20 40 Q. Did ever recall picking up from her 2 house? 3 A. Yes. 4 Q. And when he would pick her up from her house, 5 would he then bring her back to the Palm Beach house: 6 A. Yes. 7 Q. Did he remember who in general would tell him to 8 pick up from her house? 9 A. Maxwell would be the one to tell him to pick her 10 up. 11 Q. Did he recall ever driving to the movies? 12 A. Yes. 13 Q. What did he tell you about that? 14 A. That it would usually be Epstein, Maxwell, anc 15 They'd go to the movies and it would usually be late 16 at night. 17 Q. Did he tell you about what his memory was about 18 how old was? 19 A. He said she was young and that he knew that 20 because he had picked her up from school and that he knew 21 she was too young to drive. 22 Q. Switching gears. I want to talk to you about a 23 different aspect of your interviews with Based 24 on what he told you about his job duties, were there ever 25 times when he would have to clean Epstein's massage room? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000170 EFTA00008670 06/29/20 41 A. Yes. 2 Q. What did he tell you about that? 3 A. He said that he found sex toys in the massage room 4 and he had to wash them afterwards. 5 Q. Aside from those experiences, was he aware of 6 there being sex toys in the house? 7 A. Yes. There was a basket of sex toys that were 8 kept in Maxwell's closet. 9 Q. Did stop working for Epstein in 10 approximately 2002? 11 A. Yes. 12 Q. Was he told that he was being replaced? 13 A. Yes. 14 Q. And was he generally aware that the person who 15 replaced him was much younger? 16 A. Yes. 17 Q. Did tell you that a few months after he 18 left working for Epstein he became suicidal because of 19 issues in his marriage? 20 A. Yes. 21 Q. Did he tell you that he went to Epstein's house 22 and tried to take Epstein's gun? 23 A. Yes, he did. 24 Q. Did he tell you he took several thousand dollars? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000171 EFTA00008671 06/29/20 42 Q. Did Epstein discover this and confront him about 2 it? 3 A. Yes, he did. 4 Q. Did admit to Epstein and the police what he'd done? 6 A. Yes. 7 Q. Did Epstein also tell the police his gun was 8 missing? 9 A. Yes. 10 Q. Were there any charges filed? 11 A. No. 12 Q. Was he ever arrested? 13 A. I don't believe so. 14 Q. And did Epstein pursue any charges about this 15 incident? 16 A. No, he didn't pursue anything. 17 Q. Have you interviewed one of Epstein's former 18 pilots? 19 A. Yes. 20 Q. Is that pilot named 21 A. Yes. 22 Q. Was he one of the pilots for Epstein's private jet 23 in the 1990's? 24 A. Yes. 25 Q. Did he remember traveling on the je FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GJ_SDNY_00000172 EFTA00008672 06/29/20 in the 90's? 2 A. He remembered her traveling, but he didn't 3 remember specifics. 4 Q. So just to be clear, is your testimony that he 5 didn't remember the specific dates of the flights, but he 6 remembered her traveling on the jet during the 1990's? 7 A. Yes. 8 Q. And did he remember specifically as 9 a person who traveled? 10 A. Yes. 11 Q. Did you discuss with him the flight records that 12 we talked about earlier that lists a person named as 13 passenger? 14 A. Yes. 15 Q. Did he have a specific memory of those exact 16 flights? 17 A. No. 18 Q. But was he aware of any other flying on the 19 jet besides in the 1990's? 20 A. No, no other at that time. 21 Q. Earlier when we were looking at Interlochen 22 attendance records for the summer of 1994, you noted tha 23 • was one of the names on that record. Is that 24 right? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000173 EFTA00008673 06/29/20 44 Q. Is that 2 A. Yes. 3 Q. Have you interviewed 4 A. Yes, I have. 5 Q. Did he tell you that he remembered talking 6 that summer at camp about having met Jeffrey Epstein? 7 A. Yes. 8 Q. Did he tell you that he remembered going 9 over to Epstein's house in Palm Beach when they were in high 10 school? 11 A. Yes. 12 Q. Did he remember that would often talk about 13 spending time with Maxwell and Epstein during this time? 14 A. Yes. 15 Q. Did he remember telling him when they were 16 in high school about at least one trip to New York City that 17 she took with Epstein? 18 A. Yes. 19 Q. Did he remember describing Epstein's 20 townhouse in Manhattan? 21 A. Yes. 22 Q. And does he remember talking often about 23 Ghislaine Maxwell? 24 A. Yes. 25 Q. Now, based on your interviews with did he FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000174 EFTA00008674 06/29/20 45 tell you whether he knew back then when they were in high 2 school whether was being sexually abused by Epstein? 3 A. He didn't know back then. 4 Q. Did III ever meet Ghislaine Maxwell? 5 A. Yes, he did. 6 Q. What did he remember about that? 7 A. He remembered Epstein, Maxwell, and being 8 near a movie theatre and he was approximately 16 at the time 9 and would've been 15, and just the little bit of 10 interaction they had. And then after that, had told 11 him that Maxwell had said something to the effect I could 12 teach a thing or two. 13 Q. Is that something that he remembers telling 14 him back then that Maxwell had said? 15 A. Yes. 16 Q. During the course of this investigation, have you 17 participated with interviews with an individual named 18 19 A. Yes. 20 Q. So for today's purposes I'm just going to refer to 21 her as How many times have you interviewed 22 A. Approximately twice. 23 Q. Now, does know Have they 24 ever met as far as you know? 25 A. As far as I know, no. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000175 EFTA00008675 06/29/20 46 Q. Turning to the next slide. Are these photographs 2 of when she was in high school? 3 A. Yes. 4 Q. And is her date of birth 5 A. Yes. 6 Q. When was approximately 16 and a junior in 7 high school, where was she living? 8 A. She was living in Arizona with her mother. 9 Q. Does she have any siblings? 10 A. An older sister. 11 Q. What did her older sister do? 12 A. Her older sister lived -- worked for Epstein. 13 Q. Where did she work for Epstein? 14 A. Here in New York. 15 Q. Did there come a time in approximately December 16 1995 when had a phone conversation with her sister 17 about traveling to New York City? 18 A. Yes. 19 Q. What did they discuss? 20 A. They discussed her coming to New York and meetinc 21 Epstein. 22 Q. What did her sister tell about why she 23 should meet Epstein? 24 A. She said that he could help her with college. 25 Q. And did she say -- did the sister say whether the FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000176 EFTA00008676 06/29/20 47 sister wanted her to meet Epstein or did she say whether 2 Epstein wanted to meet 3 A. Epstein wanted to meet 4 Q. Now, let me just pause here. You testified that 5 this happened in approximately December of 1995. Just for 6 context, the years that we were talking about with 7 was that 1994 through 1997? 8 A. Yes. 9 4. So is this approximately the same time period 10 while what you described telling you happened? 11 A. Yes. 12 Q. So in January of 1996, did fly on a 13 commercial airline to New York City to spend a weekend with 14 her sister and meet Jeffrey Epstein? 15 A. Yes. 16 Q. Did she tell you that? 17 A. Yes. 18 Q. During the trip, did tell you that she met 19 Epstein at his townhouse in New York City? 20 A. Yes, she did. 21 Q. Did she tell you that Epstein discussed her plan.,, 22 for college applications and offered to help her? 23 A. Yes. 24 Q. What was first impression of 25 Jeffrey Epstein? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000177 EFTA00008677 06/29/20 4P A. She was very impressed by him. 2 Q. What did she -- what was her impression based on 3 this conversation of what Epstein was going to do for her? 4 A. That he was going to help her with her future 5 plans for college. 6 Q• During that trip to New York City, did she stay at 7 Epstein's townhouse or at her sister's apartment? 8 A. Her sister's apartment. 9 Q. During that trip, did she tell you that she saw 10 Epstein a second time when he took and her sister to 11 the movies? 12 A. Yes. 13 Q. What did she tell you happened at the movies? 14 A. She said that they were sitting in the theatre and 15 Epstein was between and her sister, and Epstein put 16 his hand on her leg, he rubbed her arm and held hands with 17 her. 18 Q. From what she told you what was her impression 19 about whether her sister could see what was going on? 20 A. She felt like her sister couldn't see. 21 Q. What was her reaction to this happening? 22 A. She was uncomfortable. 23 Q. After the movie did she tell her sister what had 24 happened? 25 A. No, she didn't. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000178 EFTA00008678 06/29/20 49 Q. Did she say why not? 2 A. She said that she knew -- her sister really 3 liked Epstein and that Epstein could help them, so she 4 didn't tell her. Q. After this trip did go back home to 6 A. Yes. 7 Q. Did Epstein contact her afterwards? 8 A. Yes. 9 Q. Did he discuss with her her ongoing college plans? 10 A. Yes, he did. 11 Q. Did he invite her to a weekend at his ranch in New 12 Mexico in the spring of 1996? 13 A. Yes. 14 Q. Was she 16 at the time? 15 A. Yes, she was. 16 Q. From what she told you, what was 17 impression of who would be on this trip to New Mexico? 18 A. She knew Maxwell would be there. 19 Q. Did she -- was she told anyone else was going to 20 be present during this trip? 21 A. She said that there would be, like, other students 22 her -- kids her age. 23 Q. And what was her understanding of who these other 24 kids were and why they'd be there? Sorry, let me 25 A. Rephrase. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000179 EFTA00008679 06/29/20 50 Q. -- rephrase the questions. You testified that she 2 was told that on this trip that there would be other 3 students. Was she under the impression that there would be 4 other young students like her on the trip who were also 5 being mentored by Epstein? 6 A. Yes. 7 Q. Now, you testified just a moment ago that she was 8 also told that Maxwell would be there. Are you referring to 9 Ghislaine Maxwell? 10 A. Yes. 11 Q. At the point that she was told that 12 Ghislaine Maxwell would be on this trip, had she ever met 13 Ghislaine Maxwell? 14 A. No, she hadn't. 15 Q• Had she heard her sister talk about 16 Ghislaine Maxwell? 17 A. Yes. 18 Q. How did -- from what she described to you, how did 19 her expectation that Maxwell would be on this trip make her 20 feel about the trip? 21 A. It made her comfortable. Her sister had talked 22 highly of Maxwell. 23 Q. Did tell you that she flew to New Mexico 24 that spring when she was 16? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000180 EFTA00008680 06/29/20 51 Q. Did she meet Ghislaine Maxwell when she arrived in 2 New Mexico? 3 A. Yes, she did. 4 Q. How did she describe Maxwell's demeanor and 5 attitude when she met her? 6 A. She described Maxwell as being very charming. She 7 gave her a tour of the house and Maxwell took 8 shopping, which made her feel special. 9 Q. What does she remember talking about with 10 Ghislaine Maxwell? 11 A. They talked about school, homework, trips. 12 Q. Did she talk with her about applying to college? 13 A. Yes. 14 Q. Did she talk about her classes in high school? 15 A. Yes. 16 Q. Did she talk with her about the homework that she 17 had to do that weekend? 18 A. Yes. 19 Q. Did she talk with Maxwell about her family? 20 A. Yes. 21 Q. Did she talk with her about her home life and 22 living with her mother? 23 A. Yes. 24 Q. From what told you, when she got there who 25 else was at the ranch besides Ghislaine Maxwell and FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_0000018I EFTA00008681 06/29/20 52 1 Jeffrey Epstein? 2 A. It was just them. 3 4. Was it just the three of them the entire weekend 4 of the visit? 5 A. Yes. 6 Q. Were there any other school kids there? 7 A. No. 8 Q. When they were at the ranch, from what told 9 you, did Maxwell say anything to about massages? 10 A. Yes. 11 Q. Did she say anything to her about foot massages? 12 A. Yes. 13 Q. What did tell you about that? 14 A. Maxwell told to give Epstein a foot massage, 15 and then she showed her and instructed her how to do it. 16 was a little uncomfortable, but Maxwell was joking 17 around so she just followed her lead. 18 Q. Did tell you what Maxwell and Epstein took 19 her to the movies that weekend? 20 A. Yes. 21 Q. What did she tell you about that trip to t 22 movies? 23 A. She said that when they went outside the theatre 24 Maxwell was joking around and pulled Epstein's pants down a 25 little bit. And then once they went inside the theatre, FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000182 EFTA00008682 06/29/20 1 Epstein -- when they were sitting down, Epstein touched 2 leg, he rubbed her arm, held her hand. And this 3 time he -- felt that he wasn't trying to hide it from 4 Maxwell. 5 Q. What was reaction to all of this? 6 A. She was uncomfortable. 7 Q. During the same weekend, was there another 8 occasion when Maxwell talked about massages? 9 A. Yes. 10 Q. What happened? 11 A. Maxwell had asked if she ever had a massage, 12 and Maxwell told her she could give her one. So was 13 on her back and Maxwell had pulled the sheet down exposing 14 her chest, she was nude from the top up, and proceeded to 15 massage around her chest and breast area. 16 Q. From what told you when she was describing 17 to you what you just described to the grand jury, how did 18 she feel while this was happening? 19 A. She felt really uncomfortable. 20 Q. Did also tell you about an incident that 21 happened one morning when she was in New Mexico? 22 A. Yes. 23 Q. What did she tell you happened? 24 A. She said she was in bed and Epstein came into the 25 room and told her that he wanted to cuddle. So he laid down FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000183 EFTA00008683 06/29/20 54 next to her and spooned her. She told him she had to go tc 2 the bathroom to get out of the situation. 3 Q• What was her reaction to that when Epstein got 4 into her bed? 5 A. She was uncomfortable. She didn't know what to 6 do. 7 Q. Did go back home to when the weekend 8 was over? 9 A. Yes, she did. 10 Q. Did she tell anyone when she got home about what 11 happened? 12 A. No. 13 Q. Is that for the same reason you described earlier? 14 A. Yes. 15 Q. Did Epstein end up paying for to go on a 16 trip to Thailand that summer? 17 A. Yes. 18 Q. Did have any contact with Maxwell or Epstein 19 after that trip? 20 A. Not that she recalled. 21 Q. When you interviewed what was her demeanor 22 like when she described her interactions with 23 Jeffrey Epstein and Ghislaine Maxwell? 24 A. She became upset, emotional. 25 Q. Is currently pursuing a civil lawsuit FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000184 EFTA00008684 06/29/20 against Maxwell and Epstein's estate? 2 A. Yes, she is. 3 Q. What does do for a living now? 4 A. She's a psychologist who works with trauma 5 victims. 6 Q. During the course of this investigation, have you 7 interviewed someone named 8 A. Yes. 9 Q. For today's purposes, I'm just going to refer to 10 her as How many times have you interviewed 11 approximately? 12 A. Approximately three times. 13 Q. Turning to the next slide. Is this a photograph 14 of that she provided to you? 15 A. Yes. 16 Q. And did she tell you that this was taken when she 17 was in -- approximately 16 or 17 years old? 18 A. Yes. 19 Q. Is date of birth 20 A. Yes. 21 Q. Did grow up in England? 22 A. Yes, she did. 23 Q. Did she tell you that there came a point when she 24 met Ghislaine Maxwell when she was about 17? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000185 EFTA00008685 06/29/20 56 Q. How did she tell you that they met? 2 A. She said they met through a mutual friend. 3 Q. Did she tell you that this would've happened in 4 around 1994 or 1995? 5 A. Yes. 6 Q. And is that within the same time period that we've 7 been talking about today? 8 A. Yes. 9 Q. What happened after she was introduced to 10 Ghislaine Maxwell from what she told you? 11 A. She said Maxwell treated her like they were 12 sisters. Her quote was, "like naughty school girls" is how 13 Maxwell treated with -- her. 14 Q. Did she tell you that Maxwell seemed to 15 immediately take an interest in her? 16 A. Yes. 17 Q. Did she tell you that they began spending time 18 together in London? 19 A. Yes. 20 Q. And just to be clear, was Maxwell in her 30's 21 while this was happening? 22 A. Yes. 23 Q. Did Maxwell -- did ever remember Maxwell 24 ever talk about having a boyfriend named Jeffrey Epstein? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000186 EFTA00008686 06/29/20 Q. What did she tell about that? 2 A. Maxwell told that Epstein was going to 3 like her. 4 Q. Did there come a time when she was 17 that described that Maxwell introduced her to Jeffrey Epstein? 6 A. Yes. 7 Q. How did she describe that occurring? 8 A. Epstein had flown to London. He was at Maxwell's 9 residence in London and Maxwell had called over. So 10 went over and when she got there, Maxwell was saying 11 to Epstein kind of -- the words used was giving him 12 a resume of her attributes. Saying she's so pretty, she's 13 so strong, and then Maxwell asked her to give Epstein a 14 massage. 15 Q. Now, you testified just a moment ago that Maxwell 16 -- that described to you that Maxwell asked her to 17 give Epstein a massage during this first meeting. Is that 18 correct? 19 A. Yes. 20 Q. Did Maxwell say to her in sum and substance since 21 you're so strong I'd appreciate it if you give Jeffrey a 22 massage because he needs a massage every day or I get in 23 trouble? 24 A. Yes, she said that. 25 Q. Is that what said to you in sum and FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000187 EFTA00008687 06/29/20 substance? 2 A. Yes. 3 Q. When that happened, did remember Maxwell 4 leading her to a room in the house? 5 A. Yes. 6 Q• What happened? 7 A. When went in the room, Epstein was in a 8 robe. He took his robe off and she started massaging him, 9 and then he touched and pulled her hand to his 10 penis. 11 Q. What does remember Epstein saying when he 12 did this? 13 A. Don't be frigid. 14 Q. What was her reaction to this happening from what 15 she told you? 16 A. She was taken back by it. 17 Q. When this episode ended and left the room 18 did she tell you that she remembered Maxwell being just 19 outside the room when she left? 20 A. Yes. 21 4• Did she remember Maxwell saying to her, did you 22 have fun? Did he like it? 23 A. Yes. 24 Q. Does she remember Maxwell calling her several days 25 afterwards or at some short period of time afterwards? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000188 EFTA00008688 06/29/20 59 A. Yes, she did. 2 Q. Did remember Maxwell saying to her on the 3 phone call in sum and substance, well, aren't you a clever 4 girl, Jeffrey was very impressed? 5 A. Yes. 6 Q. Shortly after this incident, does she remember 7 Maxwell asking her to come back over to the house? 8 A. Yes. 9 Q. And when she got there did she tell you she 10 remembered Maxwell saying to her, in substance, thank God 11 you're here; if it's not you or someone it falls to me? 12 A. Yes. 13 4• Does she remember Maxwell bringing her up the 14 stairs to the house on that occasion? 15 A. Yes, she did. 16 Q. What does she remember happening when Maxwell 17 opened the door to the room? 18 A. Epstein was standing there nude. 19 4• Does she remember Maxwell then saying I'll leave 20 you guys to it? 21 A. Yes. 22 Q. After these first two encounters, did Epstein and 23 Maxwell invite to travel with them to Palm 24 Beach, U.S. Virgin Islands, Paris, and New York for the next 25 several years? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000189 EFTA00008689 06/29/20 60 A. Yes, they did. 2 Q. Does she remember whether these trips began before 3 or after her 18th birthday? 4 A. She couldn't remember specifically. 5 Q. Before these trips started, you were describing 6 earlier when told you about the time that she spent 7 with Maxwell when they first met when she was 17. Is that 8 right? 9 A. Yes. 10 Q. During these conversations when she would spend 11 time with Maxwell, did remember talking with her 12 about her life and her family, and her personal 13 circumstances with Maxwell? 14 A. Yes. 15 Q. Now, you testified a moment ago that told 16 you that at some point she began traveling with Maxwell and 17 Epstein, and she wasn't sure whether or not whether these 18 trips started before she turned 18. Is that right? 19 A. Yes. 20 Q. Did describe to you that Epstein sexually 21 abused her during these trips, typically in the context of a 22 sexualized massage? 23 A. Yes, he did. 24 Q. Did Epstein give her money? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000190 EFTA00008690 06/29/20 61 Q. Did she tell you that he would give her cash? 2 A. Yes. 3 Q. Did she describe to you that the abuse included, 4 among other things, Epstein groping her and using a massager 5 device on her genitals? 6 A. Yes. 7 Q. And was the massager device like a vibrator? 8 A. Yes, it was. 9 Q. From what told you, was Maxwell in the 10 room during these encounters? 11 A. Maxwell wasn't in the room. 12 Q. What did she tell you would typically happen when 13 left the room after these episodes; was Maxwell 14 typically nearby? 15 A. Yes. She was usually right near the room. 16 Q. Does she remember Maxwell asking her, after she'd 17 leave the room from one of these sessions, 'how was it, is 18 he happy?' 19 A. Yes. 20 Q. Did she also tell you that she remembers Maxwell 21 telling her at some point, in sum and substance, 'you know 22 how he is when he's not happy and you know what makes him 23 happy, he has to have sex all the time, he's like a super 24 hero?' 25 A. Yes, she said that. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000191 EFTA00008691 06/29/20 62 Q. Did tell you about an incident that 2 occurred after she turned 18 in Palm Beach when she was 3 staying at the Palm Beach house? 4 A. Yes. 5 Q. Did the incident she described to you involve a 6 school-girl outfit? 7 A. Yes, it did. 8 Q. Could you please describe for the grand jury what 9 told you about that incident? 10 A. said that Maxwell had shown her to a 11 bedroom and on the bed was a school-girl outfit and Maxwell 12 told her when -- confronted her about it and Maxwell 13 said 'well, I thought it would be adorable if you gave 14 Jeffrey his tea in this.' So felt like she had to 15 put it on so she put it on, took Epstein his tea, and 16 Epstein then slapped her on the buttocks and reached under 17 the skirt and touched her. 18 Q. What was her demeanor like when she described this 19 incident to you? 20 A. She was crying; she was very upset. 21 Q. When described seeing the school-girl 22 outfit and talking to Maxwell about it, did she remember 23 Maxwell telling her 'don't be so frigid?' 24 A. Yes. 25 Q. Does she remember that later in the day, after she FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000192 EFTA00008692 06/29/20 63 had delivered Epstein his tea and he assaulted her, does she 2 remember Maxwell telling her 'I heard you did well?' 3 A. Yes. 4 Q. During the years that was in contact with 5 Maxwell and Epstein did she remember whether Maxwell would 6 ever ask her if she knew any other girls who could massage 7 Epstein? 8 A. Yes. 9 Q. Does she remember Maxwell saying, in sum and 10 substance, 'do you know anyone who can give him a blow job 11 today; I don't feel like it?' 12 A. Yes. 13 Q. Does she remember Maxwell saying, when she asked 14 her to bring other girls, that they have to look young at 15 least? 16 A. Yes. 17 Q. From your conversations with did she tell 18 you whether or not she ever brought any other girls? 19 A. didn't bring any girls. 20 Q. Did she tell you why not? 21 A. She didn't want anyone else to go through that. 22 Q. From your interviews with did she tell you 23 that there came a time when she was in her early 20s when 24 she stopped traveling with Maxwell and Epstein? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000193 EFTA00008693 06/29/20 64 Q. Was she struggling with substance abuse at tha 2 point? 3 A. Yes, she was. 4 Q• Did she tell you that she got sober in her 20s? 5 A. Yes, she did. 6 Q. What is her current profession? 7 A. She runs a non-profit for people who struggle with 8 addiction and trauma. 9 Q. Did provide you with several emails that 10 she exchanged with Epstein in the early 2000s? 11 A. Yes, she did. 12 Q. And were those emails very friendly in tone? 13 A. Yes, they were. 14 Q. What did she say to you when you talked with her 15 about those emails? 16 A. She said she didn't, at the time, want to 17 acknowledge what was going on to her; that looking back on 18 it's different. 19 Q. Did your squad at the FBI execute a search warrant 20 at Jeffery Epstein's townhouse in Manhattan in July 2019? 21 A. Yes. 22 Q. Did you personally participate in the search of 23 Epstein's residence? 24 A. Yes, I did. 25 Q. Did the townhouse include a massage room? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000194 EFTA00008694 06/29/20 69 A. Yes. 2 Q. Have you yourself been in that massage room? 3 A. Yes, I have. 4 Q. Could you please describe for the grand jury what 5 that massage room looked like? 6 A. It was dark. It had dark draperies covering the 7 windows. There was a massage table. There were oils. 8 There was a hand-held massager in there along with 9 handcuffs, a whip, and along the walls were nude photographs 10 of young females. 11 Q. I believe you testified a moment ago tha- 12 told you that there was a time when Maxwell 13 asked her to wear a school-girl outfit for Epstein when they 14 were in Palm Beach. Did you find a school-girl outfit in 15 Epstein's New York townhouse? 16 A. Yes, we did. 17 Q. Where did you find it? 18 A. It was found in a room next to the massage room. 19 Q. And to be clear, did the FBI find sex toys during 20 the search? 21 A. Yes. 22 Q. What was found? 23 A. Butt plugs, dildo, vibrators. 24 Q. We've talked about three minor girls today, 25 and is that right? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000195 EFTA00008695 06/29/20 66 A. Yes. 2 Q. Have you reviewed the proposed indictment, marked 3 Grand Jury Exhibit 1? 4 A. Yes, I have. 5 Q. Is the individual referred to as Victim 1 in 6 the proposed indictment? 7 A. Yes. 8 Q. Is the individual referred to as Victim 2 in 9 the proposed indictment? 10 A. Yes. 11 Q. Is the individual referred to as Victim 3 12 in the indictment? 13 A. Yes. 14 Q. During all of Maxwell's interactions with the 15 victims when they were underage girls, based on the 16 timeframe and your knowledge of Maxwell's birth date, was 17 she in her 30s? 18 A. Yes, she was. 19 Q. Just one moment. All right. Switching gears. 20 Have you become aware that in or about 2016 Maxwell gave 21 sworn testimony in a civil deposition in connection with a 22 lawsuit? 23 A. Yes. 24 Q. Could you please explain for the grand jury what 25 is a deposition? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000196 EFTA00008696 06/29/20 67 A. It is a statement made under oath. 2 Q. And in the course of civil litigation is it common 3 for witnesses or the parties of the lawsuit to give a 4 deposition under oath where they testify about the substance 5 of the case? 6 A. Yes. 7 Q. And is deposition testimony live and in person and 8 under oath? 9 A. Yes. 10 Q. Is a court reporter present when a deposition 11 takes place? 12 A. Yes. 13 Q. Now before we talk about Maxwell's deposition 14 testimony, I want to talk with you about the lawsuit that 15 the testimony was about. Have you become aware that in or 16 about 2015 an individual named filed a 17 lawsuit against Ghislaine Maxwell here in the Southern 18 District of New York? 19 A. Yes. 20 Q. And was suing Maxwell for defamation? 21 A. Yes, she was. 22 Q. Was the lawsuit captioned against 23 Ghislaine Maxwell with Docket Number 15-CV-7433 here in the 24 Southern District of New York? 25 A. Yes. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000197 EFTA00008697 06/29/20 68 Q. Generally speaking, in broad strokes, what was the 2 lawsuit about? What was the claim that was bringing 3 against Maxwell? 4 A. had stated that she had been sexually 5 abused by Epstein and Maxwell as a minor. Maxwell came 6 forward publically and called her a liar. So 7 her for defamation. 8 MS. So just a small legal instruction on 9 this topic. Ladies and gentleman, I instruct you that the 10 allegations in the lawsuit are not being presented to you as 11 evidence that those incidents occurred. I instruct you that 12 you should not consider those allegations for their truth; 13 instead, the circumstances of the lawsuit are being 14 presented to you so that you can consider the context of the 15 case and the circumstances under which Maxwell made 16 statements under oath. 17 BY MS. 18 Q. Turning back to the deposition. Did Maxwell's 19 deposition take place over two different days? 20 A. Yes. 21 Q. On both days did she give testimony in Manhattan? 22 A. Yes, she did. 23 Q. Is that where the deposition took place? 24 A. Yes. 25 Q. And on both days was Maxwell sworn under oath? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000198 EFTA00008698 06/29/20 A. Yes. 2 Q. If you could flip through the remaining slides in 3 the presentation. Do those slides contain true and accurate 4 excerpts of the transcript of that deposition? 3 A. Yes. 6 Q. Turning to the next slide, is this the cover page 7 of the transcript of the first deposition that took place on 8 April 22, 2016? 9 A. Yes. 10 Q. And does it have the case caption on it? 11 A. Yes, it does. 12 Q. Turning to the next slide, is this an excerpt from 13 the transcript? 14 A. Yes. 15 Q. I imagine the grand juries can't read it from 16 their seats so if you could read it with me, I'll read the 17 questions and if you could read the answers. 18 Question: "Did Jeffrey Epstein have a scheme to 19 recruit underage girls for underage massages?" 20 And it appears there was an objection from the 21 lawyer. 22 Question: "If you know." 23 A. Answer: "I don't know what you are talking about." 24 Q. Just to be clear with the question and answer, is 25 the answer here Maxwell's testimony? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000199 EFTA00008699 06/29/20 70 A. Yes. 2 Q. Just to be clear, you testified earlier that 3 participated in sexualized massages with Epstein and 4 Maxwell; is that right? 5 A. Yes. 6 Q. And was a minor when that occurred? 7 A. Yes. 8 Q. And did you also testify earlier that Maxwell -- 9 that told you that Maxwell asked her to 10 give Epstein massages when she was a minor? 11 A. Yes. 12 Q. If you could turn to the next slide, please. 13 this another excerpt from that same deposition? 14 A. Yes, it is. 15 Q. All right. I'll read the question and you can 16 read the answer. 17 Question: "List all the people under the age of 18 18 that you've interacted with at any of Jeffrey Epstein's 19 properties?" 20 A. Maxwell's answer: "I'm not aware of anybody that I 21 interacted with, other than obviously who was 1.7 22 at this point." 23 Q. Just to be clear, you testified earlier about two 24 girls under the age of 18 who interacted with Maxwell at 25 Epstein's properties; is that correct? FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000200 EFTA00008700 06/29/20 11 A. Yes. 2 Q. And those individuals were and 3 who told you that, correct? 4 A. Yes, that's correct. 5 Q. Turning to the next slide, is this the cover page 6 of the transcript from the deposition that took place on 7 July 22, 2016? 8 A. Yes. 9 Q. And again, was this Maxwell giving testimony as 10 part of the testimony under oath here in Manhattan? 11 A. Yes. 12 Q. If you could please turn to the next slide. Is 13 that an excerpt -- are these two excerpts from that 14 deposition? 15 A. Yes. 16 Q. Again, I'll read the questions if you could please 17 read the answers. 18 Question: "Were you aware of the presence of sex 19 toys or devices used in sexual activities in Mr. Epstein's 20 Palm Beach house?" 21 There's an objection from the lawyer. 22 A. Maxwell's answer: "No, not that I recall." 23 Q. "Do you know whether Mr. Epstein possessed sex 24 toys or devices used in sexual activities?" 25 There's an objection from the lawyer. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GNLGUDNYJX000201 EFTA00008701 06/29/20 72 A. Maxwell's answer: "No." 2 Q. Just to be clear, you testified earlier that 3 told you he found sex toys in the massage room 4 in Palm Beach and also that he had seen that Maxwell had a 5 basket of sex toys in her closet there; is that correct? 6 A. Yes, that's correct. 7 Q. And is it correct that you testified earlier that 8 Epstein had used a vibrator on is that 9 correct? 10 A. Yes, that's correct. 11 Q. And did you also testify earlier that 12 told you he did that, as well? 13 A. Yes, that's correct. 14 Q. And did you also testify earlier that sex toys 15 were found by the police in the Palm Beach house in 2005; is 16 that right? 17 A. Yes. 18 Q. And did you also testify earlier that the FBI 19 found sex toys in Epstein's New York City townhouse in 2019? 20 A. Yes, that's correct. 21 Q. If you could please turn to the next slide. This 22 is on page 27. Is this -- are these also excerpts from that 23 same deposition? 24 A. Yes. 25 Q• Again, I'll read the questions if you could please FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000202 EFTA00008702 06/29/20 73 read the answers. 2 Questions: "Other than yourself, and the blonde 3 and brunette that you have identified as having been 4 involved in three-way sexual activities, with whom did 5 Mr. Epstein have sexual activities?" 6 There's an objection from the lawyer. 7 A. Maxwell's answer: "I wasn't aware that he was 8 having sexual activities with anyone when I was with him 9 other than myself." 10 Q. Question: "I want to be sure that I'm clear, is i- 11 your testimony that in the 1990s and 2000s you were not 12 aware that Mr. Epstein was having sexual activities with 13 anyone other than yourself and the blonde and brunette on 14 those few occasions when they were involved with you?" 15 A. Maxwell's answer: "That is my testimony. That is 16 correct." 17 Q. Have you reviewed the deposition transcript -- 18 A. Yes. 19 Q. -- in full? Now, the excerpt we just read has a 20 reference to a blonde and brunette. Are those individuals 21 completely different from the individuals we've been talking 22 about today? 23 A. Yes. 24 Q. Just to be clear, is it correct that you testified 25 earlier that and told you that Epstein FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GNLGUDNYJX0000203 EFTA00008703 06/29/20 14 sexually abused them repeatedly; is that correct? 2 A. Yes. 3 Q. And did you also testify earlier that Maxwell was 4 occasionally present when Epstein was abusing based 5 on what she told you? 6 A. Yes, that's correct. 7 Q. Turning to the next slide, is this also an excerpt 8 from the same deposition? 9 A. I'm sorry? 10 Q. I'm so sorry. Turning to the next slide, on page 11 28, is this also an excerpt from the same deposition? 12 A. Yes. 13 Q. Thank you. Okay. Again, if we could read that 14 together I'll take the question if you could take the 15 answer. 16 Question: "Let's just tie that down. Is it your 17 testimony that you've never given anybody a massage?" 18 A. Maxwell's answer: "I have not given anyone a 19 massage." 20 Q. "You never gave Mr. Epstein a massage; is that 21 your testimony?" 22 A. Maxwell's answer: "That is my testimony." 23 Q. "You never gave a massage; is that 24 your testimony?" 25 A. Maxwell's answer: "I never gave FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000204 EFTA00008704 06/29/20 75 1 massage." 2 Q. Just to be clear, as you testified earlier, is it 3 correct that told you that Maxwell gave her a 4 massage when they were in New Mexico? 5 A. Yes. 6 Q. Have you told the grand jury everything that you 7 know about this case or have you just answered the questions 8 that I've asked? 9 A. I've just answered the questions you've asked. 10 Q. And when you testified about the documents that 11 you reviewed or the conversations that you had with others, 12 were you testifying to the exact words used or just the 13 substance of the documents or conversations? 14 A. The substance? 15 Q. And are you willing to return to the grand jury if 16 the grand jury has any further questions for you? 17 A. Yes. 18 MS. With the Foreperson's permission I'd 19 ask that the witness be excused at this time. 20 FOREPERSON. You're excused. 21 MS. Thank you. 22 (Witness Excused) 23 (Time Noted: 11:41 a.m.) 24 (Colloquy Follows) 25 FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000205 EFTA00008705 FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000206 EFTA00008706 1 CERTIFICATE 2 3 I hereby certify that the foregoing is a true and 4 accurate transcription, to the best of my skill and ability, 5 from my electronic notes of this proceeding. 6 7 July 6, 2020 Date 8 Acting Grand Jury Reporter Free State Reporting, Inc. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDN Y_00000207 EFTA00008707