25 UNITED STATES GRAND JURY

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES GRAND JURY SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA -v- GHISLAINE MAXWELL (2018R01618) APPEARANCE S: : November 19, 2019 Additional -x United States Courthouse 300 Quaroppas Street White Plains, New York July 8, 2020 10:05 a.m. Assistant United States Attorney Acting Grand Jury Reporte. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GNLGUDNYJX000(1208 EFTA00008708 United States v. Ghislaine Maxwell 07/08/20 2 PROCEEDINGS 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (10:05 a.m.) MS. Let the record reflect that there are 17 grand jurors present and that the foreperson is present. Good morning, ladies and gentlemen. My name is and I am an Assistant United States Attorney here in the Southern District of New York. Can everyone hear me okay? All right. I see everybody's heads nodding. Thank you. I am here today to present for your consideration a proposed superseding indictment charging Ghislaine Maxwell in six counts. This indictment is virtually identical to the indictment that you returned last week charging Maxwell in those same six counts except that it corrects two clerical errors, or two typographical errors that were contained in Counts Five and Six which are the perjury charges. As a result, I will not be presenting any new evidence or new witnesses today. Instead, I will identify for you those two clerical errors in the indictment. I will point out the portion of the exhibits that you saw last week that provide the correct information. Then I will identify the corrected portion of the superseding indictment in the proposed superseding indictment. Before I do that though, I must ask you all the FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000209 EFTA00008709 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 United States v. Ghislaine Maxwell 07/08/20 same preliminary questions that we went over last week. First, do any of you believe that you personally know or have met the proposed defendant, Ghislaine Maxwell? I see no hands. Next, have you any heard or read about, or learned anything Ghislaine Maxwell, Jeffrey Epstein or anyone else related to this case, if you could just raise your hand? I see a number of hands. Virtually every hand is in the air. You can all put your hands down. Thank you. As you know, you must make your determination as a grand jury based on the evidence presented before you in the grand jury, in this room alone. Accordingly, you must set aside any other knowledge you may have about this case or the people involved in it, and base your decision solely on the evidence presented to this grand jury to determine whether there is probable cause to believe that the charges in the proposed indictment were committed. Is there any grand juror here today who cannot follow these instructions? I see no hands. Just to be sure, is there any grand juror here who would have any difficulty setting aside the outside information you may have about the defendant or the facts of this case? I see no hands. Finally, do any of you believe you know me in anything other than my professional capacity? I see no FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000210 EFTA00008710 United States v. Ghislaine Maxwell 07/08/20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 hands. Now, as I mentioned, I will not be calling any witnesses today. Instead I will present you with the exhibits from last week, the transcript of the testimony you heard from last week and the proposed superseding indictment. I will then walk you through the error that the superseding indictment seeks to correct. Please keep in mind though that what I say is not evidence. Only the testimony of the witnesses and the exhibits are evidence. So as I'm walking you through these exhibits, your understanding of them and your understanding of the evidence controls. I am just trying to provide you with an overview. With that instruction in mind, I am going to put up onto the Elmo what was previously received and marked as Grand Jury Exhibit 1. That is the proposed six-count indictment that you voted to return last week. A copy of it will be available for review when you deliberate. You also received what has been marked as Grand Jury Exhibit 2, which I will not put up on the Elmo. Thar was a PowerPoint presentation containing photographs anc excerpts of certain documents that was shown to you during the testimony last week. You also heard testimony from FBI Special Agent Today I am marking, as Grand Jury Exhibit 3, a FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GNLGUDNYJMOXIMI EFTA00008711 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 United States v. Ghislaine Maxwell 07/08/20 copy of the transcript of that testimony. It is up on the Elmo now and it will be available for you to review if you would like as you deliberate. I will not read it back to you now, but you can read through it as you deliberate. Finally, I am marking, as Grand Jury Exhibit 4, the proposed superseding indictment, which I have now placed up on the Elmo. As I mentioned, this proposed superseding indictment corrects two clerical errors and is otherwise identical to the original indictment, Grand Jury Exhibit 1. I'm now going to walk you through the errors that we're going to correct starting on Grand Jury Exhibit 1. Page 15 contains the beginning of Count Five which charges Maxwell with perjury. Paragraph 21 on that page refers to the civil case in which Maxwell gave deposition testimony on April 22nd, 2016, as 15 Civ. 7344. That is the error we are going to correct. Similarly, page 16 contains the beginning of Count Six which charges another count of perjury. Paragraph 23 on that page refers to the civil case in which Maxwell gave deposition testimony on July 22nd, 2016, under the sare number, 15 Civ. 7344. Turning now to Grand Jury Exhibit 2. Slue 22 el that exhibit contains the first page of the deposition transcript from the testimony that Maxwell gave on April 22nd, 2016. As you can see here, the docket number FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000212 EFTA00008712 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 United States v. Ghislaine Maxwell 07/08/20 for that case is in fact 15 Civ. 7433 not 7344. Similarly, slide 25 contains the first page of cite transcript from the July 22nd, 2016 deposition that Maxwell gave. As you can see here, again, the docket number for that case is 15 Civ. 7433 not 7344. Finally, I will turn to the proposed indictment, Grand Jury Exhibit 4. On page 15, you have again the same perjury count with one change. Paragraph 21 corrects the docket number for the civil case to be 15 Civ. 7433. Similarly, on page 16, which contains the second perjury count for the July 22nd, 2016 deposition, the docket number is corrected to 15 Civ. 7433. There are otherwise no changes to the substance of this indictment. That is my presentation. Before I leave you to deliberate, would anyone like me to read the full proposed superseding indictment out loud? I see no hands. I must advise you that you must independently find probable cause, again, for each count in the superseding indictment. The evidence before you in support of the charges in the superseding indictment is the same evidence that was before you when you considered the indictment last week. Does anyone have any questions about that evidence? I see no hands. The legal instructions that you received before FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY JX*Mn 13 EFTA00008713 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 United States v. Ghislaine Maxwell 07/08/20 7 voting on the indictment last week are the same instructions that apply to your consideration of the proposed superseding indictment. Would anyone like me to read those instructions out loud for you again? I see no hands. Does anyone have any questions about the legal instructions? I see no hands. I will leave you now with the exhibits to deliberate. As always, if you have any questions or concerns about the proposed indictment, please let me know before you vote so that I may answer any questions you may have on the law, or bring any additional evidence before you to consider. Thank you, all. (Matter concluded) (Time Noted: 10:14 a.m.) FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDNY_00000214 EFTA00008714 1 2 3 4 5 6 7 9 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATE I hereby certify that the foregoing is a true and accurate transcription, to the best of my skill and ability, from my electronic notes of this proceeding. July 22, 2020_ Date Acting Grand Jury Reporter Free State Reporting, Inc. FREE STATE REPORTING, INC. Court Reporting Transcription D.C. Area 301-261-1902 Balt. & Annap. 410-974-0947 GM_GLSDN Y_000002 15 EFTA00008715