UNITED STATES DISTRICT COURT

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,