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1 described that Maxwell introduced her to
2 Jeffrey Epstein?"
3 A. "Yes."
4 Q. "How did she describe that occurring?"
5 A. "Epstein had flown into London. He was at
6 Maxwell's residence in London, and Maxwell had called
7 over. So went over, and when she got there
8 Maxwell was saying to Epstein, kind of -- the words
9 used was -- giving him a resume of her attributes, saying,
10 she's so pretty, she's so strong; and then Maxwell asked hel
11 to give Epstein a massage."
12 Q. "Now you've testified just a moment ago that
13 Maxwell -- that described to you that Maxwell asked
14 her to give Epstein a massage during this first meeting, is
15 that correct?"
16 A. "Yes."
17 Q. "Did Maxwell state to her, in sum and substance,
18 since you're so strong, I'd appreciate it if you'd give
19 Jeffrey a massage because he needs a massage every day or I
20 get in trouble?"
21 A. "Yes, she said that."
22 Q. "Is that what said to you, in sum and
23 substance?"
24 A. "Yes."
25 Q. "When that happened did remember Maxwell
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1 leading her to a room in the house?"
A. "Yes."
3 Q. "When went in the room -- oh excuse m(
4 what happened?"
5 A. "When went in the room Epstein was in
6 robe. He took off his robe, and she started massaging him.
7 And then he touched and pulled her hand to his
8 penis."
9 Q. "What does remember Epstein saying when he
10 did this?"
11 A. "Don't be frigid."
12 Q. "What was her reaction to this happening, from
13 what she told you?"
14 A. "She was taken back by it."
15 Q. "When this episode ended and left the
16 room, did she tell that she remembered Maxwell being just
17 outside the room when she left?"
18 A. "Yes."
19 Q. "Did she remember Maxwell saying to her, did you
20 have fun? Did he like it?"
21 A. "Yes."
22 Q. "Does she remember Maxwell calling her several
23 Jays afterwards, or at some short period of time
24 afterwards?"
25 A. "Yes, she did."
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1 Q. "Did remember Maxwell saying to her on the
2 phone call, in sum and substance, well, aren't you a clever
3 girl, Jeffrey was very impressed?"
4 A. "Yes."
5 Q. "Shortly after this incident does she remember
6 Maxwell asking her to come back over to the house?"
7 A. "Yes."
8 Q. "And when she got there did she tell you she
9 remembered Maxwell saying to her, in substance, thank God
10 you're here, if it's not you or someone else it falls to
11 me?"
12 A. "Yes."
13 Q. "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 Q. "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
24 Palm Beach, U.S. Virgin Islands, Paris, and New York, for
25 the next several years?"
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1 A. "Yes, they did."
2 Q. "Does she remember whether these trips began
3 before 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 she spent with
7 Maxwell when they first met, when she was 17, is that right?
8 A. "Yes."
9 Q. "During these conversations when she would spend
10 time with Maxwell, did remember talking with her
11 about her life, and her family, and her personal
12 circumstances, with Maxwell?"
13 A. "Yes."
14 Q. "Now you testified a moment ago that told
15 you that at some point she began travelling with Maxwell and
16 Epstein, and she wasn't sure whether or not these trips
17 started before she turned 18, is that right?"
18 A. "Yes."
19 Q. "Did describe to you that Epstein sexually
20 abused her during these trips, typically in the context of a
21 sexualized massage?"
22 A. "Yes, he did."
23 Q. "Did Epstein give her money?"
24 A. "Yes."
25 Q. "Did she tell you that he would give her cash?"
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1 A. "Yes."
2 Q. "Did she describe to you that the abuse included,
3 among other things, Epstein groping her and using a massager
4 device on her genitals?"
5 A. "Yes."
6 Q. "And was the massager device like a vibrator?"
7 A. "Yes, it was."
8 Q. "From what told you, was Maxwell in the
9 room during these encounters?"
10 A. "Maxwell wasn't in the room."
11 Q. "What did she tell you would typically happen when
12 left the room after these episodes; was Maxwell
13 typically nearby?"
14 A. "Yes. She was usually right near the room."
15 Q. "Does she remember Maxwell asking her, after she'd
16 leave the room from one of these sessions, how was it; is he
17 happy?"
18 A. "Yes."
19 Q. "Did she also tell you that she remembers Maxwell
20 telling her at some point, in sum and substance, you know
21 how he is when he's not happy, and you know what makes him
22 happy; he has to have sex all the time; he's like a super
23 hero?"
24 A. "Yes, she said that."
25 Q. "Did tell you about an incident that
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1 occurred, after she turned 18, in Palm Beach when she was
2 staying at the Palm Beach house?"
3 A. "Yes."
4 Q. "Did the incident she described to you involve a
5 school-girl outfit?"
6 A. "Yes, it did."
7 Q. "Could you please describe for the grand jury what
8 told you about that incident?"
9 A. said that Maxwell had shown her a bedroom
10 and upon the bed was a school-girl outfit. Maxwell had told
11 her -- when confronted her about it -- and Maxwell
12 said, well, I thought it would be adorable if you gave
13 Jeffrey his tea in this; so felt like she had to put
14 it on. And so she put it on, took Epstein his tea, and
15 Epstein then slapped her on the buttocks and reached under
16 the skirt and touched her."
17 Q. "What was her demeanor like when she described
18 this incident to you?"
19 A. "She was crying. She was very upset."
20 Q. "When described seeing the school-girl
21 outfit and talking to Maxwell about it, did she remember
22 Maxwell telling her, don't be so frigid?"
23 A. "Yes."
24 Q. "Does she remember that later in the day, after
25 she had delivered Epstein his tea and he assaulted her, does
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1 she remember Maxwell telling her, I heard you did well?"
2 A. "Yes."
3 Q. "During the years that was in contact with
4 Maxwell and Epstein, did she remember whether Maxwell had
5 ever asked her if she knew any other girls who could massage
6 Epstein?"
7 A. "Yes."
8 Q. "Does she remember Maxwell saying, in sum and
9 substance, do you know anyone who could give him a blowjob
10 today, I don't feel like it?"
11 A. "Yes."
12 Q. "Does she remember Maxwell saying, when she asked
13 her to bring other girls, that they have to look young at
14 least?"
15 A. "Yes."
16 Q. "From your conversations with , did she
17 tell you whether or not she ever brought any other girls?"
18 A. "'I'll didn't bring any girls."
'
19 Q. "Did she tell you why not?"
20 A. "She didn't want anyone else to go through that."
21 Q. "From your interviews with , did she tell
22 you that there came a time, when she was in her early
23 twenties, when she stopped travelling with Maxwell and
24 Epstein?"
25 A. "Yes."
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1 Q. "Was she struggling with substance abuse at that
point?"
3 A. "Yes, she was."
4 Q. "Did she tell you that she got sober in her
5 twenties?"
6 A. "Yes, she did."
7 Q. "What is her current profession?"
8 A. "She runs a non-profit for people who struggle
9 with addiction and trauma."
10 Q. "Did provide you with several emails that
11 she exchanged with Epstein in the early 2000s?"
12 A. "Yes, she did."
13 Q. "And were those emails very friendly in tone?"
14 A. "Yes, they were."
15 4• "What did she say to you when you talked with her
16 about those emails?"
17 A. "She said she didn't, at the time, want to
18 acknowledge what was going on to her. That looking
19 back -- on -- it's different."
20 Q. "Did your squad at the FBI execute a search
21 warrant at Jeffrey Epstein's townhouse in Manhattan in July
22 of 2019?"
23 A. "Yes."
24 Q. "Did you personally participate in the search of
25 Epstein's residence?"
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1 A. "Yes, I did."
2 Q. "Did the townhouse include a massage room?"
3 A. "Yes."
4 Q. "Have you yourself been in that massage room?"
5 A. "Yes, I have."
6 Q. "Could you please describe for the grand jury what
7 that massage room looked like?"
8 A. "It was dark. It had dark draperies covering the
9 windows. There was a massage table; there were oils, there
10 was a handheld massager in there; along with handcuffs, a
11 whip, and along with -- walls were nude photographs of young
12 females."
13 Q. "I believe you testified a moment ago that
14 told you that there was a time when Maxwell
15 asked her to wear a school-girl outfit for Epstein when they
16 were in Palm Beach. Did you find a school-girl outfit in
17 Epstein's New York townhouse?"
18 A. "Yes, we did."
19 Q. "Where did you find it?"
20 A. "It was found in a room next to the massage room."
21 Q. "And to be clear did the FBI find sex toys during
22 the search?"
23 A. "Yes."
24 Q. "What was found?"
25 A. "Butt plugs, dildo, and vibrators."
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1 Q. "We've talked about three minor girls today;
2 , is that right?"
3 A. "Yes."
4 Q. "Have you reviewed the proposed indictment marked
5 Grand Jury Exhibit 1?"
6 A. "Yes, I have."
7 Q. "Is the individual referred to as Victim 1
8 in the proposed indictment?"
9 A. "Yes."
10 Q. "Is the individual referred to as Victim 2
11 in the proposed indictment?"
12 A. "Yes."
13 Q. "Is the individual referred to as Victim 3
14 in the indictment?"
15 A. "Yes."
16 Q. "During all of Maxwell's interactions with the
17 victims when they were underage girls, based on the
18 timeframe and your knowledge of Maxwell's birthdate, was she
19 in her thirties?"
20 A. "Yes, she was."
21 Q. "Just one moment. All right. Switching gears.
22 Have you become aware that in or about 2016 Maxwell gave
23 sworn testimony in a civil deposition in connection with a
24 lawsuit?"
25 A. "Yes."
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1 Q. "Could you please explain for the grand jury, what
is a deposition?"
3 A. "It is a statement made under oath."
4 Q. "And in the course of civil litigation is it
5 common for witnesses or parties of the lawsuit to give a
6 deposition, under oath, where they testify about the
7 substance of the case?"
8 A.
" Yes. "
9 Q. "And is deposition testimony live, and in-person,
10 and under oath?"
11 A. "Yes."
12 Q. "Is a court reporter present when a deposition
13 takes place?"
14 A. "Yes."
15 Q. "Now before we talk about Maxwell's deposition
16 testimony, I want to talk to you about the lawsuit that the
17 testimony was about. Have you become aware that in or about
18 2015 an individual named filed a lawsuit
19 against Ghislaine Maxwell here in the Southern District of
20 New York?"
21 A. "Yes."
22 Q. "And was suing Maxwell for defamation?"
23 A. "Yes, she was."
24 Q. "Was the lawsuit captioned
25 against Ghislaine Maxwell, the docket number 15CB 7433, here
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1 in the Southern District of New York?"
2 A. "Yes."
3 Q. "Generally speaking, in broader strokes, what was
4 the lawsuit about; what was the claim that was
5 bringing against Maxwell?"
6 WITNESS. I'm sorry. What line are we on again?
7 MS. Page 68, line 4.
8 WITNESS. had stated that she had been
9 sexually abused by Epstein and Maxwell as a minor. Maxwell
10 came forward publically and called her a liar, so
11 sued her for defamation."
12 BY MS.
13 Q. "So just a small legal instruction on this topic.
14 Ladies and gentlemen, I instruct you that the allegations in
15 the lawsuit are not being presented to you as evidence that
16 those incidents occurred. I instruct you that you should
17 not consider those allegations for their truth. Instead,
18 the circumstances of the lawsuit are being presented to you
19 so that you can consider the context of the case and the
20 circumstances under which Maxwell made statements under
21 oath. Turning back to the deposition, did Maxwell's
22 deposition take place over two different days?"
23 A. "Yes."
24 Q. "On both days does she give testimony in
25 Manhattan?"
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1 A. "Yes, she did."
2 Q. "Is that where the deposition took place?"
3 A. "Yes."
4 Q. "And on both days was Maxwell sworn under oath?"
5 A. "Yes."
6 Q. "If you could flip through the remaining slides of
7 the presentation, do those slides contain true and accurate
8 excerpts of the transcript of that deposition?"
9 A. "Yes."
10 Q. "Turning to the next slide, is this the cover page
11 of the transcript of the first deposition that took place on
12 April 22, 2016?"
13 A. "Yes."
14 Q. "And does it have the case caption on it?"
15 A. "Yes, it does."
16 Q. "Turning to the next slide. Is this an excerpt
17 from the transcript?"
18 A. "Yes."
19 Q. "I imagine the grand jurors can't read it from
20 their seats so if you could read it with me, I'll read the
21 questions, and if you could read the answers."
22 "'Did Jeffrey Epstein have a scheme to recruit
23 underage girls for underage massages?'"
24 MS. And it appears there was an objection
25 from the lawyer.
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1 BY MS.
2 Q. "'If you know.'"
3 A. "'I don't know what you are talking about.'"
4 Q. "Just to be clear, was the question and
5 answer is the answer here Maxwell's testimony?"
6 A. "Yes."
7 Q. "Just to be clear you testified earlier that
8 participated in sexualized massages with Epstein and
9 Maxwell, is that right?"
10 A. "Yes."
11 Q. "And was a minor when that occurred?"
12 A. "Yes."
13 Q. "And did you also testify earlier that
14 Maxwell -- that told you that Maxwell
15 asked her to give Epstein massages when she was a minor?"
16 A. "Yes."
17 Q. "If you could turn to the next slide please. Is
18 this another excerpt from that same deposition?"
19 A. "Yes, it is."
20 Q. "All right. I'll read the question and you can
21 read the answer."
22 "'Was all the people, under the age of 18 that
23 you've interacted at with, at any of Jeffrey Epstein's
24 properties?'"
25 A. "'I'm not aware of anybody that I interacted with,
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1 other than, obviously, who was 17 at this point.'"
2 Q. "Just to be clear, you testified earlier about two
3 girls under the age of 18 who interacted with Maxwell at
4 Epstein's properties, is that correct?"
5 A. "Yes."
6 Q. "And those individuals were and
7 who told you that, correct?"
8 A. "Yes, that's correct."
9 Q. "Turning to the next slide. Is this the cover
10 page of the transcript from the deposition that took place
11 on July 22, 2016?"
12 A. "Yes."
13 Q. "And again, was this Maxwell giving testimony as
14 part of the testimony under oath here in Manhattan?"
15 A. "Yes."
16 Q. "If you could please turn to the next slide. Is
17 that an excerpt -- are these two excerpts from that
18 deposition?"
19 A. "Yes."
20 Q. "Again, I'll read the questions, if you could
21 please read the answers."
22 "'Were you aware of the presence of sex toys or
23 devices used in sexual activities in Mr. Epstein's
24 Palm Beach house?'"
25 MS. There is an objection from the
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1 lawyer.
2 WITNESS. "'No, no. Not that I recall.'"
3 BY MS.
4 Q. "'Do you know whether Mr. Epstein possessed sex
5 toys or devices used in sexual activities?'"
6 MS. There's an objection from the lawyer.
7 WITNESS. "'No."
8 BY MS.
9 Q. "Just to be clear you testified earlier that
10 told you he found sex toys and a massager in
11 Palm Beach and also that he had seen Maxwell had a basket of
12 sex toys in her closet there, is that correct?"
13 A. "Yes, that's correct."
14 Q. "And is it correct you testified earlier that
15 Epstein used a vibrator on , is that correct?"
16 A. "Yes, that's correct."
17 Q. "And did you also testify earlier that
18 told you he did that as well?"
19 A. "Yes, that's correct."
20 Q. "And did you also testify earlier that sex toys
21 were found by the police in the Palm Beach house in 2005, is
22 that right?"
23 A. "Yes."
24 Q. "And did you also testify earlier that the FBI
25 found sex toys in Epstein's New York City townhouse in
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1 2019?"
2 A. "Yes, that's correct."
3 Q. "If you could please turn to the next slide. This
4 is on Page 27. It says, are these also excerpts from that
5 same deposition?"
6 A. "Yes."
7 Q. "Again, I'll read the questions if you could
8 please read the answers."
9 4. "'Other than yourself, and the blonde and brunette
10 that you have identified as having been involved in
11 three-way sexual activities, with whom did Mr. Epstein have
12 sexual activities?'"
13 MS. There's an objection from the lawyer.
14 WITNESS. "'I wasn't aware that he was having
15 sexual activities with anyone when I was with him, other
16 than myself.'"
17 BY MS.
18 Q. "'I want to be sure that I'm clear. Is it your
19 testimony that in the 1990s and 2000s you were not aware
20 that Mr. Epstein was having sexual activities with anyone
21 other than yourself and the blonde and brunette on those few
22 occasions when they were involved with you?'"
23 A. "'That is my testimony. That is correct.'"
24 Q. "Have you reviewed the deposition transcript?"
25 A. "Yes."
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1 Q. "In full? Now the excerpt we just read has the
2 reference to a blonde and a brunette. Are those individuals
3 completely different from the individuals we've been talking
4 about today?"
5 A. "Yes."
6 4• "Just to be clear, is it correct that you
7 testified earlier that and told you that
8 Epstein sexually abused them repeatedly, is that correct?"
9 A. "Yes."
10 Q. "And did you also testify earlier that Maxwell was
11 occasionally present when Epstein was abusing , based
12 on what she told you?"
13 A. "Yes, that's correct."
14 Q. "Turning to the next slide. Is this also an
15 excerpt from the same deposition?"
16 A. "I'm sorry?"
17 Q. "I'm so sorry. Turning to the next slide, on
18 Page 28. Is this also an excerpt from the same deposition?"
19 A. "Yes."
20 Q. "Thank you. Okay. Again, if we could read that
21 together. I'll take the question and you can take the
22 answer."
23 Q. "'Let's just tie that down. Is it your testimony
24 that you've never given anybody a massage?'"
25 A. "'I've not given anyone a massage.'"
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1 Q. "'You never gave Mr. Epstein a massage? Is that
2 your testimony?'"
3 A. "'That is my testimony.'"
4 Q. "'You never gave a massage? Is that
5 your testimony?'"
6 A. "'I never gave a massage.'"
7 Q. "Just to be clear, as you testified earlier, is it
8 correct that told you that Maxwell gave her a
9 massage when they were in New Mexico?"
10 A. "Yes."
11 MS. We're going to stop the read back
12 there. Ladies and gentlemen, let's take a five minute break
13 and we'll come back to finish the presentation in about five
14 minutes. With the Foreperson's permission, I will ask that
15 the witness please be excused.
16 FOREPERSON. Yes, he may.
17 MS. Thank you.
18 (Witness Temporarily Excused)
19 (Time noted: 11:21 a.m.)
20 (Recess taken)
21
22
23
24
25
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1 (Colloquy Precedes)
2 (Witness Resumes)
3 (Time Noted: 11:34 a.m.)
4 BY MS.
5 Q. Welcome back, Detective.
6 A. Thank you.
7 Q. I have placed in front of you what has been marked
8 as Grand Jury Exhibit 5. Do you recognize that?
9 A. I do.
10 Q. Is this a PowerPoint presentation concerning some
11 of the facts and evidence that you have gathered in your
12 investigation?
13 A. Yes.
14 Q. Did you participate in preparing this Exhibit in
15 connection with your testimony today?
16 A. Yes.
17 Q. Will it assist you in testifying today?
18 A. Yes.
19 Q. Then we're going to have it up on the screen and
20 we'll use it as you testify. During the course of this
21 investigation have you participated in multiple interviews
22 with an individual named ?
23 A. Yes.
24 Q. Did those interviews take place in the year 2020
25 and the year 2021?
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