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1 A. "Yes."
2 Q. "Did they find massage tables and sex toys?"
3 A. "Yes, they did."
4 Q. "Did they find any photographs of
5 A. "Yes."
6 Q. "Was one of the photographs signed by
7 A. "Yes, it was."
8 Q. "Did it say,
9
10 A. "Yes."
11 Q. "During your interviews with , did tell
12 you how she felt about Epstein and Maxwell in the 90s when
13 she was a young girl?"
14 A. "She did. She expressed that she felt like they
15 loved her. She felt they were her family; that they
16 supported her, and that they felt like -- she was made to
17 feel that she was needed to be grateful to them."
18 Q. "Okay. Did she tell you that she felt like they
19 were trying to help her?"
20 A. "Yes."
21 Q. "Have you talked with about how she feels
22 about this now?"
23 A. "Yes."
24 Q. "What was 's demeanor like when she described
25 to you what Epstein and Maxwell had done to her?"
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1 A. "She was upset. She recognized that now. It's
2 affected her life to a great degree. She's struggled in
3 relationships with opening up to people and trusting people;
4 both personal and professional relationships."
5 Q. "Did she tell you that she struggled to tell
6 anyone what had happened to her for most of her adulthood?"
7 A. "Yes."
8 Q. "When was the first time you interviewed
9 A. "Last fall."
10 Q. "Was that the first time she ever reported this to
11 law enforcement?"
12 A. "Yes, it was."
13 Q. "Now you testified earlier about your interviews
14 with who worked at Epstein's Palm Beach house.
15 Did he remember a girl named coming to the house
16 during that time?"
17 A. "Yes, he did."
18 Q. "Did he recall , Maxwell, and Epstein meeting
19 in the Palm Beach house together?"
20 A. "Yes."
21 Q. "What was his understanding of why
22 there?"
23 A. "He thought that Epstein was helping her. That's
24 what Epstein had told him, and had told him that
25 Epstein was helping her."
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1 Q. "Did he ever observe Epstein interacting with
2 physically?"
3 A. "Yes."
4 Q. "What did he see?"
5 A. "He saw Epstein kiss 's cheek and pat her on
6 the bottom."
7 Q. "Did he have any knowledge about what was
8 happening with Epstein or Maxwell when he wasn't present?"
9 A. "He didn't."
10 Q. "Did ever recall picking up from her
11 house?"
12 A. "Yes."
13 Q. "And when he would pick her up from her house,
14 would he then bring her back to the Palm Beach house?"
15 A. "Yes."
16 Q. "Did he remember who, in general, would tell him
17 to pick up from her house?"
18 A. "Maxwell would be the one to tell him to pick her
19 up."
20 Q. "Did he recall ever driving to the movies?"
21 A. "Yes."
22 Q. "What did he tell you about that?"
23 A. "That would usually be Epstein, Maxwell, and
24 ; they would go to the movies, and it would usually be
25 late at night."
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1 Q. "Did he tell you about what his memory was about
2 how old was?"
3 A. "He said she was young, and that he knew that
4 because he had picked her up from school, and that he knew
5 she was too young to drive."
6 Q. "Switching gears. I want to talk to you about a
7 different aspect of your interviews with Based
8 on what he told about his job duties, were there ever times
9 where he would have to clean Epstein's massage room?"
10 A. "Yes."
11 Q. "What did he tell you about that?"
12 A. "He said that he found sex toys in the massage
13 room, and he had to wash them afterwards."
14 Q. "Aside from those experiences, was he aware it
15 there were any sex toys in the house?"
16 A. "Yes. There was a basket of sex toys that were
17 kept in Maxwell's closet."
18 Q. "Did stop working for Epstein in
19 approximately 2002?"
20 A. "Yes."
21 Q. "Was he told that he was being replaced?"
22 A. "Yes."
23 Q. "And was he generally aware that the person who
24 replaced him was much younger?"
25 A. "Yes."
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1 Q. "Did tell you that a few months after he
2 left working for Epstein he became suicidal because of
3 issues in his marriage?"
4 A. "Yes."
5 Q. "Did he tell you that he went to Epstein's house
6 and tried to take Epstein's gun?"
7 A. "Yes, he did."
8 Q. "Did he tell you that it's worth several thousand
9 dollars?"
10 A. "Yes."
11 Q. "Did Epstein discover this and confront him about
12 it?"
13 A. "Yes, he did."
14 Q. "Did admit to Epstein and the police what
15 he had done?"
16 A. "Yes."
17 Q. "Did Epstein also tell the police his gun was
18 missing?"
19 A. "Yes."
20 Q. "Were there any charges filed?"
21 A. "No."
22 Q. "Was he ever arrested?"
23 A. "I don't believe so."
24 Q. "And did Epstein pursue any charges about this
25 incident?"
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1 A. "No. He didn't pursue anything."
2 Q. "Have you interviewed one of Epstein's former
3 pilots?"
4 A. "Yes."
5 Q. "Is that pilot named David Rodgers?"
6 A. "Yes."
7 Q. "Was he one of the pilots for Epstein's private
8 jet in the 1990s?"
9 A. "Yes."
10 Q. "Did he remember travelling on the
11 jet in the 90s?"
12 A. "He remembered her travelling, but he didn't
13 remember specifics."
14 Q. "So just to be clear, is your testimony that he
15 didn't remember the specific dates of the flights, but he
16 remembered her travelling on the jet during the 1990s?"
17 A. "Yes."
18 Q. "And did he remember specifically as
19 a person who travelled?"
20 A. "Yes."
21 Q. "Did you discuss with him the flight records that
22 we talked about earlier that lists a person named as a
23 passenger?"
24 A. "Yes."
25 Q. "Did he have a specific memory of those exact
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1 flights?"
2 A. "No."
3 Q. "But was he aware of any other flying on the
4 jet, besides , in the 1990s?"
5 A. "No. No other at the time."
6 Q. "Earlier, when we were looking at Interlochen
7 attendance records for the summer of 1994, you noted that
8 was one of the names on that record, is that
9 right?"
10 A. "Yes."
11 Q. "Is that ?"
12 A. "Yes."
13 Q. "Have you interviewed ?"
14 A. "Yes, I have."
15 Q. "Did he tell you that he remembered talking
16 that summer at camp about having met Jeffrey Epstein?"
17 A. "Yes."
18 Q. "Did he tell you that he remembered going
19 over to Epstein's house in Palm Beach when they were in high
20 school?"
21 A. "Yes."
22 Q. "Did he remember that would often talk about
23 spending time with Maxwell and Epstein during this time?"
24 A. "Yes."
25 Q. "Did he remember telling him they -- when
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1 they were in high school -- about at least one trip to
2 New York City that she took with Epstein?"
3 A. "Yes."
4 Q. "Did he remember describing Epstein's
5 townhouse in Manhattan?"
6 A. "Yes."
7 Q. "And does he remember talking often about
8 Ghislaine Maxwell?"
9 A. "Yes."
10 Q. "Now based on your interviews with did he
■,
11 tell you whether he knew back then, when they were in high
12 school, whether was being sexually abused by Epstein?"
13 A. "He didn't know back then."
14 Q. "Did ever meet Ghislaine Maxwell?"
■
15 A. "Yes, he did."
16 Q. "What did he remember about that?"
17 A. "He remembered Epstein, Maxwell, and being
18 near a movie theatre, and he was approximately 16 at the
19 time and would have been 15, and just the little bit
20 of interaction they had. And then after that, had
21 told him that Maxwell had said something to the effect of, I
22 could teach a thing or two."
23 Q. "Is that something that he remembers telling
24 him back then, that Maxwell said?"
25 A. "Yes."
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1 Q• "During the course of this investigation have you
2 participated in any interviews with an individual named
3 ?II
4 A. "Yes."
5 Q. "So for today's purposes, I'm just going to refer
6 to her as . How many times have you referred to
7 (verbatim) ?"
8 A. "Approximately, twice."
9 MS. Excuse me.
10 BY MS.
11 Q. "How many times have you interviewed ? 11
12 A. "Approximately twice."
13 Q. "Now does know ? Have they
14 ever met before as far as you know?"
15 A. "As far as I know, no."
16 Q. "Turning to the next slide. Are these photographs
17 of when she was in high school?"
18 A. "Yes."
19 Q. "And is her date of birth ?"
20 A. "Yes."
21 Q. "When was approximately 16 and a junior in
22 high school where was she living?"
23 A. "She was living in with her mother."
24 Q. "Does she have any siblings?"
25 A. "An older sister."
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1 Q. "What did her older sister do?"
2 A. "Her older sister lived -- worked for Epstein."
3 Q. "Where did she work for Epstein?"
4 A. "Here in New York."
5 Q. "Did there come a time, in approximately December
6 1995, when had a phone conversation with her sister
7 about travelling to New York City?"
8 A. "Yes."
9 Q. "What did they discuss?"
10 A. "They discussed her coming to New York and meeting
11 Epstein."
12 Q. "What did her sister tell about why she
13 should meet Epstein?"
14 A. "She said that he could help her with her
15 college."
16 Q. "And did she say -- does the sister say whether
17 the sister wanted her to meet Epstein, or did she say
18 whether Epstein wanted to meet
19 A. "Epstein wanted to meet
20 Q. "Now let me just pause here. You testified that
21 this happened in approximately December of 1995. Just for
22 context, the years that we were talking about with
23 , was that 1994 through 1997?"
24 A. "Yes."
25 Q. "So is this approximately the same time period
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1 while what you described telling you happened?"
2 A. "Yes."
3 Q. "So in January of 1996 did fly on a
4 commercial airline to New York City to spend a weekend with
5 her sister and meet Jeffrey Epstein?"
6 A. "Yes."
7 Q. "Did she tell you that?"
8 A. "Yes."
9 Q. "During the trip did tell you that she met
10 Epstein at his townhouse in New York City?"
11 A. "Yes, she did."
12 Q. "Did she tell you that Epstein discussed her plans
13 for college applications and offered to help her?"
14 A. "Yes."
•
15 Q. "What was s first impression of Jeffrey
16 Epstein?"
17 A. "She was very impressed by him."
18 Q. "What did she -- what was her impression, based on
19 this conversation, of what Epstein was going to do for her?"
20 A. "That he was going to help her with her future
21 plans for college."
22 Q. "During that trip to New York City did she stay at
23 Epstein's townhouse or at her sister's apartment?"
24 A. "Her sister's apartment."
25 Q. "During that trip did she tell you that she saw
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1 Epstein a second time when he took and her sister to
2 the movies?"
3 A. "Yes."
4 Q. "What did she tell you happened at the movies?"
5 A. "She said that they were sitting in the theatre
6 and Epstein was between and her sister, and Epstein
7 put his hand on her leg; he rubbed her arm and held her
8 hands -- held hands with her."
9 Q. "From what she told you, what was her impression
10 about whether her sister could see what was going on?"
11 A. "She felt like her sister couldn't see."
12 Q. "What was her reaction to this happening?"
13 A. "She was uncomfortable."
14 Q. "After the movie did she tell her sister what hac
15 happened?"
16 A. "No, she didn't."
17 Q. "Did she say why not?"
18 A. "She said that she knew , her sister, really
19 liked Epstein and that Epstein could help them. So she
20 didn't tell her."
21 Q. "After this trip did go back home to
22 7"
23 A. "Yes."
24 Q. "Did Epstein contact her afterwards?"
25 A. "Yes."
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1 Q. "Did he discuss with her, her ongoing college
2 plans?"
3 A. "Yes, he did."
4 Q. "Did he invite her to a weekend at his ranch in
5 New Mexico in the spring of 1996?"
6 A. "Yes."
7 Q. "Was she 16 at the time?"
8 A. "Yes, she was."
9 Q. "From what she told you, what was
10 impression of who would be on this trip to New Mexico?"
11 A. "She knew Maxwell would be there."
12 Q. "Did she -- was she told anyone else was going to
13 be present during this trip?"
14 A. "She said that there would be like other students
15 her -- kids her age."
16 Q. "And what was her understanding of who these other
17 kids were and why they would be there? Sorry, let me --"
18 A. "Rephrase."
19 Q. "Rephrase that question. You testified that she
20 was told that on this trip that there would be other
21 students. Was she under the impression that there would be
22 other students like her on the trip who were also being
23 mentored by Epstein?"
24 A. "Yes."
25 Q. "Now you testified just a moment ago that she was
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1 also told that Maxwell would be there. Are you referring to
2 Ghislaine Maxwell?"
3 A. "Yes."
4 Q. "At the point that she was told that
5 Ghislaine Maxwell would be on this trip, had she ever met
6 Ghislaine Maxwell?"
7 A. "No, she hadn't."
8 Q. "Had she heard her sister talk about
9 Ghislaine Maxwell?"
10 A. "Yes."
11 Q. "How did -- from what she described to you -- how
12 did her expectation that Maxwell would be on this trip make
13 her feel about the trip?"
14 A. "It made her comfortable. Her sister had talked
15 highly of Maxwell."
16 Q. "Did tell you that she flew to New Mexico
17 that spring when she was 16?"
18 A. "Yes."
19 Q. "Did she meet Ghislaine Maxwell when she arrived
20 in New Mexico?"
21 A. "Yes, she did."
22 Q. "How did she describe Maxwell's demeanor and
23 attitude when she met her?"
24 A. "She described Maxwell as being very charming.
25 She gave her a tour of the house, and Maxwell took
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1 shopping which made her feel special."
2 Q. "What does she remember talking about with
3 Ghislaine Maxwell?"
4 A. "They talked about school, homework, trips."
5 Q. "Did she talk with her about applying to college?"
6 A. "Yes."
7 Q. "Did she talk about her classes in high school?"
8 A. "Yes."
9 Q. "Did she talk with her about the homework that she
10 had to do that weekend?"
11 A. "Yes."
12 Q. "Did she talk with Maxwell about her family?"
13 A. "Yes."
14 Q. "Did she talk with her about her home life and
15 living with her mother?"
16 A. "Yes."
17 Q. "From what told you, when she got there, who
18 else was at the ranch besides Ghislaine Maxwell and
19 Jeffrey Epstein?"
20 A. "It was just them."
21 Q. "Was it just the three of them there the entire
22 weekend of the visit?"
23 A. "Yes."
24 Q. "Were there any other school kids there?"
25 A. "No."
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1 Q. "When they were at the ranch, from what to_
2 you, did Maxwell say anything to about massages?"
3 A. "Yes."
4 Q. "Did she say anything about -- to her about foot
5 massages?"
6 A. "Yes."
7 Q. "What did tell you about that?"
8 A. "Maxwell told to give Epstein a foot massage
9 and then showed her and instructed her on how to do it.
10 was a little uncomfortable, but Maxwell was joking
11 around so she just followed her lead."
12 Q. "Did tell you what Maxwell and
13 Epstein -- took her to the movies that weekend?"
14 A. "Yes."
15 Q. "What did she tell you about that trip to the
16 movies?"
17 A. "She said that when they went outside the theatre
18 Maxwell was joking around and pulled Epstein's pants down a
19 little bit. And then once they went inside the theatre,
20 Epstein, when they were sitting down, touched 's leg,
21 and rubbed her arm, held her hand. And that this time
22 he -- felt -- he wasn't trying to hide it from
23 Maxwell.
24 Q. "What was 's reaction to all of this?"
25 A. "She was uncomfortable."
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1 Q. "During the same weekend was there another
2 occasion when Maxwell talked about massages?"
3 A. "Yes."
4 Q. "What happened?"
5 A. "Maxwell had asked if she had ever had a
6 massage, and Maxwell told her she could give her one.
7 was on her back, and Maxwell pulled the sheet down
8 exposing her chest; she was nude from the top up and
9 proceeded to massage around her chest and breast area."
10 Q. "From what told you when she was describing
11 to you what you just described to the grand jury, how did
12 she feel while this was happening?"
13 A. "She felt really uncomfortable."
14 Q. "Did also tell you about an incident that
15 happened one morning when she was in New Mexico?"
16 A. "Yes."
17 4. "What did she tell you happened?"
18 A. "She said that she was in bed, and Epstein came
19 into the room and told her that he wanted to cuddle. So he
20 laid down next to her and spooned her. She told him that
21 she had to go to the bathroom to get out of the situation."
22 Q. "What was her reaction to that, when Epstein got
23 into her bed?"
24 A. "She felt uncomfortable. She didn't know what to
25 do."
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1 Q. "Did go back home to when the
2 weekend was over?"
3 A. "Yes, she did."
4 Q. "Did she tell anyone, when she got home, about
5 what had happened?"
6 A. "No."
7 Q. "Is that for the same reason you described
8 earlier?"
9 A. "Yes."
10 Q. "Did Epstein end up paying for to go on
11 trip to Thailand that summer?"
12 A. "Yes."
13 Q. "Did have any contact with Maxwell or
14 Epstein after that trip?"
15 A. "Not that she recalled."
16 Q. "When you interviewed , what was her demeanor
17 like when she described her interactions with
18 Jeffrey Epstein and Ghislaine Maxwell?"
19 A. "She became upset and emotional."
20 Q. "Is currently pursuing a civil lawsuit
21 against Maxwell and Epstein's estate?"
22 A. "Yes, she is."
23 Q. "What does do for a living now?"
24 A. "She's a psychologist who works with trauma
25 victims."
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1 Q. "During the course of this investigation have you
2 interviewed someone named
3 A. "Yes."
4 Q. "For today's purposes I'm just going to refer to
5 her as . How many times have you interviewed
6 , approximately?"
7 A. "Approximately three times."
8 Q. "Turning to the next slide. Is this a photograph
9 of that she provided to you?"
10 A. "Yes."
11 Q. "And did she tell you that this was taken when she
12 was in -- approximately 16 or 17 years old?"
13 A. "Yes."
14 Q. "Is 's date of birth
15 A. "Yes."
16 Q. "Did grow up in England?"
17 A. "Yes, she did."
18 Q. "Did she tell you that there came a point where
19 she met Ghislaine Maxwell when she was about 17?"
20 A. "Yes."
21 Q. "How did she tell you that they met?"
22 A. "She said they met through a mutual friena."
23 Q. "Did she tell you that this would have happened in
24 around 1994 or 1995?"
25 A. "Yes."
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1 Q. "And is that within the same time period that
2 we've been talking about today?"
3 A. "Yes."
4 Q. "What happened after she was introduced to
5 Ghislaine Maxwell, from what she told you?"
6 A. "She said Maxwell treated her like they were
7 sisters. Her quote was 'like naughty school girls' is how
8 Maxwell treated with her."
9 Q. "Did she tell you that Maxwell seemed to
10 immediately take an interest in her?"
11 A. "Yes."
12 Q. "Did she tell you that they began spending time
13 together in London?"
14 A. "Yes."
15 Q. "And just to be clear was Maxwell in her thirties
16 while this is happening?"
17 A. "Yes."
18 Q. "Did Maxwell -- did ever remember Maxwell
19 ever talking about having a boyfriend named
20 Jeffrey Epstein?"
21 A. "Yes."
22 Q. "What did she tell about that?"
23 A. "Maxwell told that Epstein was going to
24 like her."
25 Q. "Did there come a time when she was 17 that
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