{"efta_number": "DOJ-OGR-00014107", "page_count": 197, "url": "https://epstein-data.com/DOJ-OGR-00014107", "pdf_url": "https://epstein-data.com/pdf/DOJ-OGR-00014107.pdf", "pages": [{"efta_number": "DOJ-OGR-00014107", "page_number": 0, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page1 of 197 2542\nLCFCmaxl\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\nx\nUNITED STATES OF AMERICA,\nVv. 20 CR 330 (AJN)\nGHISLAINE MAXWELL,\nDefendant. Jury Trial\nx\nNew York, N.Y.\nDecember 17, 2021\n8:56 a.m.\nBefore:\nHON. ALISON J. NATHAN,\nDistrict Judge\nAPPEARANCES\nDAMIAN WILLIAMS\nUnited States Attorney for the\nSouthern District of New York\nBY: MAURENE COMEY\nALISON MOE\nLARA POMERANTZ\nANDREW ROHRBACH\nAssistant United States Attorneys\nHADDON MORGAN AND FOREMAN\nAttorneys for Defendant\nBY: JEFFREY S. PAGLIUCA\nLAURA A. MENNINGER\n—-and-—\nBOBBI C. STERNHEIM\n-and-\nCOHEN & GRESSER\nBY CHRISTIAN R. EVERDELL\nAlso Present: Amanda Young, FB\nPaul Byrne, NYPD\nSunny Drescher,\nParalegal, U.S. Attorney's Office\nAnn Lundberg,\nParalegal, Haddon Morgan and Foreman\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014107\n", "char_count": 998}, {"efta_number": "DOJ-OGR-00014107", "page_number": 1, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCFCmaxl\n\n(Jury not present)\n\nTHE\n\nak\n\nCOURT: Matters\n\nit's obviously a long list o\n\nDocument 763\n\nf prior inconsistent statements\n\nFiled 08/10/22 Page 2 of 197 2543\n\nto take up, from my perspective,\n\nneed to go through. Before that,\n\nMS. MENN\n\nNGER:\n\nwe hav\n\nYour Honor,\n\nanything,\n\nthere\n\ncounsel?\n\nis one witness that\n\nunder subpoena who has not been in contact with us that\n\nwe very much would like to call as a witness. can say the\nname out loud or we can have a sidebar, but it is one of the\nwitnesses about whom the government moved to preclude their\ntestimony and your Honor ruled last night that we would be\npermitted to put that testimony on. All of our attempts to\nhave communication with this witness after the service of\nsubpoena have gone unresponded to. So I think, at this point,\n\nwe have no choice left\n\nthe marshals\n\nin\n\nxcept to ask to have\n\ntervention of\n\nto bring that witness to court to\n\ntesti\n\nfy.\n\nTHE COURT: You'll have to file something.\n\nMS. MENNINGER: Yes.\n\nTHE COURT: Ms. Comey, anything on that?\n\nMS. COMEY: Your Honor, this is the first time hearing\nof this. We'll have to see whatever is filed.\n\nTHE COURT: Obviously, if you've got authority for how\nto proceed, you need to put that in quickly because we're not\ndelaying trial.\n\nMS. MENNINGER: Secondly, your Honor, with respect to\n\nthe pleading that was\n\nfiled yesterday or the day bef\n\nOre\n\nSOUTH\n\nE RN\n\nD\n\nSTR\n\nCT R\n\nG\n\nPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014108\n", "char_count": 1603}, {"efta_number": "DOJ-OGR-00014107", "page_number": 2, "text_content": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 3 of 197 2544\nLCFCmaxl\n1 asserting a Fifth Amendment privilege, I'm not sure whether\n2 that -—-\n3 THE COURT: [ don't have a pleading, I have --\n4 MS. MENNINGER: Well, a letter from a third party.\n5 That person also was under our subpoena. I don't know if your\n6 Honor views that as sufficient record on a Fifth Amendment\n7 assertion. We have not released the person from their\n8 subpoena. It wasn't styled as a motion to quash. So I'ma\n9 little bit unsure. Otherwise, we would like that witness to\n10 testify, as well.\n11 So, if your Honor deems it necessary to have a further\n12 record on it or a formal pleading from that witness, the\n13 witness is represented by counsel, Compton counsel, a former\n14 AUSA. So I don't know what their intentions are with regard to\n15 their client testifying beyond what the Court received in that\n16 letter.\n17 THE COURT: As said yesterday, I don't have an\n18 application. And I asked if you have an application.\n19 MS. MENNINGER: don't.\n20 THE COURT: And now the application is, Judge, tell me\n21 what you think we should do.\n22 MS. MENNINGER: No, it would be similar. We have a\n23 valid subpoena on the person and I would ask to enforce the\n24 subpoena and have the witness come testify. And if --\n25 THE COURT: Have you communicated with counsel as to\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014109\n\n", "char_count": 1415}, {"efta_number": "DOJ-OGR-00014107", "page_number": 3, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 4 of 197\n\nthe presence of\n\n2545\n\nwhether either a declaration\n\ntion and the like,\n\nremember\n\n. The lawyer requested\n\nyou have\n\nyou should address\n\nfroma\n\nact\n\nfor the subpoena to be\n\nI wanted to\nI think the ball is\n\nthe witness to come\n\nLCFCmaxl\n\n1 whether, in lieu of appearing and outside of\n\n2 the jury, they invoke their Fifth,\n\n3 or a letter from counsel making a representa\n\n4 I think the letter said you rejected that, if\n\n5) correctly.\n\n6 MS. MENNINGER: No, your Honor\n\n7 that we withdraw the subpoena and we said we're not withdrawing\n\n8 the subpoena, we want your client to testify, and if\n\n9 an issue with enforcement of the subpoena,\n\n10 it to the Court, and then the lawyer submitted that particular\n1] letter to the Court. I didn't think that an email\n\n12 lawyer was sufficient to invoke.\n\n13 THE COURT: [t didn't ask the Court to do anything.\n14 The Court is not in the business of just —--\n\n15 MS. MENNINGER: understand.\n\n16 THE COURT: -- reading letters and then going out in\n17 the world and doing things. It's an adversary process.\n\n18 on applications.\n\n19 MS. MENNINGER: Then we'll ask\n20 enforced as to that witness, too.\n21 THE COURT: Okay. Ms. Moe.\n22 MS. MOE Yes, your Honor. On that score,\n23 note the government agrees with the Court,\n24 in defense counsel's court. F they want\n25 to court and invoke in front of the jury --\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212%) 805-0220\n\nDOJ-OGR-00014110\n", "char_count": 1479}, {"efta_number": "DOJ-OGR-00014107", "page_number": 4, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763 ‘Filed 08/10/22 Page\n\n5 of 197 2546\n\nLCFCmaxl\n\n1 THE COURT: It does not happen that anyone invokes in\n2 front of the jury. All we would be doing is, outside the\n\n3 presence of the jury, they come, questions asked, invoke, and\n\n4 then they go home. We could do that if that's what the parties\nS want to do — that seems like an enormous waste of time — or\n\n6 counsel can make an application as to how to proceed after\n\n7 consulting with counsel for the witness. I mean, it's your\n\n8 witness. If you want to send the marshals, despite -- or make\n9 an application to send the marshals despite the witness's\n\n10 counsel indicating to you that they want to invoke the Fifth,\n11 then suppose you can do that, but --\n\n12 MS. MENNINGER: Your Honor, I didn't ask for that with\n13 respect to that witness. asked for it for one who refused to\n14 communicate with us. [ will make a formal application.\n\n15 understand, your Honor.\n\n16 THE COURT: Okay.\n\n17 MS. COMEY: Your Honor, we're happy to confer with the\n18 defense on this issue to the extent the defense wants to make a\n19 record that this witness would have invoked, we're happy to\n20 confer to the extent it would be helpful about how to make that\n2] record.\n22 THE COURT: That's precisely why I raised it last\n23 night and asked if there was an application, but here we are.\n24 But again, we're not delaying trial, so this all needs to\n25 happen yesterday.\n\nSOUTHERN D\n\nSTR\n(212)\n\nCT REPORTERS, P.C.\n805-0300\n\nDOJ-OGR-00014111\n\n", "char_count": 1511}, {"efta_number": "DOJ-OGR-00014107", "page_number": 5, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\nKn\nOY\n\na\n~]\n\nKn\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCFCmaxl\n\nproceeds,\n\nrequesting. Al\n\nis a le\n\n1 I have\n\nthat they hav\n\ntter\n\na def\n\nTf the\n\ninvoke.\n\nand invoke\n\nthat.\n\nwith the government and make a proposal to\n\nOkay.\n\nns\n\nrequest\n\nformally outside th\n\nWhat else?\n\npresence of\n\nDocument 763 Filed 08/10/22 Page 6 of 197 2547\nIt seems to me, again, I've indicated how I think this\nbut I need counsel to tell me what they're\n\nfrom the lawyers saying\nsubpoena and their witness would\n\nis that you want the witness to come\n\nthe jury, we can do\n\nFor that, confer\n\nthe request is some substitution\n\nthe\n\nCourt.\n\nMS. MENN\n\nNG\n\nER: Your Honor, I've conferred with the\n\ngovernment a couple\n\nyesterday, I tried i\n\ntimes on redactions.\n\nt again this morning.\n\nI tried that\n\nI don't have an\n\nanswer back yet from\n\nthe exhibits\n\nsome of\n\nbut\n\nthem, IT hope we can have one soon on\n\nthat are outstanding. That's something\n\nelse that's outstanding.\n\nMR. ROHRBACH: Yes, your Honor, we've been trading\nviews on redactions. We'll finalize them and submit them to\nthe Court shortly.\n\nTHE COURT: Yes, Ms. Sternheim?\n\nMS. STERNHEIM: Judge, I wanted to inform the Court,\nas the government is aware --\n\nTHE COURT: I'm not sure your mic is on.\n\nMS. STERNHEIM: Now it is. There were technical\n\nissues with regard\n\nEngland,\n\nto providing testimony\n\nand we viewed it to be just\n\nHamilton in\n\nfrom Mr.\n\nfar too complicated.\n\nSOUTH\n\nERN D\n\nSTR\n\n(212) 805-0300\n\nCT REPORTERS, P.C.\n\nDOJ-OGR-00014112\n\n", "char_count": 1563}, {"efta_number": "DOJ-OGR-00014107", "page_number": 6, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCFCmaxl\n\nThere was no way that documents could be shown to him wit\n\nall\n\nturning o\n\nviewing him while he looks a\n\nthe equipment\n\nDocument 763\n\nFiled 08/10/22\n\nt and depriving the public of\n\nt certain things.\n\nPage 7 of 197\n\nSo we have\n\ndecided to withdraw our calling him as a witness.\n\nTHE\n\nCOURT:\n\nOkay.\n\nMS.\n\ncourtroom while\n\ntechnical chall\nconsulting with\n\nlonger prepared\n\nthe record that\n\ntechnological d\n\nPOMI\n\nMPRANTZ:\n\nYour Honor,\n\nthat was happening,\n\nI was her\n\nand whil\n\ne in the\n\nth\n\n2548\n\nthout\n\nnges\n\nth\n\nQ\n\ndef\n\nWw\n\nwer\n\nprepared to proceed.\n\nCO\n\n, from our perspective,\n\ncall\n\nn\n\nhi\n\nifficulties,\n\nMr. Hamilton.\nTHE COURT: [ gu\npurposes, Ms. Sternheim,\n\nrequesting be\n\nhere, they'r\n\nrequesting be d\n\none?\n\nMS. ST\n\nthere were things beyond their control\n\njust viewed that it would be\n\nERNHE\n\nduring the process,\n\nwho is not well\n\nM:\n\nSe,\n\nLM.\n\ness,\n\nSO\n\nthey indicated tha\n\njust wanted\n\njust\n\nbut instead that was\n\nTe; wer\n\nA\n\nfter\n\nto be clear\n\nthis 18S not an issue of\n\nunderstanding was they decided to not proceed and call\n\nfor record preservation\n\nis there anything that you're\n\nNo,\n\ndone technologically?\n\nincredibly capable.\n\nI worked with\n\nWe have o\n\nIs there something\n\nur tech\n\nthe\n\nor abil\n\ntech\n\nfar too complicated.\n\nfolks\n\nsom\n\nt they were no\n\nfor\n\nyou're\n\nfolks and\n\nity to do and we\n\nI would also add, as I told the government, that\nDetective Byrne kept calling Mr. Hamilton,\n, and it was somewhat unnerving. So we've made\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014113\n", "char_count": 1663}, {"efta_number": "DOJ-OGR-00014107", "page_number": 7, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Documen\nLCFCmaxl\n\na decision not to call him.\n\nTHE COURT: Okay.\n\nMS. POMERANTZ: Your Honor,\n\nt 763\n\nFiled 0\n\n8/10/22 Page 8 of 197 2549\n\njust to clarify, I don't\n\nthink that's an accurate representation as to Detective Byrne.\n\nAnd I, again, would note that\n\nfolks were here working and\n\nunderstand the decision not\n\ntroubl\n\nleshoot\n\nto cal\n\nthe technological issues, but\n\ncounsel has made.\n\nMS. STERNHEIM: We coul\n\nsuffice it to say, we're not\n\naide\n\nEA\n\nll Mr.\n\nthe very capable tech\n\nting the issue. And I\n\nHamilton was not with\n\nt instead a decision that defense\n\nld go on all day, Judge, but\n\ncalling Mr. Hamilton.\n\nCOURT: You're not calling Mr. Hamilton and you\n\nhave no additional application regarding being able to call him\n\nremotely with public access at th\n\nthere would be a limitation of\n\ntime. Your concern is\n\nsam\n\ntestimony, and for that reason,\n\nyou'v\n\npublic access during his\n\ndecided well, that's\n\nthe case, and you've decided not to call him.\n\nMS. STERNHEIM: That is correct. Thank you.\n\nTHE COURT: All right.\n\nMS. COMEY: Your Honor,\n\nis one brief piece of evidenc\n\nThank you. Anything else?\n\njust in terms of timing, there\n\nthat we may seek to introduce as\n\nrebuttal evidence. I think it would take 10 minutes, at most,\n\nto get in. We just need to know whether we should have those\n\nwitnesses — who are basically custodians — available at the end\n\nof today or if they should be available Monday.\n\nSOUTHERN DISTR\n\nCT REPORTERS, P.C.\n\n(212)\n\n805-0300\n\nDOJ-OGR-00014114\n\n", "char_count": 1632}, {"efta_number": "DOJ-OGR-00014107", "page_number": 8, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCFCmaxl\n\nthink we'\n\nyou indicated or what?\n\ndocuments tha\n\nDocument 763 _— Filed 08/10/22 Page 9 of 197 2550\nTHE COURT: [ think it's today. Ms. Menninger.\nMS. MENNINGER: don't think so, your Honor. I don't\nll be able to rest until Monday morning.\nTHE COURT: That's because there is some small issue\nMS. MENNINGER: There is, your Honor.\nThere also are a number of stipulations that are\noutstanding between the parties. There are some other\nt we are seeking to get custodians and\nto, and they're not ready today. So I understand\n\nstipulations\n\nyour Honor wants to move this forward.\n\nThe det\n\nFense has had its\n\ncase for a day so far. [ don't think we are delaying --\n\nTHE COURT: I'm not suggesting you are. just\nalways -- my approach is I want to use the time that we have.\nAnd needless to say, there is a pandemic. We don't want to\nunnecessarily delay and we want to move forward as quickly as\nwe can using the time we have allocated. So if we have tim\ntoday to get everything in, then we'll do it.\n\nMR. EVERDELL: Your Honor, on the issue of timing,\nthink we mentioned yesterday we may have one more witness who\n\ncan only\n\nSo we will need\n\ncome on Monday.\n\nMS. COME\nTHE COUR\nSO\n\nYs Your Honor,\n\nT:\n\nto have him on Monday,\n\nIt is possible\n\ntha\n\npoten\n\nUTHERN\n\nD\n\nSTR\n\nCT RE\n\n(212) 805-0300\n\nPORTERS,\n\nLD\n\nwe will\n\ntially.\n\ncall him.\n\nwe don't know who that witness\n\nWho is that witness and why can't they be\n\nDOJ-OGR-00014115\n\n", "char_count": 1570}, {"efta_number": "DOJ-OGR-00014107", "page_number": 9, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\nKn\nOY\n\na\n~]\n\nKn\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCFCmaxl\n\nDocument 763 __— Filed 08/10/22\n\nhere today?\n\nMR. EVERDELL:\n\nBecaus\n\nthey're coming\n\nand they can't be here until Monday.\n\nTHE COURT:\n\nWho is it and how long?\n\nMR. EVERDELL:\n\nwitness. And\n\nIt would be a very short\n\nKinnerton Street property.\n\nwhich I\n\ndeclaration from him, can\n\nThey got this signed this morning about what his\n\nwould be. And I\n\ncould provide it to the Court,\n\n[ would like it in front of me, but\n\nsummarize, don't quote me on this, but he is the\n\nPage 10 of 197\n\n2551\n\nfrom the U.K.\n\nHow long is the witness going to be?\nthis is related to the\nI think just today we got a\n\nhand over to the government.\n\ntestimony\n\nas well.\n\ncould generally\n\nthe\n\nowner of\n\nthe street\n\nNags Head Pub, which is right across\n\nKinnerton Street residence. He owned that\n\nthat's relevant her\n\nsaw them there.\n\nownership of the property, and he knew the prior\nliving there,\n\nther\n\nHe knew the previous owners.\n\nfrom the\n\nfor the whole time\n\nHe always\n\nAnd he met Ghislaine Maxwell when she took\n\nowners to be\n\nand then he knew Ghislaine to be living there\n\nwhen she bought the property. And he goes\n\nowned the pub, he had a flat above the pub\n\nto the Kinnerton Street property,\n\napartment.\n\nand he can verify the\n\nvery day. He\n\nthat Looked across\n\nfact\n\nthat she didn't take occupancy until after she purchased the\n\nMS. COMEY:\n\nYour Honor, I would just no\n\nte that the\n\ntime\n\ndefense has had an extraordinary amount of\n\nSOUTHERN D\n\nSTR\n(212)\n\nCT REPORTERS, P.C.\n805-0300\n\nto prepare its\n\nDOJ-OGR-00014116\n\n", "char_count": 1650}, {"efta_number": "DOJ-OGR-00014107", "page_number": 10, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\nKn\nOY\n\na\n~]\n\nKn\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 11 of 197 2552\n\nLCFCmaxl\n\non\n\nfense case. We noted\n\narly last week that we were going to\n\nrest. We rested on Friday. They then had five full days,\n\nincluding three business days, to prepare. So we would object\n\nto holding the case over to Monday for a new witness.\n\nMR. EVERDELL:\n\nextraordinarily relevan\n\nThis is a witness that is\n\nand sometimes things develop during\n\ntrial and we need to ge\n\nup at trial. We were a\n\nbl\n\nwitnesses to address issues that come\n\nprovide this testimony\n\nif\n\nto find this person and he's willing\n\nto come, even those he's 81, because he wants to come and\n\nit's required.\n\nThis is extraordinarily relevant, especially with the\n\nissue that came up with the property records and the issue\n\nraised to the Court. He can directly speak to that issue. His\n\ntestimony is relevant for a critical issue in this case, which\n\n1s whether or not this\n\nthe events that Kate described could\n\nhave even taken place at the time they took place, which she\n\nalleges they took place in, and he should be heard.\n\nMS. COMEY: Your Honor, I just note this is the\n\ndefense's third bite of this particular apple and it emphasizes\n\nthe prejudice to us of\n\nde\n\nlayed disclosure. We will have no\n\nopportunity to investigate further at this point.\n\nDHE COURTS\n\nL me\n\nan, what we talked about yesterday was\n\ninclusion of documents that show ownership; right?\n\nMR. EVERDELL:\n\nTHE COURT: An\n\nThat's correct, your Honor.\n\ndi\n\nthink I said those could come in.\n\nSOUTHERN\n\nD\n\nSTRICT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014117\n\n", "char_count": 1701}, {"efta_number": "DOJ-OGR-00014107", "page_number": 11, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 12 of 197 2553\nLCFCmaxl\n\nMR. EVERDELL: You did.\n\nTHE COURT: Along with, I presume the government would\n\nseek to introduce the testimony?\n\nMS. COMEY: Yes, your Honor.\n\nMR. EVERDELL: That's right, your Honor.\n\nTHE COURT: So a new witness --\n\nMR. EVERDELL: Your Honor, I did not anticipate that\n\nthe issue between ownership versus occupancy was going to be\n\nsuch a relevant issue, and so given that that came up in the\n\ncourse of discussing what the stipulation --\n\nTHE COURT: Just to be clear, I considered that as to\n\nwhether to allow you to introduce ownership documents. I'm\nallowing you to introduce ownership documents. Arguably, they\n\nwere not relevant or marginally relevant, but a 403 issue\n\nbecause of the complications of ownership. If you can put in\n\nthe ownership documents on stipulation as to the timing of\n\nownership, I'm allowing that. It's not a basis -- because I\n\nalmost excluded it, but didn't, that's not a basis to call a\n\nnew witness.\n\nMR. EVERDELL: Your Honor, the stipulation would allow\n\nus to put in the ownership documents and the Court itself\n\nraised that there is an issue with residency or occupancy.\n\nTHE COURT: I raised that in questioning whether the\nownership documents were relevant. I'm allowing the ownership\ndocuments in. That's not a basis to call a new witness.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014118\n", "char_count": 1489}, {"efta_number": "DOJ-OGR-00014107", "page_number": 12, "text_content": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 13 of 197 2554\n\nLCFCmaxl\n\n1 That's just saying, oh, Judge has a good point, maybe we could\n2 strengthen this, I'm going to propose a new witness and delay\n\n3 trial. No.\n\n4 MR. EVERDELL: Your Honor, we're not delaying trial.\n\n5 We only had one day of defense case. We're allowed to put\n\n6 on -—-\n\n7 THE COURT: You're announcing a new witness simply\n\n8 because I've questioned the relevance of the ownership\n\n9 documents by asking if they showed ownership or residency,\n\n10 because I thought, well, if it's just ownership, maybe it's not\n11 relevant, but I'm letting them in. f weren't letting them\n12 in, I suppose you'd have a point.\n\n13 MR. EVERDELL: Your Honor, the way the stipulation\n\n14 understand is going to be worded with the government allowing\n15 admitting the testimony from Ms. Maxwell's testimony, they will\n16 be arguing to the jury that that shows that she didn't reside\n17 there, that the ownership records don't show residency, and you\n18 can infer from that that maybe she was there at the time\n\n19 period.\n20 THE COURT: Is that deposition transcript new\n21 information to you? You weren't aware that your client --\n22 MS. MENNINGER: t was a property deposition that was\n23 taken in 2019, a slip and fall, and she was deposed as a\n24 third-party witness. They didn't give it to us. We still\n25 don't have th ntire deposition. So yes, your Honor, it is\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014119\n", "char_count": 1494}, {"efta_number": "DOJ-OGR-00014107", "page_number": 13, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCFCmaxl\n\nnew to us.\n\nlike\n\nDocument 763\n\nFiled 08/10/22 Page 14 of 197 2555\n\nAnd what she said in that deposition is something\n\n\"92 to '93. She didn't have documents in front of her.\n\nShe was being inquired in 2019 about when she lived someplace\n\nin\n\nto\n\ntrying now to address\n\nrelevant testimony to\n\ndocument that is avail\n\nor you rest. On this issue,\n\nthe\n\nthe\n\nearly '90s, and she made a\n\nportion that was provided to us.\n\nTHE COURT: Yo\n\nMS. COMEY: We\n\nMR. EVERDELL:\n\nMS. COMEY: Your Honor,\n\nTHE COURT:\n\nthat this might be relevant.\n\nthe entire transcript as discovery last w\n\nlready have, your\n\n\"92 comment, '93, according\n\nll provide the transcript.\n\nHonor. We produced\n\nk when we realized\n\nGiven we got there\n\nthis issue wit\n\n[ have a rule:\n\nand the government has a response,\n\nis going to be able to produce one of\n\nthe very issue.\n\nlast week, we ar\n\nth a witness that has\n\nI would note this is a public\n\nlable on a New York State public website.\n\nYou have your next witness\n\nsimply because\n\nI raised a question\n\nwe're not delaying trial.\n\n, but if otherwis\n\nthe case closes\n\nI'm not delaying trial on this issue\n\nsought to have let in.\n\nrest today,\n\nSo we'll s where we ar\n\ntoday, it closes today.\n\nbecaus let in what you\nMR. EVERDELL:\n\nof whether we're going to\n\nof whether the marshal\n\nthe wit\n\nSo we're going to be going over to Monday probably anyway. If\n\nI think, your Honor, that on the issue\n\nwe still have the issue\n\ntnesses that we want that we put on the valid subpoena.\n\nSOUTHERN\n\nD\n\nSTR\n\nCT RE\n\nPORTERS,\n\n(212)\n\n805-\n\n0300\n\nPG ew\n\nDOJ-OGR-00014120\n\n", "char_count": 1715}, {"efta_number": "DOJ-OGR-00014107", "page_number": 14, "text_content": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 15 of 197\nLCFCmaxl\n\n1 we're going to do that, I think we should have the ability to\n\n2 call this witness.\n\n3 THE COURT: When did you start attempting to contact\n\n4 this witness?\n\na) MR. EVERDELL: We issued a subpoena to her, and I\n\n6 don't have the dates off the top of my head, your Honor, can\n7 find that out for you.\n\n8 THE COURT: Two and a half weeks ago?\n\n9 MR. EVERDELL: I think that's when we issued the\n\n10 subpoena.\n\n11 THE COURT: And you've had no contact?\n\n12 MR. EVERDELL: We've been trying to contact her, but\n13 no.\n\n14 MS. MENNINGER: We gave her a letter with all of our\n15 contact information contemporaneous with our subpoena. Every\n16 witness that we have subpoenaed has been in touch with us, they\n17 have called our paralegal, et cetera.\n\n18 THE COURT: But you haven't raised this until now.\n\n19 MS. COMEY: That's exactly the point, your Honor. The\n20 defense has had extensive time to raise this issue and they are\n21 raising it at the 11th hour when they could have raised it long\n22 in advance when all of the other witnesses they subpoenaed were\n23 in touch with them and this one was not.\n24 MR. EVERDELL: Your Honor, look, if the government is\n25 willing to agree to a stipulation as to this witness's\n\nSOUTHERN D\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nLD\n\n2556\n\nDOJ-OGR-00014121\n", "char_count": 1363}, {"efta_number": "DOJ-OGR-00014107", "page_number": 15, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 16 of 197\n\n2557\n\nLCFCmaxl\n1 testimony, we can consider that. We don't have to delay trial.\n2 But think this witness has relevant testimony.\n3 THE COURT: Which witness is it?\n4 MR. EVERDELL: The one who can only come from the U.K.\n5 on Monday. I'm not talking about the marshals issue, I'm\n6 talking about the witness from the Nags Head Pub. If they're\n7 willing to agree to a stipulation, we could probably do it that\n8 way, that wouldn't delay anything, but I think this is relevant\n9 information.\n10 MS. COMEY: Your Honor, I was talking about the\n11 marshal issue.\n12 MR. EVERDELL: I'm sorry.\n13 MS. COMEY: With respect to the marshal issue, we\n14 received absolutely no materials from the defense about\n15 statements that this witness has made, we have no idea what\n16 this witness would say on the stand, so we would not be able to\n17 stipulate to anything.\n18 THE COURT: Which witness have you subpoenaed but\n19 heard nothing from for weeks that I'm hearing about for the\n20 first time?\n21 MS. MENNINGER: Her name is Kelly.\n22 THE COURT: Why am I hearing about it for the first\n23 time now?\n24 MS. MENNINGER: Your Honor, there has been a lot going\n25 on I understand that your Honor runs a tight ship. [ think\n\nSOUTHERN D\n\nSTR\n\nCT R\n\nBPORTERS, P.C.\n\n(212) 805\n\n—0300\n\nDOJ-OGR-00014122\n\n", "char_count": 1350}, {"efta_number": "DOJ-OGR-00014107", "page_number": 16, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\nKn\nOY\n\na\n~]\n\nKn\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCFCmaxl\n\nDocument 763\n\nFiled 08/10/22\n\nPage 17 of 197 2558\n\nthat we've all been working very diligently to present a\n\ndefense in this cas\n\nW\n\nhav\n\nissued with very short\n\nare trying to work out\n\nI understand trying to\n\nbut to be honest, your\n\nTHE COURT:\n\npoint is a nonresponsive witness is not\n\nnotice,\n\nstipulations\n\nrun the\n\nhonored deadlines that are\n\nwe have conf\n\nj\n\nt is a lot of\n\nrred repeatedly, we\n\nfor a number of\n\nwitnesses.\n\ntrial quickly and ef\n\nficiently,\n\nwork.\n\nHonor,\n\nam aware of that, Ms.\n\nMS. MENNING\n\nPR:\n\nknow the number, but 40 witnesses,\n\nworking we've b\n\nthe pond. Our client's lit\n\ngiven one day it to put on a def\n\nn\n\nTher\n\nhave b\n\nMenninger. My\n\nn\n\nnse, on\n\nyour Honor.\n\nI mean,\n\nand a halt\n\nt a little thing.\n\nT don't\n\nWe are\nflying people across the country, across\n\nfe is on the line and we're being\n\nfF days, and\n\nthere is one witness that we're having problems with. We're\n\nnot asking for some weeks' long delay.\n\nTHE COURT: So far, I have nothing.\n\nMS. MENNINGER: have made an oral application, your\nHonor. I understand we will get someone working on a written\none right away.\n\nTHE COURT: Give me a written application, give me a\n\nproposed order within a half an hour.\n\nMS. COMEY:\n\nYour Honor,\n\ncharacterization that the det\n\nhas had an extraordinary amount of\n\nthe government's case and putting on their case.\n\nfendant has just made.\n\nI need to resist the\n\nThe defense\n\ntime betw\n\nSOUTH\n\nE RN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nLD\n\nn th\n\nresting of\n\nThey have had\n\nDOJ-OGR-00014123\n\n", "char_count": 1668}, {"efta_number": "DOJ-OGR-00014107", "page_number": 17, "text_content": "Case 1:20-cr-00330-PAE\nLCFCmaxl\n\nDocument 763\n\nFiled 08/10/22\n\nPage 18 of 197 2559\n\n1 Five full days, including three business days. They had extra\n2 days' notice that we were going to rest on Friday of last week,\n3 and they had plenty of time in advance of trial to plan for\n\n4 this. So we strongly disagree with the suggestion that defense\n5 counsel has been unduly rushed here.\n\n6 MS. MENNINGER: can go back and forth on this, as\n\n7 well, your Honor.\n\n8 THE COURT: We're not going to go back and forth. The\n9 record is what it is. There was a five-day, three-business-—day\n10 break between the close of the government's case. The record\n11 will reflect when you learned when the government will likely\n12 rest, the record will reflect what you said regarding when you\n13 learned of a nonresponsive witness, and the record will reflect\n14 that I will take an application within a half an hour with an\n15 opportunity for the government to respond all in the interest\n16 of conforming to my standard practice, which is everybody has\n17 their next witness or be prepared to rest or bring in a\n\n18 different witness.\n\n19 Now, wetll take it as it comes. What I'm learning,\n20 what is new information to me today, which is different than\n21 yesterday, when we knew when I was informed that the defense\n22 would rest today with the exception of some small issue or\n23 document that Ms. Menninger put aside. There is no argument\n24 about a subpoenaed witness who is nonresponsive. There was no\n25 suggestion of a need for a witness to fly in from England. So\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212%) 805-0220\n\nDOJ-OGR-00014124\n", "char_count": 1622}, {"efta_number": "DOJ-OGR-00014107", "page_number": 18, "text_content": "Case 1:20-cr-00330-PAE\n\nLCFCmaxl\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nI'm learning that today.\n\nDocument 763 ‘Filed 08/10/22 Page 19 of 197 2560\n\nWe've lost the time that we might\n\nhave had, had it been raised sooner. I'll still accept the\n\napplication,\n\nhave your witnesses or you rest.\n\nbut do I have a standard practice, which is you\n\nI have about 40 prior inconsistent statements to rule\n\nwe take that up?\n\nCOURT: Anything else to take up before?\n\n'm trying to get in touch with\n\non. Anything else befor\nMS. COMEY: No, your Honor.\nTHE\nMS. MENNINGER:\n\nsomeone from the office, your Honor.\nTHE COURT: Defe\n\nof a prior in\n\nthat, quote,\n\nnse seeks to admit extrinsic evidence\n\nconsistent statement under 613(b), which requires\n\nthe witness is given an opportunity to explain or\n\ndeny the stat\nto examine th\n\nMy c\n\nement and an adverse party is given an opportunity\n\ne witness about it.\n\nolleague,\n\nJu\n\ndge Kaplan, in the Gulani (poh.) case,\n\nhopefully laid out the proper steps of the analysis.\n\nFirs\nstatement, in\n\nto be impeach\n\nt, the Court must determine whether the proffered\n\nfact, is inconsistent with the testimony sought\n\ned. The test is whether there is any variance\n\nbetween the s\nbearing on cr\nActu\n\nMs. Menninger\n\ntatement and the testimony that has a reasonable\n\nedibility.\n\nally, I just thought of something, a question,\n\n. The witness you haven't been in touch with, is\n\nthat one of the witnesses\n\nfor whom you sought to testify under\n\nSOUTHERN\n\nD\n\nSTRICT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014125\n\n", "char_count": 1602}, {"efta_number": "DOJ-OGR-00014107", "page_number": 19, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCFCmaxl\n\na pseudonym?\nMS.\n\nTH\n\nma\n\nSecond, the parties seeking to of\n\nevidence of a prior inconsistent sta\n\nMENN\n\nNGER:\n\nCOURT:\n\nproper foundation\n\nNo,\n\nOkay.\n\nDocument 763\n\nit was not,\n\nFiled 08/10/22\n\nPage 20 of 197 2561\n\nyour Honor.\n\nJust wanted to ask that.\n\nfer extrinsic\n\nfor doing so by af\n\ncement\n\nFording,\n\nmust have laid a\n\nA, the witness an\n\nopportunity to explain or deny the prior inconsisten\n\nstatement; and B,\n\nthe witness about\n\nThird,\n\nthe opposite party an opportunity\n\nTits\n\ninconsistent\n\nadmissible.\n\nFour\n\nthe extrinsic evidence of the prior\n\nto question\n\nstatement must be competent and otherwise\n\nstatement mus\n\nmatter.\n\nFinally,\n\nth, th\n\neven if\n\nsatisfied, the trial cour\n\nextrinsic ev1\n\ndenc\n\nunder\n\nThat's United States v.\n\n2011).\n\nAt i\n\nimpeached had an oppor\n\nrequirement,\n\nSSUE\n\nG\n\nbut in support of\n\nt relate to material\n\nall\n\nimpeachment by prior inconsistent\n\nrather than a collateral\n\nthese requirements have been\n\nnevertheless may exclude\n\nfirst is step 2,\n\nneed not be shown the prior st\n\nulani, 761 F.\n\nSupp.\n\nRule 403 on an appropriate\n\nthe\n\nfinding.\n\n2d 114.\n\n(S.D.N.Y.\n\nwhether the witness being\n\ntatement.\n\nThe det\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212) 805-0300\n\nLD\n\ntunity to explain or deny the statement.\n\nParties have diametrically opposed interpretations of this\nits position that the witness\n\nfense has\n\nDOJ-OGR-00014126\n\n", "char_count": 1513}, {"efta_number": "DOJ-OGR-00014107", "page_number": 20, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nWw\n\na\nOY\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 21 of 197 2562\nLCF Cmax1\n\nrepeatedly relied on rule 613(a), which uses different language\n\nand is about impeachment by prior inconsistent statement on\n\ncross examination, not introduction of a prior statement as\n\nextrinsic evidence as it seeks to do here.\n\nSo the opportunity to explain the statement should\n\nconsist of something more than just the opportunity to admit or\n\ndeny making the statement. That's right in Miller, 28 Federal\n\nPractice and Procedure Evidence, Section 6205, Note 1, Second\n\nEdition 2021. Citing a Seventh Circuit case and an Eleventh\n\nCircuit case.\n\nNow I'm going to quote from Gulani again. A trial\n\ncourt has discretion to require satisfaction of the latter\n\nrequirement before th xtrinsic evidence is offered or\n\nalternatively to permit it to be satisfied by recalling the\n\nwitness after the extrinsic evidence is received.\n\nIn a case called Surdow, S-u-r-d-o-w, the Second\n\nCircuit stated that the district court has broad discretion to\n\nexclude extrinsic impeachment evidence that was not revealed\n\nwhile the witness was on the stand or at least before the\n\nwitness was permitted to leave the court. That's United States\nv. Surdow, 121 F.Appx. 898 (2d Cir. 2005), collecting\n\nauthorities.\n\nTherefore, the Court will sustain the government's\n\nobjection as to all proposed prior inconsistent statements to\n\nwhich the witness was not presented with the statement to\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014127\n", "char_count": 1588}, {"efta_number": "DOJ-OGR-00014107", "page_number": 21, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nWw\n\na\nOY\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 22 of 197 2563\nLCFCmaxl\n\nexplain or deny it.\n\nNext at issue is the first step of whether the\n\nwitness's testimony and the prior statement are inconsistent.\n\nI provide the following guidance before we turn to the\n\nspecifics.\n\nFirst, if the statement was presented to the witness\n\nand the witness admitted to making the statement, then\n\nextrinsic evidence is inappropriate, and the parties apparently\n\nagree on this point in their last two letters as do circuit\n\ncourts who have decided the issue. That's true for the Fifth\n\nCircuit, Sixth Circuit, and Tenth Circuit.\n\nSecond, the prior inconsistent statement must actually\n\nbe the witness's statement to show an inconsistency. United\n\nStates v. Almonte, 956 F.2d 27, (2d Cir. 1992).\n\nWhere the defense relies on a third party's\n\ncharacterization of the witness's words rather than a verbatim\n\ntranscript, then the witness must have subscribed to that\n\ncharacterization. On that basis, notes taken in law\n\nenforcement interviews will generally not prove an\n\ninconsistency for purposes of rule 613(b). See, for example,\n\nUnited States v. Leonardi, 623 F.2d 746, the Gulani case and\n\nothers.\n\nOf course, that infirmity is solved by calling the\n\ninterviewing officer as a witness or to avoid calling another\n\nwitness, the government stipulates to the accuracy of the\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014128\n", "char_count": 1506}, {"efta_number": "DOJ-OGR-00014107", "page_number": 22, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763\nLCFCmaxl\n\nnotes.\n\nFiled 08/10/22 Page 23 of 197 2564\n\nThird, as I previously explained, testimony that a\n\nwitness does not recall making a statement may be but is not\n\nnecessarily a basis for inconsistency.\n\nFinally, I'll apply 403,\n\nrulings of prior inconsistent statemen\n\nin full into the record. I'll sustain\n\nconsistent with my prior\n\nt has already been read\n\nthe government's\n\nobjection to admitting the statement as extrinsic evidence.\n\nSee, for example, United States\n\n(2d Cir. 1977). Stating wher\n\nV.\n\nKing,\n\nvidenc\n\n613, it could be excluded under 403.\n\n560 F.2d 122\n\nis admissible under\n\nWith that, we can turn to the list of the prior\n\nstatements and I'll do my best to apply that guidance I've just\n\ngiven in light of the arguments raised by the parties and my\n\nreview of the transcript.\n\nSo beginning with Jane,\n\ntranscript at 447, I will\n\noverrule. Jane denied the statemen\n\nwhich is an inconsistency, even\n\nif\n\nJane's testimony. I will overrule\n\nthe\n\nt in the handwritten notes,\n\nlater 302 corroborates\n\nthat government objection.\n\nTranscript at 455, I'll sustain the government's\n\nobjection for two reasons. The\n\nthe record and Jane responded it was,\n\nadmitting the statement.\n\nTranscript at 470 to 71,\n\nquote,\n\noverruled.\n\nfull statement was read into\n\ncorrect, I guess,\n\nHere the defens\n\nhas adequately identified the statement at issue.\n\nSOUTHERN DISTRICT RE\n\nPORT\n\nERS,\n\n(212) 805-0300\n\nPG ew\n\nDOJ-OGR-00014129\n\n", "char_count": 1584}, {"efta_number": "DOJ-OGR-00014107", "page_number": 23, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 24 of 197 2565\n\nLCFCmaxl\n\nTranscript at 471, sustained. As I said at the time,\n\nthe timeframe of that question was too unclear to create an\n\ninconsistency and no statement was presented to Jane to explain\n\nor deny it.\n\nTranscript at 473 to 74, overruled. That's provided\n\nadmissibl] videnc ither via stipulation or a witness is used\n\nto prove the notes.\n\nTranscript at 475, sustained. Jane's prior statement\n\nwas that she was not sure where the incident happened, so there\n\nis no inconsistency. She also answered \"I don't recall\" to\n\neach question, so there is no inconsistency.\n\nTranscript 475 to 76, I'll sustain. The defense's\n\nquestions did not track the 302 report, does not refer to\n\nwhether the defendant touched Jane or not. The defense\n\nreferred Jane to the December 2019 interview document, but then\n\nasked questions about the February 2020 interview. So there is\n\nan inadequate basis for inconsistency.\n\nTranscript at 476, lines 2 through 4, sustained.\n\nAgain, the defense referred Jane to the incorrect interview and\n\nfor the statement it now seeks to admit in Jane's statement\n\nthat she doesn't recall, she said she was not sure is not an\ninconsistency.\n\nTranscript at 476, lines 8 through 10, sustained. The\n\nquestion follows the above entry and again fails to properly\n\norient Jane, and Jane said \"I don't recall,\" which is not\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014130\n", "char_count": 1588}, {"efta_number": "DOJ-OGR-00014107", "page_number": 24, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCFCmaxl\n\nDocument 763\n\nFiled 08/10/22\n\ninconsistent.\nTranscript at 476, lines 14 through\nthe same reasons as the last two.\nTranscript at 476, line 17 through 1\nthe same reasons.\nTranscript at 477, sustained for the\nTranscript at 478, overruled.\nTranscript at 479 to 80, overruled.\nTranscript at 480, sustained. There\ninconsistency, because Jane's answer that she\n\nand her prior statement\n\nthat she did not know\n\nPage 25 of 197 2566\n16, sustained for\n9, sustained for\n\nsame reasons.\n\nis no\n\ndoesn't remember\nwhether\nEEHCY .\n\n1 overrule.\n\nMs. Maxwell was present, there is no inconsis\nTranscript at 499, 507 to 508, I wil\nTranscript at 506 to 7, sustained.\n\nmaking the prior statement.\n\nTranscript at 512 to 13, sustained.\n\nJane admitted to\n\nJane's prior\n\nstatement that they hiked is not inconsistent with her\n\ntestimony.\n\nAlso not material.\n\nTranscript at 513, overruled.\n\nTranscript at 514, overruled.\n\nTranscript at 514 to 15, sustained. Jane's prior\nstatement about abuse in New York not being, quote, a group\nthing, is not inconsistent with her testimony.\n\nTranscript at 521 to 22, sustained. Jane agreed with\nvirtually all of the details of this event, except for the\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212%) 805-0220\n\nDOJ-OGR-00014131\n", "char_count": 1387}, {"efta_number": "DOJ-OGR-00014107", "page_number": 25, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 26 of 197 2567\n\nLCFCmaxl\n\ntimeline, which she said she does not remember and is not a\n\nbasis for inconsistency and it\n\n532, sustained.\n\n596, sustained,\n\nThat's, I believe,\n\ncorrect?\n\nMS. COMEY: Ye\n\nMS. MENNINGER:\n\nSy\n\nt goes\n\nto a collateral matter.\n\nStatement was read aloud.\n\nthe statement was read aloud.\n\nall of\n\nyour Honor.\n\nYes,\n\nF the Jane statements; is that\n\nyour Honor. The parties had\n\nagreed to a few either being in or out before we\n\nthis, so those are part\n\nMS. COMEY: Ye\n\ne)\n\nSy\n\nthe parties know what they are.\n\nyour Honor.\n\nsubmitted\n\nf the record your Honor just gave, but\n\nTHE COURT: Thank you, Ms. Menninger, for that\n\nclarification.\n\nNext, Annie.\n\nTranscript at 2151,\n\nsustained.\n\nstatement but said she didn't recall making it.\n\ninference of inconsistency.\n\nTranscript at\n\nthere is not an inconsistency.\n\nchef, but, quote, that\n\nthere, quote. It also\nTranscript at\n\nalready read out loud,\n\nShe acknowledged the\n\nSo there is no\n\n2160 to 61, sustained. Annie said --\n\nmakes sense to me that there was a chef\n\nAnnie said she didn't recall a\n\ngoes only to a collateral issue.\n\n2165 to 66, sustained. 5S\n\ntestimony is not inconsist\n\namount of horseback riding is collateral.\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORTERS, P.C.\n\n(212)\n\n805-0300\n\ntatement was\n\ntent, and the\n\nDOJ-OGR-00014132\n\n", "char_count": 1465}, {"efta_number": "DOJ-OGR-00014107", "page_number": 26, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCFCmaxl\n\nTrans\n\nsustained tw\n\nissue.\nmake its impea\n\n2182\n\n2185\n\nand there is no inconsistency as\n\n2195,\n\n2197 and 98,\n\ncharacterize Ms.\n\nnot an inconsi\n\nexplain or deny the statement or lack thereof.\n2209 to 13,\n\nand Annie answered, \"I\n\n2224,\n\nread aloud and I\n\nI think that's it.\n\nDocument 763\n\ncript at\n\nFiled 08/10/22\n\n2174 to 76 and 2194 to 95,\n\nPage 27 of 197\n\nI'll sustain.\n\no objections to continuing question on this\n\nStatement was read aloud and the defense made and can\nchment argument.\nto 83, sustained. The statement was read aloud.\nto 86, sustained. The statement was read aloud\n\nsustained\n\nsustained.\nMaxwell as, quote\n\nstency. Further,\n\nsustained.\n\nsustained.\n\nfor the same reasons\n\n[ previously ruled at 2186.\n\njust indicated.\n\nAnnie did not earlier\n\ntf\n\ndisinterested, but that's\n\ndon't recall.\"\n\nAnnie had no opportunity to\n\nThere isn't an inconsistency\n\nAnd just on\n\ndon't see an inference of\n\nAnything else on that?\nMS. COMEY: No, your Honor.\nTHE COURT: Ms. Menninger?\nMS. MENNINGER: No,\nTHE COURT: Again,\n\nagreed on others.\nMS. MENNINGER: Yes,\n\nyour Honor.\n\nyour Honor.\n\nthat last one,\n\nit was\n\ninconsistency.\n\nrecognizing that the parties had\n\nJust with respect to\n\none thing your Honor just said, because the statement was read\n\nSOUTHERN D\n\nSTR\n\nCT R\n\nG\n\nPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\n2568\n\nDOJ-OGR-00014133\n", "char_count": 1484}, {"efta_number": "DOJ-OGR-00014107", "page_number": 27, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCFCmaxl\n\naloud,\n\nmake th\n\nthe\n\naloud, even if\n\ndoes not prohibit us\n\nthe statement was,\n\nimpeaches\n\nDocument 763\n\nimpeachment argument.\n\nwitness doesn't recall\n\nin fact,\n\nthe witness's testimony;\n\nTHE\n\nCOURT:\n\navailable to argue.\n\nMS. COMEY:\n\nFes La\n\nFiled 08/10/22 Page 28 of 197 2569\n\nI believe the phrase you just used was the defense can\n\nBecause the quote was read\n\nmaking the statement\n\nfrom making an argument to the jury that\n\nmade to law enforcement and\n\ncorrect?\n\nthe record, that inference is\n\nAny disagreement?\n\nNo objection,\n\nMS. MENN\n\nNGER:\n\narguments —-\n\nEe\n\nCOURT:\n\nina\n\n[ totally appreciate\n\nyour Honor.\n\njust want to make sure in closing\n\nthat. And anything\n\nto avoid objections during closi\n\nMS. COMEY:\n\nObviously it's not\n\nng argument.\n\nfor the truth, it's for\n\nimpeachment, but no objection to that argument.\n\nMS. MENN\n\nNGER:\n\nthink impeachment is\n\nfor the truth,\n\nyour Honor.\n\nTHE COURT:\n\nhandle at\n\nthis moment.\n\nMS. MENN\n\nNGER:\n\nTHE\n\nCOURT:\n\nMS. COMEY:\n\nthe rulings on the\n\nthere is no longer\n\nThank you.\nYour Honor,\nAnnie Farmer\n\nany relevance\n\nThat is way more metaphysical than\n\ncan\n\nThank you.\n\nI would note that in light of\n\nstatements, it appears that\n\nfor calling AUSA Rossmiller as\n\nfrom\n\na witness, and I just want to confirm that he is released\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212%) 805-0220\n\nDOJ-OGR-00014134\n\n", "char_count": 1493}, {"efta_number": "DOJ-OGR-00014107", "page_number": 28, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCFCmaxl\n\nDocument 763\n\npotentially having to testify.\n\nTHE\n\nCOURT:\n\ndon't have a basis to know.\n\nFiled 08/10/22\n\n[ think that's a conferral question.\n\n'm not sure what the status is of\n\nPage 29 of 197 2570\n\nI'm asking so that there\n\nyou can think about\n\nKing, if that was a\n\nMS. COMEY: Yes, your Honor.\nis a clear record.\n\nTHE COURT: Okay. Ms. Menninger,\nit.\n\nMS. MENNINGER:\nthis email with Mr. Glassman about The Lion\nstipulation --\n\nMS. COMEY: Your Honor, I believe\nYour Honor's ruling about testimony from at\n\nth mail\n\nthat was precluded.\n\nLorneys was that the\n\nfrom —--\n\nonly permissible testimony would have been\n\nthe statement by Mr. Glassman about whether\n\ntestifying would\n\nhelp her case and that all other testimony about attorneys\n\nwould be precluded.\n\nTHE this is\n\nCOURT: ic\n\nrelated to calling the three attorneys,\n\nwith respect to that.\n\nMS. MENNINGER: '1]\n\nHonor. That's the only other\n\nrespect to Mr. Rossmiller's potential --\n\nTHE COURT:\n\ntestimony, which may have been my basis.\n\nMS. MENNINGER:\n\nt may be,\n\nhave to look back at that,\n\nyour Honor.\n\nimplicated in the motion\n\nthen that was my ruling\n\nyour\n\nthing that's coming to mind with\n\nThat series was questioned during the\n\njust don't\n\nSOUTHERN D\n\nSTR\n(212)\n\nCT REPORTERS,\n805-0300\n\nPG ew\n\nDOJ-OGR-00014135\n\n", "char_count": 1422}, {"efta_number": "DOJ-OGR-00014107", "page_number": 29, "text_content": "=\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\na\n=\n\nN\n\nWw\n\nCase 1:20-cr-00330-PAE\n\nLCFCmaxl\n\nremember if\n\nDocument 763\n\nthe witness --\n\nFiled 08/10/22\n\nPage 30 of 197\n\nTHE COURT: t's fine.\n\nMS. MENNINGER: Said she didn't know about it because\nit was her lawyer who had had the communication.\n\nMS. COMEY: My recollection, your Honor, is that we\n\nhad this discussion on the record and that Jane testified that\n\nshe was to\n\n1997, and I\n\nwas -—- that\n\nabout her\n\navailable\n\nthink defense counsel\n\nit was after that,\n\nfor det\n\nMS.\n\nDr.\n\nLo\n\ntravel to New York.\n\nelicited\n\nld at some point about The Lion King coming out in\n\nfrom her that that\n\nSo\n\nM\n\nENN\n\nNG\n\nthat she had a di\n\nBR:\n\nthink,\n\nas your Honor heard\n\nfferent memory\n\nI think the record is\n\nfense to make the argument it wants to make.\n\nfrom\n\n2571\n\nthe\n\nfact tha\n\nftus yesterday, t someone suggests an answer\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nand that\ntestimony,\n\nMr. Rossmil\n\nbecause it came through\n\nler,\n\nmay be the part that wasn\n\nbut\n\n't clear from Jane's\n\nher attorney,\n\nT'll go back and take a look at your\n\nHonor's ruling and raise any issues with the government in\n\nconferral.\n\nTHE COURT: Okay. I will cross whatever bridge you\nput in front of me. I'm looking at my ruling on the three\nattorneys, which kept out that testimony.\n\nWhat else?\n\nMR.\n\nthe witnesses this morning,\n\nAmanda Youn\n\nBV\n\nWe do have all\n\nour jurors.\n\nBR\n\nDELL:\n\ngr\n\nwho is one of\n\nYour Honor,\n\nanticipate that one of\n\nthe defense will call Special Agent\n\nthe case agents on the\n\nSOUTHERN\n\nDISTR\n\nCT RE\n\nPORT\n\nBRS, Pes\n\n(212)\n\n805-\n\n0300\n\nDOJ-OGR-00014136\n", "char_count": 1610}, {"efta_number": "DOJ-OGR-00014107", "page_number": 30, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22 Page 31 of 197 2572\n\nLCFCmaxl\ninvestigation. just want to make clear that she be called as\na witness who's associated with an adverse party. So I intend\n\nto use leading questions under rule 611(c).\n\nTH\n\nwith direct\n\nand if\n\ndirect questions,\n\nanswers or you're ge\n\ndelaying, I'll take\nMs. Comey,\nMS. COMEY:\n\nE COURT:\n\nalways encourage you to try -- you begin\n\nshe becomes adversarial, truth comes out in\n\nbut i\n\nf you're not getting response to the\n\ntting somewhat responsive answers but it's\nthe application.\n\ndid you have something?\n\njust wanted\n\nunderstanding of Agent Young's test\n\nto note, your Honor, that my\n\nimony is that it's going to\n\nbe about the prior inconsistent statements of Jane that your\n\nHonor has ruled are admissible.\n\nleading wil\n\nMR.\n\nBV\n\nBR\n\nD\n\nBLL:\n\n1 be necessary\n\nfor\n\nYour\n\naspects with Special Agent Yo\n\nthat.\nHonor,\n\nung.\n\n[ don't imagine that much\n\nintend to go into other\n\nTHE COURT: Like what?\n\nMR. EVERDELL: Well, I believe, under your Honor's\nruling, I'm allowed to inquire about the absence of evidence,\nand there is an absence of evidence in this case.\n\nTHE\n\nUR\n\nT:\n\nMR.\n\n1990s, there is no geo location.\n\nBV\n\nBR\n\nD\n\nBLL:\n\nWell,\n\nthere\n\nthe jury, these are all things that\n\nmodern era would expect,\n\nGive me an example question.\n\n1s no emails from the\n\nIT want to make that clear for\n\nI think jurors in the\n\nand there is none here, given the age\n\nSOUTHERN\n\nD\n\nSTR\n\nCT RE\n\nPORTERS, PwC.\n\n(212\n\n) 805-\n\n0300\n\nDOJ-OGR-00014137\n\n", "char_count": 1636}, {"efta_number": "DOJ-OGR-00014107", "page_number": 31, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 32 of 197 2573\nLCFCmaxl\n\nof the case. There is no phone records. There is no -- there\n\nis lots of things that you might expect to be part of the case\nthat are not here. The main reason for that is that the age of\nthe case, especially the allegations in the 1990s are quite old\nand these records don't exist anymore. So I think it's fair to\nraise to the agent the absence of evidence, that evidence\n\nrough the agent.\nTHE COURT: So,\nquestion on emails.\nMR. EVERDELL: It'\n\npart of!\n\ns in her\n\nThat's one topic.\n\nfor example, g\n\nsomewhere,\n\nive me your example\n\nAs\n\nF your investigating the case,\n\nyour Honor.\n\nyou tried to gather as\n\nmuch documentary evidence as you can to corroborate what the\n\nwi\n\ntnesses ar\n\ntelling you,\n\nisn't that right.\n\nimagine the\n\nanswer is going to be yes to that. And given the age of the\ncase, ther re no emails from the 1990s, there are\nallegations in this case from the 1990s, correct, yeah. There\n\nare no emails tha\n\nt you have\n\nfor any of\n\nthe accusing witnesses\n\nwho testified against Ms. Maxwell from the 1990s, is that\nright, yes. Because, in fact, in the 1990s, nobody used email,\nit wasn't very popular, it was just starting, yes. So because\nthe allegations are over 25 years old, there are no emails in\nthis case from that period, isn't that right, yes, there is no\nemails. Same thing about phone --\n\nTHE COURT: I'm sorry. cut you off, Mr. Everdell.\nSame thing about phone records?\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212%) 805-0220\n\nDOJ-OGR-00014138\n\n", "char_count": 1664}, {"efta_number": "DOJ-OGR-00014107", "page_number": 32, "text_content": "be\n\nNO\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 33 of 197 2574\nLCF Cmax1\n\nMR. EVERDELL: Phone records, geo location\n\ninformation, things like that.\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\nca)\n\nbe\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nKe)\n\nMR. ROHRBACH: This implicates at least two of the\n\nCourt's rulings on the subject. One is that the defense can't\n\nelicit direct testimony about investigative steps that the\n\ngovernment did or did not take. And the other is defense can't\n\nelicit direct testimony about the thoroughness of the\n\ngovernment's investigation. As your Honor ruled, they can say\n\nin their closing there is no email evidence before you that\n\ngoes to defendant's guilt or innocence, but they can't elicit\n\ntestimony from the special agent, the government's case agent\n\nabout the steps the government did or did not take or why the\n\ngovernment did or did not take them and what that says about\n\nthe thoroughness of the government's investigation.\n\nMR. EVERDELL: Your Honor, I believe I am allowed to\ncomment on the absence of evidence. I'm allowed to put that in\nthrough a witness if I choose and this is the witness to do it.\n\nTHE COURT: Not inconsistent with my ruling.\n\nMR. EVERDELL: I understand that, your Honor.\n\nTHE COURT: ‘ll pull it up and look again, but with\n\nrespect to the ability to cross examine witnesses put on to\n\nshow the thoroughness of the investigation, you can cross on\n\nthe failure to do that. The absence of evidence is arguments\n\nthat you can make comments on, of course, and seek the jury to\n\nconclude from it what it likes in the course of its\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014139\n\n", "char_count": 1653}, {"efta_number": "DOJ-OGR-00014107", "page_number": 33, "text_content": "be\n\nNO\n\nCase 1:20-cr-00330-PAE\n\nLCFCmaxl\n\ninvestigation\n\nfailure of\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\n, but\n\nDocument 763\n\nspecifically precluded direct\n\nFiled 08/10/22 Page 34 of 197 2575\n\nvidence of\n\nMR.\n\ntechnique per\n\nevidence that a jury might\n\nmodern era,\n\nof the allegations.\n\nEVERI\n\nDELL:\n\nse,\n\nis not present\n\nyour Honor\n\ninvestigative techniques.\n\nI'm not saying an investigative\n\n. I'm simply pointing out that\n\nct expect\n\nto see, given we are in the\n\nSo\n\nfies the\n\nclari\n\ntried to get them,\n\nparticular\n\na case of this age,\n\nphone records get deleted at\n\nfac\n\ntechnique,\n\nt that these records don't\n\nI think,\n\nin\n\nI think this point through the agent\n\nand they didn't exist.\n\nit's just highlighting the\n\nthem because of\n\nfront of the age\n\nexist anymore, they\n\nIt's not a\n\nin\n\nfact that,\n\nthere ar\n\nrecords that have disappeared,\n\nas geo location information,\n\nthese things.\n\nSo pointing it out\n\nthe absence o\n\n£ evid\n\nbeca\n\nFter a while,\n\nthere is no such thing\n\nthere weren't cellphones that had\n\nto the agent is simply pointing out\n\nther\n\nthe record to argue\n\nne\n\nus wouldn't be anything in\n\nthat to\n\nthat in front\n\nof --\n\ntion o\n\nthrough\n\nthis agent.\n\nthe jury if I'm not allowed to put\n\nthere needs\n\nI mean, ES\n\nthe\n\nbe some explanat\n\nprovide that these people didn't have cellphones to\n\nknowledge,\n\nso they wouldn't have had geo\n\nfact that\n\nthink this agent could\n\ntheir\n\nlocation information\n\nand that's why we don't have it in this case.\n\nMR.\n\nROHRI\n\nwants to put\n\ncase fromac\n\nthis\n\nSOUTHERN D\n\nBACH:\n\nin, your\n\nHonor.\n\nI'm a little confused why the defense\n\nWe've had testimony in this\n\nustodian and others about what recordkeeping\n\nSTR\n\nCT REPORTERS, P.C.\n\n(212)\n\n805-0300\n\nDOJ-OGR-00014140\n\n", "char_count": 1789}, {"efta_number": "DOJ-OGR-00014107", "page_number": 34, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` LCFCmax1 the agent and just elicit from the agent that there were no phone records because phone records get deleted after a certain amount of time, but I believe they tried to get phone records, but none existed because of the age of the allegations. I mean, geo location, I think anybody who could testify to the fact that there aren't geo location -- the information, especially an FBI agent because cellphones didn't exist back then, there weren't records available back then. And emails, too, that there were no emails to get because of the age of the case. That's all I'm trying to do with that point, your Honor, is elicit the absence of evidence so that we can then argue it in front of the jury. MR. ROHRBACH: Your Honor, they don't have to elicit the absence of evidence in order to argue to the jury that the evidence is absent. So to the extent they are trying to elicit the absence of evidence through Special Agent Young is just the argument they want to make in closing made through leading questions on direct examination of a federal law enforcement agent. THE COURT: I'm just going to reread the relevant portion of the transcript. I will take them as they come, but my instinct is the government is correct, you're either violating my rule or you're being argumentative in a way that you can argue from an absence in closing. MR. EVERDELL: Your Honor -- ``` | OBJECTS: The image contains text and no other objects are visible. | SETTING: The setting appears to be a courtroom or legal proceeding, indicated by the presence of a judge and attorneys. | ACTIVITY: The activity in the image involves a legal discussion or argument between attorneys and a judge. The judge is considering a point raised by one of the attorneys regarding the absence of evidence. | NOTABLE: The image does not contain any unusual or concerning elements. It appears to be a typical legal document or transcript.", "char_count": 1979}, {"efta_number": "DOJ-OGR-00014107", "page_number": 35, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 36 of 197\n\n2577\n\nLCFCmaxl\n\n1 the agent and just elicit from the agent that there were no\n\n2 phone records because phone records get deleted after a certain\n\n3 amount of time, but I believe they tried to get phone records,\n\n4 but non xisted because of the age of the allegations.\n\ni) mean, geo location, I think anybody who could testify to the\n\n6 fact that there aren't geo location -- the information,\n\n7 especially an FBI agent because cellphones didn't exist back\n\n8 then, there weren't records available back then. And emails,\n\n9 too, that there were no emails to get because of the age of the\n10 case. That's all I'm trying to do with that point, your Honor,\n11 is elicit the absence of evidence so that we can then argue it\n12 in front of the jury.\n\n13 MR. ROHRBACH: Your Honor, they don't have to elicit\n14 the absence of evidence in order to argue to the jury that the\n15 evidence is absent. So to the extent they are trying to elicit\n16 the absence of evidence through Special Agent Young is just the\n17 argument they want to make in closing made through leading\n18 questions on direct examination of a federal law enforcement\n19 agent.\n20 THE COURT: I'm just going to reread the relevant\n21 portion of the transcript. I will take them as they come, but\n22 my instinct is the government is correct, you're either\n23 violating my rule or you're being argumentative in a way that\n24 you can argue from an absence in closing.\n25 MR. EVERDELL: Your Honor —-\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014142\n", "char_count": 1591}, {"efta_number": "DOJ-OGR-00014107", "page_number": 36, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCFCmaxl\n\nTHE\n\n25\n\nwhich, i\n\norder to the\n\nextent that\n\nagent what she did or didn't do, which\nof my order.\n\nAnd the whole point of the --\nof not allowing the defense\n\ngovernment did or didn't do\n\nCOURT:\n\nf probed into,\n\nextent that you're making arguments -- to\n\nfoundational\n\nDocument 763\n\nOr there would be\n\nFiled 08/10/22\n\nessentially would be violative of\n\nPage 37 of 197\n\nfoundation issues,\n\nmy\n\nthe\n\ninferences ar\n\nssentially asking\n\nis precise]\n\nthe\n\ny a violation\n\njury is,\n\nthey deemed c\n\nthe charges.\n\nI mean,\n\nthe whole point\n\nto put on a case about what the\n\nand the motivations and the like is\nbecause that's the question for the jury. The question for the\ndoes th vidence that the government put on, that\nredible, prove beyond a reasonable doubt or not\nThat is the core basis of my in limine holding.\nMR. EVERDELL: I'm not trying to violate this, which\n\nis why we're\nwas some room\n\nevidence r\n\nof\n\nwhat\n\nthinks what\n\nmight have to\n\ndiscussing this,\n\nto b\n\nyour Honor.\n\nable to\n\nI was intending to do with\nI've just\n\nthe questions on that\n\nwh\n\nbecause of\n\nTH\n\nma\n\nmodern case,\n\nevidence,\n\nat you're saying, but\nCOURT: Yeah, I mean, take it\nright, and you ask why didn't\n\nather than just arg\n\nthink it out and not\n\nproposed,\n\npoint are,\n\nlicit evidence about\n\nthis witness. If the Court\nthat's generally the tenor of\n\nviolative of\n\njust thought there\n\nthe absence\n\nument to the jury, and that's\n\nthe order,\n\nbe able to go into it\n\nI hear what you're saying.\n\n-- imagine it's a\n\nyou get geo location\n\nit's asking what the government did or didn't do.\n\nSOUTHERN D\n\nSTR\n(212)\n\nCT RE\n805-0300\n\nPORTERS,\n\nPG ew\n\n2578\n\nDOJ-OGR-00014143\n", "char_count": 1782}, {"efta_number": "DOJ-OGR-00014107", "page_number": 37, "text_content": "Case 1:20-cr-00330-PAE Document 763\n\nFiled 08/10/22\n\nPage 38 of 197 2579\n\nLCFCmaxl\n1 You essentially want the -- I'ma little with Mr. Rohrbach.\n2 I'm not sure why you want the government or if this is a spin\n3 to make -- to try to hide what the question is doing, but you\n4 want the government to testify, well, we didn't get geo\n5 location information because it didn't exist.\n6 MR. EVERDELL: Your Honor, I'll be very transparent.\n7 I think the point is highlighting the age of the allegations,\n8 which I think is a fair point to make to the jury. These are\n9 allegations that are 25 years old, and when you make a case on\n10 allegations that are more than 25 years old, you're not going\n11 to have the same type of corroboration available to you because\n12 records get destroyed in that amount of time. The records\n13 aren't available that long ago that are available today that\n14 you might otherwis xpect to to see in a case like this.\n15 But the bigger point is just the age of the\n16 allegations. So the absence of evidence goes to the fact that\n17 these are 25-year-old allegations.\n18 (Continued on next page)\n19\n20\n21\n22\n23\n24\n25\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nLD\n\nDOJ-OGR-00014144\n\n", "char_count": 1214}, {"efta_number": "DOJ-OGR-00014107", "page_number": 38, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHVMAX2\n\nDocument 763\n\nFiled 08/10/22\n\nT'1]\n\nTHE COURT: How about this:\nagent -- suppose I'll hear from\n\nWhat is the time period of\ninvestigated?\n\nMS. COMEY:\n\nthe charges here.\n\nYour Honor,\n\nappropriate\n\nfor this trial\n\nthat this agent was the case agent\n\nAnd so it could\n\ntrial. And I\n\ncrystal clear here\n\ntestimony by the defense.\n\nDe\n\nyou didn't see\n\nfense counsel,\n\nfront of a jury and says,\n\ndon't need to put an agen\n\nThey are abl\n\nthat case through af\n\nto make that\n\nFirmat\n\nand that are irrelevant\n\nthink that your Honor's pretrial\n\nthe government.\n\nPage 39 of 197\n\nlet you ask the\n\nthe allegations that she\n\nlead to avenues\n\n[ think that the investigation\n\nfor was much broader than\n\ntha\n\nct are not\n\nin almost every trial,\n\nYou didn't see this kind of\n\nme)\n\nthat this is not appropriate direct\n\nthis\n\nruling was\n\nstands up in\n\nDNA, you didn't see phone records.\n\nevidence,\n\nAnd they\n\nt on the stand to prove that negative.\n\nt argument\n\ntive agent\n\ntrue here.\n\nTHE\n\nCOURT:\n\nYou can certainly argue to the jury\n\nwithout having\n\ntestimony, and\n\nthe\n\nto put on\n\nsame is\n\nfrom\n\nthe indictment and what they are being instructed to determine\n\nwhat the age of\n\nMR.\n\nAs we're doing this,\n\nfew other points,\n\nruling.\n\nEVERDELL:\n\nsince\n\nOkay.\n\nthe allegations are.\n\nSOUTH\n\nE RN\n\nD\n\nSTR\n\nCT RE\n\nPORT\n\nBRS, Pes\n\n(212)\n\n805-0300\n\nD\n\nIT understand, your Honor.\nI think maybe we should raise a\n\nI don't want to violate the judge's\n\nOJ-OGR-00014145\n\n2580\n", "char_count": 1592}, {"efta_number": "DOJ-OGR-00014107", "page_number": 39, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHVMAX2\n\nthey\n\ninterviews, like,\n\nWe heard\n\nDocument 763\n\nI do intend to go through with\nfollowed up on certain things that\n\nfor example -—-\n\nFiled 08/10/22\n\nPage 40 of 197\n\nthis witness whether\nthey heard in the\n\nT'll give an example.\n\nfrom Jane testimony -- she confirmed on the\n\nstand that she told the government that she was involved in\n\nsexualized massages with multiple people,\n\nfirst names of\n\nwhat she was saying to the government who thos\n\nit's the subject ot\n\nCourt about other witnesses\nMy understanding is\n\nwere provided to us,\n\nthese witnesses,\n\nmentioned was Michelle.\n\nThat\n\nMichelle -- at\n\ncommunicated\n\nfice.\n\nin the of\n\nth\n\nwith some of\n\nseveral of\n\nright.\n\nF some of\n\nthose people.\n\nand sh\n\n[ believe we know\n\nnamed th\n\nthey didn't\n\nSo,\n\nfor example,\n\nfollow up and\n\nWe think we know who that\n\nMichelle was evident to the government becaus\n\npeople are,\n\nthese submissions we made to the\nthat we want to call.\nfrom looking at the records that\n\ntalk to some of\n\none of\n\nthe names\n\nther\n\nleast one Michelle.\n\nThey never spoke\n\ntha\n\nto them.\n\nAnd I\n\nthough that,\n\nat your Honor's ruling now,\n\ncase,\n\nother peopl\n\nI guess,\n\nthink that under your\n\nand you said that some argumen\n\nof the investigation are probative of guilt\n\nyou were\n\nto that Michelle.\n\nt were mentioned;\n\nis an investigative step,\n\nSOUTHERN D\n\nSTR\n\nCT RE\n\n(212)\n\n805-0300\n\nHonor's ruling,\n\nts about the\n\nwas\n\nOne Michelle was\n\nto the government by another witness that worked\n\neven\n\nand\n\ntalking about the Watson\n\nthoroughness\n\nin some\n\nPORTERS, PwC.\n\n2581\n\nfrom\n\nMichelle is.\n\na\n\nSame thing\n\nnever spoke\n\nI'm looking\n\nDOJ-OGR-00014146\n", "char_count": 1757}, {"efta_number": "DOJ-OGR-00014107", "page_number": 40, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 41 of 197 2582\nLCHVMAX2\n\ncircumstances.\n\nIn that case, law enforcement had received a tip that\n\nthe defendant was innocent because another individual shot the\n\nvictim. The Second Circuit stated that cross-examination of\n\nthe lead investigating officer on that tip was probative\n\nbecause the jury could conclude that law enforcement had\n\nprematurely concluded the defendant was the shooter and it\n\nfailed to investigate diligently the possibility that it was\n\nthe other individual. That was the Watson case.\n\nI think we want to make these points, your Honor,\n\nbecause I think the point to the jury is the government\n\ncredited the witnesses, the accusers in this case, without\n\nfollowing up on the information that they provided to see if it\n\nwas wrong. Not following up on that information is probative\n\nof the defendant's guilt or innocence in this case; because had\n\nthey followed up, we believe they would have heard that that\n\nwas not true from these witnesses. And so that goes to the\n\nguilt or innocence of this defendant.\n\nI do intend to get into that on the stand and talk to\n\nthem about, You spoke to Jane on X date. And on that date she\n\ntold you about group sexualized massages involving this person\n\nand that person; isn't that right? Yes. Spoke to her on\n\nanother date; she mentioned a few other names. Spoke to her on\n\na third date; she mentioned names again, and she gave physical\n\ndescriptions of these people. She said certain details about\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014147\n", "char_count": 1700}, {"efta_number": "DOJ-OGR-00014107", "page_number": 41, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX2\n\nthese people which I\n\nDocument 763\n\nwill elicit.\n\nYou were\n\nYou were aware, fo\nto have to use her\n\nissue,\n\nworked in the offi\n\naware of\n\nr example, of\n\nFiled 08/10/22\n\nsomeone named Michelle\n\nPage 42 of 197\n\nin this case.\n\nthis Michelle -- and\n\nfull name,\n\nbecause w\n\nCe»\n\nI would like to be able to do\n\nyou? So\nHonor's ruling,\ncase.\nTHE COURT:\nMR. ROHRB\n\n[ believe,\nMr. Rohrbach.\nACH: Your Honor,\n\nYou never spoke\n\nthat's appropriat\n\nthat.\n\nto Michelle Healy,\n\nI'm going\n\nlost the anonymity\n\nbut you're aware that there was a Michelle Healy who\n\ndid\n\nUnder your\n\nunder the Watson\n\n[ disagree with almost\n\nevery premise of w\n\nhat Mr. Everdell\n\njust said.\n\nBut the core\n\nlegal issue is one the Court has already analyzed which is the\n\nWatson case is a Brady case.\n\nthe Second Circuit\n\nevidence can andc\n\nthe challenges of\n\ncome in in lots of\n\ndefense counsel could and did ask Jan\n\nwas in the room during the massages.\n\nof witnesses who t\n\nagent and say, You\n\ndidn't take that i\n\nchallenge to the t\n\nSOU\n\nhas held,\n\nan't come in.\n\nthe thoroughness of\n\nways,\n\nIt doesn't\n\nabout exact\n\nThe Co\n\nstand\n\nincluding cross-examination.\n\nhey believ\n\nth\n\nwhen sh\n\nfor anything,\n\ntly what sorts of\n\nas\n\nurt has explained that\n\nthe investigation can\n\nThe\n\ntestified who\n\nThey can put on evidence\n\nin the room.\n\nar\n\ndidn't\n\nnvestigative step.\n\ntake this invest\n\nBut what they can't do is in their direct case,\n\nother peopl\n\ntLigative step;\n\ncall a case\n\nyou\n\nThat is precisely the\n\nhoroughness of the investigation that's\n\nTHERN D\n\nSTR\n\nCT RE\n\nPORTERS, P.\n\n(212)\n\n805-\n\n0300\n\n2583\n\nDOJ-OGR-00014148\n", "char_count": 1734}, {"efta_number": "DOJ-OGR-00014107", "page_number": 42, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 45 of 197 LCHVMAX2 information, you got her account, and then you amended the indictment and added her allegations at that point. And those refer to the last two counts in the indictment. MR. ROHRBACH: Your Honor, this is another issue the Court has already ruled on. This is evidence and testimony about the path of the investigation, the government's charging decisions along the way. THE COURT: Could you pull up the mic. MR. ROHRBACH: This is proposed testimony about the government's charging decisions and the path of the investigation along the way, including when the defendant was a target for certain pieces of the investigation and certain counts of the indictment. I think the Court relied on Saldarriaga again and the Duncan opinion when it, in its pretrial rulings, excluded these lines of testimony. And in any event, I understand that Mr. Everdell wants to make this argument to the jury. This is an argument they can make in closing to the jury; but it's not something that they can elicit as evidence from the government's case agent. MR. EVERDELL: Your Honor, I don't know how I can make that argument to the jury when there are no facts about when they spoke to these witnesses. THE COURT: To what investigative steps they took. MR. EVERDELL: When they spoke to the witnesses, if ``` | OBJECTS: The image contains text, but no physical objects are present. | SETTING: The setting appears to be a courtroom or legal proceeding, as indicated by the presence of a judge, attorneys, and legal terminology. | ACTIVITY: The activity depicted is a legal discussion or argument, likely related to a court case involving an indictment and evidence. | NOTABLE: The text suggests a complex legal debate, with references to pretrial rulings, evidence exclusion, and arguments to be made to the jury.", "char_count": 1936}, {"efta_number": "DOJ-OGR-00014107", "page_number": 43, "text_content": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 44 of 197 2585\nLCHVMAX2\n\n1 if this was now appropriate line of cross.\n\n2 THE COURT: No.\n\n3 MR. EVERDELL: Understood, your Honor. Okay.\n\n4 Then there are two other issues then. I did want to\n\nby get into this with this witness, that the investigation of the\n6 allegations against Ms. Maxwell started with the first three of\n7 the accusers, and that time period was focused, so that's Jane,\n8 Annie Farmer, and Kate. And that time period was focused on\n\n9 \"94 to '97. And then they got an indictment based on those\n\n10 charges. And then later, they talked to Carolyn and they\n\n11 amended the indictment, and those allegations relate to a later\n12 time period, 2001 to 2004, and that those are the subject of\n\n13 the last two counts in the indictment, Counts Five and Six.\n\n14 The purpose of this, your Honor, is just to be able to\n15 show the jury that there ar there's a difference between\n\n16 those counts and who the witnesses are, information whose\n\n17 evidence is related to those counts. And I think that's\n\n18 relevant to be able to explain that to the jury without\n\n19 getting -- it doesn't really talk about investigative steps;\n20 it's just simply saying, You talked to Carolyn after you spoke\n21 to these three first. These are the thr who you originally\n22 had evidence from against Ms. Maxwell. Carolyn came to you\n23 later. You spoke to her first in 2019; she wanted to talk to\n24 you with a lawyer. You didn't speak to her again until a year\n25 later. At that point you did meet with her. You took her\n\nSOUTH\n\nE RN\n\nD\n\nSTRIC\n\nIT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nDOJ-OGR-00014150\n\n", "char_count": 1647}, {"efta_number": "DOJ-OGR-00014107", "page_number": 44, "text_content": "ay\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 45 of 197 2586\nLCHVMAX2\n\ninformation, you got her account, and then you amended the\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\nKn\nOY\n\na\n~]\n\nKn\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nindictment and added her allegations at that point. And those\n\nrefer to the last two counts in the indictment.\n\nMR. ROHRBACH: Your Honor, this is another issue the\n\nCourt has already ruled on. This is evidence and testimony\n\nabout the path of the investigation, the government's charging\n\ndecisions along the way.\n\nTHE COURT: Could you pull up the mic.\n\nMR. ROHRBACH: This is proposed testimony about the\n\ngovernment's charging decisions and the path of the\n\ninvestigation along the way, including when the defendant was a\n\ntarget for certain pieces of the investigation and certain\n\ncounts of the indictment.\n\nI think the Court relied on Saldarriaga again and the\n\nDuncan opinion when it, in its pretrial rulings, excluded these\n\nlines of testimony. And in any event, I understand that\n\nMr. Everdell wants to make this argument to the jury. This is\n\nan argument they can make in closing to the jury; but it's not\n\nsomething that they can elicit as evidence from the\n\ngovernment's case agent.\n\nMR. EVERDELL: Your Honor, I don't know how I can make\n\nthat argument to the jury when there are no facts about when\n\nthey spoke to these witnesses.\n\nTHE COURT: To what investigative steps they took.\n\nMR. EVERDELL: When they spoke to the witnesses, if\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014151\n", "char_count": 1571}, {"efta_number": "DOJ-OGR-00014107", "page_number": 45, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX2\n\nyou're going\nstep --\n\nTH\n\nma\n\npretrial. So,\n\nCOURT:\n\nas\n\nto call that,\n\nsaid,\n\nAgain,\n\nDocument 763\n\nground, you can reargue.\n\nBut\n\nthe ground here.\n\nwitnesses to ask who they talked to,\n\nsubpoenaed,\n\ncharges.\n\nWhat\n\nby that ruling or to the extent it's slight]\n\nunclear\n\ninto what\n\nto me what th\n\nand when.\n\nsaid specit\n\nthe government's use or nonuse of\n\ntechniques does not tend to show def\n\nI hear you asking now,\n\nrelevanc\n\njust reading\n\nI'm not aware of\n\nFiled 08/10/22\n\nbroadly speaking,\n\nfFically,\n\nPage 46 of 197\n\nfrom my ruling,\n\n2587\n\nan investigative\n\nit was\n\nif you think things changed on the\n\nanything changing on\n\nCall\n\nF\n\nB\n\nagents as\n\nwhat documents they\n\nBut as the Second Circuit explained in Saldarriaga,\n\nis\n\nj\n\nfendant's innocence of\n\nfF certain investigative\n\nthe\n\nagain,\n\ny di\n\nther precluded\n\nFferent,\n\nMR.\n\nEVERDELL:\n\nWell,\n\nTHE\n\nagent's testimony,\n\nMS. COM\n\nwillingness to st\n\nCOURT:\n\nRY:\nEY:\n\ninconsistent sta\n\ntements.\n\nMR.\n\nEVE\n\nRDELL:\n\nTHE\n\nCOU\n\nSOUTHERN D\n\nRT: Mr.\n\nI've prohibited.\n\nAll right,\n\nYour Honor,\n\n[ will\n\nis and woul\n\nit's\n\nd likely bleed over\n\nyour Honor.\n\nMaybe now you can stipulate\n\nsince this was why you wouldn't.\n\n[ think my cross just got a lot shorter.\n\nto this\n\nreiterate our\n\nThe one other point --\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\ntipulate to this agent's testimony on prior\n\nPagliuca told me yesterday the reason\n\nDOJ-OGR-00014152\n\n", "char_count": 1559}, {"efta_number": "DOJ-OGR-00014107", "page_number": 46, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHVMAX2\n\nto do it with the agent\n\nsaid it with a straight\n\non.\n\nMR.\n\npoint,\n\nto go through with Agen\n\noccurred in Mr.\n\nsince we're goin\n\nDocument 763\n\nwas €\n\nEVERDELL:\n\nYour Honor,\ng through all\nt Young the\n\n\"s residence in 2019.\n\nFficiency,\n\nface,\n\ndevices that were taken\n\nvirtually everything th\n\nEpstein\n\ntf\n\nat was on thos\n\nbut\n\nFiled 08/10/22\n\nwhich I\n\nthis.\n\nPage 47\n\nfact\n\nthe\n\nmaybe not all of it,\n\nmillions of pages,\n\nof\n\nfact that she,\n\nThe number of\n\nI believ\n\nof 197 2588\n\nwould say he\n\ncan't tell with the mask\n\nI would just raise one last\nalso would like\n\nthe search that\n\n, rvreviewed\n\ndevices personally --\n\nbut the vast majority\n\nmillions of\n\nfiles\n\nwe have only\n\nnumber of those for\n\nthe\n\nget out\n\npages -—-\n\nfact tha\n\n; COURT:\n\nMR.\n\nEVERDELL:\n\nwere extracted\n\nwould know at least anecdotally,\n\nall of this.\n\nTH\n\nma\n\nCOURT:\n\nDidn't we hav\n\nMR.\n\nMS. COMEY:\n\nMs.\n\nEVERDELL:\n\nThat was Kimber\n\nthe government\n\nWe had Mr. F\n\nin\n\nf it.\n\nthose documents.\n\nThere were\n\nAnd\n\nhas only presented a certain\n\nBut\n\nthink\n\nthe jury.\n\nt there were mil\n\nfrom the devices\n\nThat's in evidence,\n\nis\n\nTI don't know the number of\n\nin evidence.\n\nthe person?\n\nMenninger on cross-examination of\n\nbecaus\n\nMs.\n\ne\n\nlatley.\n\nly Meder,\n\nlions and millions of\n\nis it not?\n\nJu.\n\n[ need to be able to\n\nles that\n\nbel\n\nieve she\n\nyour Honor.\n\nI think she reviewed\n\nDo you have the witness who extracted?\n\nAnd\n\nMeder did elicit that\n\nSOUTH\n\nE RN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nDOJ-OGR-00014153\n\n", "char_count": 1632}, {"efta_number": "DOJ-OGR-00014107", "page_number": 47, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHVMAX2\n\nthere were thousands of photographs\n\nonly obviously a subset that was pr\n\nMS. MENNINGER: Right. Ms.\nphotographs, your Honor, not to the\nMS. COMEY: Your Honor,\n\nDocument 763 __— Filed 08/10/22\n\nPage 48 of 197 2589\n\nseized, and that there was\nesented to the jury.\n\nMeder only was speaking to\n\nnumber of devices.\n\n[ would note that that was a\n\nSituation where we called a witness\n\nto talk about photographic evidence\n\nthe defense properly cross-examined\n\nevidence.\n\nWhat the defense is now su\n\nto do is bring in a whole host of o\n\nThere was Mr. Flatley, who testifie\n\nI believe what\n\nsingle hard drive.\n\nabout is all of the other devices t\n\nthis\n\nthe course of investigation.\n\nthe Court's orde\n\nbe in violation of\n\naffirmatively in our case\n\nthat was seized; and then\n\nthat witness about that\n\nggesting they should be able\n\nther investigative steps.\n\nd about extraction from a\nMr. Everdell is talking\nhat were seized throughout\n\nAnd I think that that would\n\nr. It would also be\n\nextremely confusing, because when we're talking about this\ninvestigation, it's a little ambiguous what we're talking\nabout, as we alluded to earlier. This investigation was\nbroader than just what resulted in these charges.\n\nMS. MENNINGER: Well, your Honor, there was a search\nthat the government elicited information about that occurred in\n2019 of our alleged co-conspirator's home. The question can be\nphrased because they\n\nTHE COURT: Which witness was that?\n\nSOUTHERN D\n\nSTR\n\nCT RE\n\nPORTERS, PwC.\n\n(212) 805-\n\n0300\n\nDOJ-OGR-00014154\n\n", "char_count": 1664}, {"efta_number": "DOJ-OGR-00014107", "page_number": 48, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763\n\nLCHVMAX2\n\nMS. MENNINGER:\n\nTHE COURT:\n\nMs.\n\non evidence of the search.\n\nMS. MENNINGER:\n\nthink it was\n\nMaguire, Kelly Maguire.\n\nMR. EVERDELL:\n\nMR. EVERDELL:\n\nFiled 08/10/22 Page 49 of 197 2590\n\n—--— which witness what?\n\n[ thought you just said the government put\n\nnot Ms. Meder --\n\nShe was the agent who did the search.\n\nI don't believe\n\nTHE COURT: Why not? I mean,\n\nTHE COURT: Did you cross on devices found?\n\nI did, your Honor.\n\nI'm not trying to probe\n\nstrategy but, like, isn't that precisely --\n\nMS. MENNINGER:\n\nthink Maguire only did certain parts\n\nof the search, in the same way that the\n\nPalm Beach ther\n\nwere only agents that did certain parts of the search. Agent\n\nYoung was in charge of\n\nthe search more broadly.\n\nMS. COMEY: Your Honor, that's\n\nSpecial Agent Maguire\n\nnot accurate.\n\ntestified that she was the\n\nsearch team leader who oversaw th ntire search of that New\n\nYork residence. And this was absolutely an avenue of cross\n\nthat defense could have taken.\n\nWe may have objected, depending\n\non how it was phrased, but we put on the search team leader\n\nfrom that search.\n\nMR. EVERDELL:\n\nMaguire extracted th\n\nFil\n\nBut, your Honor\n\ndevices?\n\n, L don't think Agent\n\ns from the devices.\n\nTHE COURT: Did Agent Young extract the files from the\n\nSOUTHERN\n\nD\n\nSTRICT REPORT\n\nBRS, Pes\n\n(212) 805-0300\n\nDOJ-OGR-00014155\n\n", "char_count": 1483}, {"efta_number": "DOJ-OGR-00014107", "page_number": 49, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 72 of 197 LCHVMAX2 Young - direct 1 A. I just want to make sure I'm in the right spot. Are you referring to \"In the beginning\"? 2 Q. That's correct. Just that sentence. 3 A. Okay. \"In the beginning, Kate would be with her mother and brothers at Epstein's house.\" 6 (Continued on next page) ``` | OBJECTS: The image contains text and a page number (Page 72 of 197), but there are no other objects visible. | SETTING: The setting appears to be a legal document or court transcript, indicated by the case number, document number, and page number. | ACTIVITY: The activity depicted is a legal proceeding or deposition, as indicated by the use of terms like \"Case,\" \"Document,\" and \"Page.\" | NOTABLE: The text refers to a legal context involving a person named Kate and mentions Epstein, which could be significant in a legal or investigative context.", "char_count": 975}, {"efta_number": "DOJ-OGR-00014107", "page_number": 50, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` LCHCmax3 Young - direct 1 Q. If I could have you turn to page 5, and the last full 2 paragraph on that page, I'm going to read this, the first 3 couple sentences here and just let me know if I read anything 4 wrong. I'll substitute the name Jane again. Okay? 5 A. Okay. 6 Q. When Jane was asked if there were times where it was only 7 Epstein, Maxwell, and her in the room, Jane was not sure. As 8 Epstein progressed incidents sexually with Jane, it would go 9 back and forth between just being solely with Jane and going 10 back to the group setting. 11 Did I read that right? 12 A. Yes. 13 Q. And now I want to turn to page 7 of that same document. 14 Are you there? 15 A. Yes. 16 Q. And the last full paragraph, I'm going to just read one 17 sentence that begins on the fourth line of that paragraph. 18 This relates to the New Mexico trip. She, Jane, did not recall 19 specific abuse that may have occurred. 20 Do you see that? 21 A. Yes. 22 Q. And then just a few lines later, there is a separate 23 notation and it carries onto the next page. I'm going to read 24 that. Jane was asked if she recalled any specific abuse that 25 occurred in New Mexico and she stated that she was not sure. ``` | OBJECTS: The image contains text from a legal document, but no physical objects are present. | SETTING: The setting is an indoor environment, likely a courtroom or legal proceeding, given the nature of the text and the formal tone of the conversation. | ACTIVITY: The activity depicted is a legal deposition or questioning, where a witness is being asked to confirm statements made in a document. | NOTABLE: The text refers to a New Mexico trip and mentions Jane, who seems to be the subject of the questioning. The conversation is focused on recalling specific incidents and abuse.", "char_count": 1856}, {"efta_number": "DOJ-OGR-00014107", "page_number": 51, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` LCHCmax3 Young - direct 1 Did I read that accurately? A. Yes. 3 And then on that same page, 8, in the fourth full paragraph, the second sentence reads: Her first trip to New York was to just go and have fun. Did I read that correctly? A. Yes. 8 And I think there is one more on page 12 of this document. If I could direct your attention to the fourth full paragraph, the last three sentences of that paragraph. Are you there? A. I'm not sure which paragraph. 12 The fourth full paragraph. So it's the second from the bottom. 14 Thank you. 15 And then the last three lines of that paragraph. From when Jane met Epstein to when she moved to New York, she lived in the same house in Florida. This house was in a gated community called Bear Lakes. It was a three-bedroom house. Did I read that correctly? A. Yes. 21 MS. MENNINGER: And if I could just briefly go back to the Annie Farmer issue. If I could pull up on the screen for the witness and the Court 3514-26. 24 Q. Do you have that in front of you? A. I do. ``` | OBJECTS: - A piece of paper with text printed on it. - A pen or similar writing instrument. - A screen or monitor displaying text. | SETTING: - An indoor setting, likely an office or courtroom environment. - The presence of legal or official documents suggests a formal proceeding or discussion. | ACTIVITY: - A conversation or deposition involving legal or investigative matters, possibly related to a court case or investigation. | NOTABLE: - The text refers to a document with page numbers 8 and 12, indicating a detailed examination of specific paragraphs. - The mention of \"Bear Lakes\" and a three-bedroom house suggests a discussion about a specific location or property. - The reference to \"Annie Farmer\" and \"Court 3514-26\" implies a connection to a legal case or witness testimony.", "char_count": 1880}, {"efta_number": "DOJ-OGR-00014107", "page_number": 52, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 78 of 197 LCHCmax3 Young - cross 1 CROSS-EXAMINATION 2 BY MS. COMEY: 3 Q. Good morning, Agent Young. 4 A. Good morning. 5 Q. Will you please tell the jury what you did before becoming an FBI agent? 6 A. I was a child adolescent forensic interviewer. 7 Q. What is a child adolescent forensic interviewer? 8 A. I was trained in a research-based protocol to conduct interviews of children to gather information when there are allegations of child abuse. 12 MS. MENNINGER: Objection, your Honor. 702. 13 MS. COMEY: I have no intention of eliciting -- 14 MS. MENNINGER: -- and no disclosure and -- 15 THE COURT: I understand, Ms. Menninger. Let me hear from you at the side, please. (Continued on next page) ``` | OBJECTS: The image contains text and a legal document header indicating it is from a court case. | SETTING: The setting appears to be a courtroom or legal proceeding, as indicated by the presence of a legal document and the formal language used. | ACTIVITY: The activity depicted is a legal proceeding, specifically a cross-examination of an FBI agent named Agent Young. The witness is being questioned about their previous role as a child adolescent forensic interviewer. | NOTABLE: The document includes a reference to objection by counsel, indicating that there may be legal arguments or objections being made during the proceeding.", "char_count": 1473}, {"efta_number": "DOJ-OGR-00014107", "page_number": 53, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 79 of 197 LCHCmax3 Young - cross (At the sidebar) THE COURT: Where is this going? MS. COMEY: Your Honor, I believe Agent Young will testify about her experience conducting interviews and her experience and training both before being at the FBI and as an FBI agent in practices of conducting non-suggestive interviews. This is relevant both because the defense asked a number of questions about how they conduct interviews, so it's within the scope of the direct. And also, the defense elicited expert testimony from Dr. Loftus about how suggestive questioning and leading questioning can lead to implanted memories. And the premise, the basis for admitting that opinion in a letter that was submitted to your Honor just this week was that there was going to be a suggestion by the defense that the agents who conducted interviews here conducted them in a leading fashion. So this is responsive directly to the premise of that expert testimony. MS. MENNINGER: We were just precluded from asking any questions about investigative techniques. THE COURT: I mean, you want to open the door on how interviews were conducted of these witnesses, that opens the door. I think it's beyond the scope. MS. MENNINGER: It is beyond the scope, your Honor. MS. COMEY: I apologize, your Honor. I don't understand what your Honor means by open the door. ``` | OBJECTS: The image contains text but no visible objects. | SETTING: The setting appears to be a courtroom or legal proceeding, indicated by the presence of a court document and the use of legal terminology. | ACTIVITY: The activity involves a legal discussion between a lawyer (Ms. Comey) and a judge (The Court), regarding the admissibility of evidence related to interview techniques used by FBI agents. | NOTABLE: The conversation revolves around the relevance and scope of questioning techniques used during interviews, with \n... [truncated, 2253 chars — for the full page use /api/corpus/document/DOJ-OGR-00014107/53 or ?id=DOJ-OGR-00014107&page=53]", "char_count": 2253}, {"efta_number": "DOJ-OGR-00014107", "page_number": 54, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 81 of 197 LCHCmax3 Young - cross (In open court) MS. MENNINGER: Your Honor, can we strike the answer? THE COURT: Jury will disregard the answer regarding the agent's training in conducting interviews with children to gather information. MS. COMEY: I'll move on, your Honor. THE COURT: Thank you. BY MS. COMEY: Q. Agent Young, did you participate in all of Jane's interviews with law enforcement? A. Yes, I did. Q. During those interviews, was Jane able to talk about everything that happened with Maxwell and Epstein in a single meeting or did she disclose more over time? A. No, she wasn't able to talk about everything in one meeting. It was a process and she disclosed at different points. Q. Did you ever have to stop interviews with Jane when discussing abuse involving Epstein and Maxwell? MS. MENNINGER: Objection, your Honor. Beyond the scope. THE COURT: Sustained. Q. Were you able to cover everything that Jane remembered about Jeffrey Epstein and Ghislaine Maxwell in a single interview? ``` | OBJECTS: The image contains text and a legal document header indicating it is from a court case. | SETTING: The setting appears to be a courtroom, as indicated by the presence of a judge and the formal language used in the text. | ACTIVITY: The activity depicted is a legal proceeding, specifically a court hearing or trial, where attorneys are questioning an individual named Agent Young about Jane's interviews with law enforcement regarding her experiences with Jeffrey Epstein and Ghislaine Maxwell. | NOTABLE: The document includes legal terms such as \"jury will disregard,\" \"objection,\" and \"sustained,\" which are typical in court proceedings. The text also mentions the names of individuals involved in the case, including Jeffrey Epstein and Ghislaine Maxwell.", "char_count": 1902}, {"efta_number": "DOJ-OGR-00014107", "page_number": 55, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 82 of 197 LCHCmax3 Young - cross MS. MENNINGER: Objection. Beyond the scope, your Honor. THE COURT: Sustained. Q. Who was present in the room for interviews with Jane? A. Her attorneys and Assistant United States Attorneys, myself, my partner. In the initial interviews, it was a larger group. Later, in later interviews, we condensed it down to myself and another AUSA. Q. And in your more recent interviews with Jane, who was in the room? MS. MENNINGER: Objection, your Honor. Beyond the scope. I didn't ask about recent ones. THE COURT: Sustained. Q. I think you already addressed this a little bit on direct, but just to be clear, are the reports that were read into the record just now verbatim? A. No. Q. Are they transcripts? A. No. Q. What are they? A. They're a summary of the interview with Jane. Q. Did you ever ask Jane to review your reports to confirm they were accurate? A. No. Q. To your knowledge, was Jane ever shown those reports before ``` | OBJECTS: The image contains text from a legal document, including names, case numbers, and court references. There are no physical objects present in the image. | SETTING: The setting appears to be a courtroom or legal proceeding, as indicated by the presence of legal terminology and the structure of the document. | ACTIVITY: The activity depicted in the image is a legal proceeding, specifically a court hearing or deposition, where questions and objections are being made regarding the presence of individuals during interviews with Jane and the nature of the reports read into the record. | NOTABLE: The document includes legal terms such as \"Objection,\" \"Beyond the scope,\" \"THE COURT: Sustained,\" and references to Assistant United States Attorneys (AUSA), indicating a formal legal setting. The text also mentions summaries of interviews with Jane, suggesting that the proceedings involve discussions \n... [truncated, 2020 chars — for the full page use /api/corpus/document/DOJ-OGR-00014107/55 or ?id=DOJ-OGR-00014107&page=55]", "char_count": 2020}, {"efta_number": "DOJ-OGR-00014107", "page_number": 56, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 83 of 197 LCHCmax3 Young - cross 1 she testified in court during this trial? 2 A. No, she was not. 3 MS. COMEY: Your Honor, may I have a moment? 4 THE COURT: You may. 5 MS. COMEY: Your Honor, may I confer with defense 6 counsel? 7 THE COURT: You may. 8 MS. COMEY: Your Honor, I think we need to approach. 9 THE COURT: Okay. 10 (Continued on next page) ``` | OBJECTS: - Paper document - Text on the document - Margins indicating the page number and case information | SETTING: - The setting appears to be a courtroom or legal proceeding, indicated by the presence of a judge's name, \"THE COURT,\" and the formal language used in the conversation. | ACTIVITY: - The activity depicted is a legal proceeding, specifically a court hearing or trial. The conversation involves a lawyer named Ms. Comey seeking permission from the judge to confer with defense counsel. | NOTABLE: - The document is part of a legal case, as indicated by the case number and the formal language used in the conversation. - The document is from page 83 of 197, suggesting it is a lengthy legal document or transcript. - The conversation includes references to a witness who did not testify in court during the trial, which could be relevant to the ongoing discussion.", "char_count": 1367}, {"efta_number": "DOJ-OGR-00014107", "page_number": 57, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 84 of 197 LCHCmax3 Young - cross (At the sidebar) MS. COMEY: Your Honor, I'm transitioning entirely away from where we were at the prior sidebar. I was about to switch to eliciting some prior consistent statements of Jane's. I do believe the door has been opened for that, but I understand defense counsel would object as beyond the scope. But for efficiency purposes, I was going to ask her now while she's on the stand about these prior consistent statements. MS. MENNINGER: I mean, your Honor, opening the door to prior consistent statements in this manner will then, on recross, I think open the door to any number of other prior inconsistent statements that your Honor just ruled out, and we had to go through an entire process to get in the very few prior inconsistent statements we did. The government hasn't even told us now which prior consistent statement that they're offering. THE COURT: Rebuttal if it's beyond the scope. So sustained with the opportunity to confer if they want to recall the witness for rebuttal. (Continued on next page) ``` | OBJECTS: - A legal document titled \"Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 84 of 197\" - The text is formatted with paragraphs and citations, indicating a legal proceeding. - The text includes names such as \"LCHCmax3,\" \"Young - cross,\" \"MS. COMEY,\" \"MS. MENNINGER,\" and \"THE COURT.\" | SETTING: - The setting appears to be a courtroom or legal proceeding, indicated by the use of terms like \"Your Honor,\" \"sidebar,\" and \"court.\" - The text is formatted in a way typical of legal transcripts or court proceedings. | ACTIVITY: - The activity involves a legal discussion between attorneys and the judge regarding the admissibility of prior consistent statements during a trial or hearing. | NOTABLE: - The discussion revolves around the admissibility of evidence, specifically prior consistent statem\n... [truncated, 2291 chars — for the full page use /api/corpus/document/DOJ-OGR-00014107/57 or ?id=DOJ-OGR-00014107&page=57]", "char_count": 2291}, {"efta_number": "DOJ-OGR-00014107", "page_number": 58, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 85 of 197 LCHCmax3 Young - redirect (In open court) MS. COMEY: No further questions, your Honor. MS. MENNINGER: Briefly, your Honor. THE COURT: Thank you. REDIRECT EXAMINATION BY MS. MENNINGER: Q. You used these interviews of Jane in the grand jury; correct? A. Not all of them. The interviews prior to the grand jury. Q. Selective ones; right? A. I'm not sure what you're -- Q. You chose which of these statements of Jane to present to the grand jury; correct? MS. COMEY: Objection, your Honor. THE COURT: Sustained. Q. You were just asked on cross examination whether Jane had an opportunity to review these notes before she testified; correct? A. Yes. Q. You could have shown her the notes before she testified; right? A. That's not our practice. We don't -- we don't show witnesses notes taken by law enforcement. Q. You couldn't have done it? A. It's not ethical. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014191 ``` | OBJECTS: - Paper document with text - Legal document header and footer information - Text in various fonts and sizes | SETTING: - Appears to be a legal proceeding, likely a courtroom, given the presence of a judge and the formal language used. | ACTIVITY: - A legal proceeding is taking place, specifically a redirect examination in a court case. The attorneys are questioning a witness named Jane about the use of interviews and notes in the grand jury process. | NOTABLE: - The conversation involves legal terms and practices, indicating a formal and serious legal context. - The mention of \"grand jury\" and \"witnesses notes taken by law enforcement\" suggests that the case may involve criminal proceedings. - The exchange includes objections from one attorney, indicating a point of disagreement or concern during the examination.", "char_count": 1903}, {"efta_number": "DOJ-OGR-00014107", "page_number": 59, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 86 of 197 LCHCmax3 Young - redirect Q. You chose not to review her prior reports with her; correct? A. Again, we don't -- we don't do that. Her memory is her memory and we take the best notes we can, but we don't compare our notes with her. That's not appropriate. Q. You chose not to record the interviews? A. No, we don't record. Q. The FBI protocol provides for you to record interviews; correct? A. No, it doesn't. Q. The FBI protocol provides for custodial situations to be recorded; correct? A. Yes, that's correct. Q. And makes it optional for other situations; correct? A. We don't -- we don't record witness interviews. Q. I'm asking you about FBI protocol. A. Yes, we record individuals who are in custody, but we don't record victim witness interviews unless they're a minor. Q. It's not an option? A. It's not something we do. It's not our practice. Q. Is it an option under the FBI protocols or not? MS. COMEY: Objection, your Honor. THE COURT: Sustained. Q. Are you familiar with the Department of Justice obtaining evidence protocols? ``` | OBJECTS: - A piece of paper with text - A pen (used to write on the paper) - A court document header (Case 1:20-cr-00330-PAE Document 763) | SETTING: - An indoor setting, likely a courtroom or legal proceeding environment - The presence of a court document header suggests a formal legal context | ACTIVITY: - A legal proceeding or deposition, involving questions and answers between a lawyer and a witness or expert. The lawyer is questioning the witness about their practices regarding reviewing prior reports, recording interviews, and following FBI protocols. | NOTABLE: - The use of \"Objection, your Honor\" by MS. COMEY indicates that the conversation is taking place in a courtroom or legal setting. - The term \"custodial situations\" refers to situations where an individual is in custody, which is a common l\n... [truncated, 2199 chars — for the full page use /api/corpus/document/DOJ-OGR-00014107/59 or ?id=DOJ-OGR-00014107&page=59]", "char_count": 2199}, {"efta_number": "DOJ-OGR-00014107", "page_number": 60, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 87 of 197 LCHCmax3 Young - redirect MS. COMEY: Your Honor, I'm going to object. It's beyond the scope. THE COURT: Overruled. I just want you to use words to be specific about what you're referring to. MS. MENNINGER: I have a document that we have marked for identification as AY-1. I can show it to the government. THE COURT: Please. Q. Are you familiar with the Department of Justice protocols on electronic recording of statements? MS. COMEY: Your Honor, I'm going to object. Beyond the scope. And I'd want to be heard if there is going to be further questions. (Continued on next page) ``` | OBJECTS: The image contains text and a legal document reference. | SETTING: The setting appears to be a courtroom or legal proceeding, indicated by the presence of a judge and the formal language used. | ACTIVITY: The activity involves a legal proceeding where a witness is being questioned, and objections are being raised by attorneys. | NOTABLE: The document is from a case filed on August 10, 2022, and is page 87 of 197 pages. The text indicates a discussion about Department of Justice protocols related to electronic recording of statements.", "char_count": 1272}, {"efta_number": "DOJ-OGR-00014107", "page_number": 61, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` LCHCmax3 Young - redirect (At the sidebar) MS. COMEY: Your Honor, this is not an FBI protocol. I think all of the predicate questions leading up to this document was about FBI protocols. This is a Department of Justice protocol that references the United States Marshal Service. So I would object to further questioning or reading from this. MS. MENNINGER: It talks about the policy applicable to FBI agents in the very first sentence. MR. EVERDELL: Your Honor, this is from the Justice -- THE COURT: Just a second. MR. EVERDELL: I'm sorry, your Honor. MS. COMEY: Your Honor, I would also note that I believe I have walked away from opening the door on interrogating the methods used to conduct -- THE COURT: You asked if it was recorded. I mean -- MS. COMEY: That is true, your Honor. THE COURT: I think it's the only reason it is within the scope. MS. COMEY: Your Honor, I did not ask if it was recorded. I believe Ms. Menninger asked if it was. I asked if it was a transcript. THE COURT: Let me check. The question on cross was, are they transcripts, are they verbatim. Not about recording. MS. MENNINGER: Right. But the recording would give ``` | OBJECTS: - A piece of paper with text - A sidebar (a small area on the left side of the document) - A court setting with a judge and attorneys | SETTING: - An indoor setting, likely a courtroom, given the presence of a judge and attorneys. - The setting includes a piece of paper with text, which appears to be part of a legal document or transcript. | ACTIVITY: - The activity appears to be a legal proceeding, possibly a trial or hearing, where attorneys are discussing a document related to FBI protocols and the Department of Justice. | NOTABLE: - The discussion involves a document that is not an FBI protocol but rather a Department of Justice protocol referencing the United States Marshal Service. - There is a mention of recording and transcripts, indicating that the\n... [truncated, 2146 chars — for the full page use /api/corpus/document/DOJ-OGR-00014107/61 or ?id=DOJ-OGR-00014107&page=61]", "char_count": 2146}, {"efta_number": "DOJ-OGR-00014107", "page_number": 62, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 89 of 197 LCHCmax3 Young - redirect us a transcript. MS. COMEY: Not necessarily, your Honor. We're not being recorded right now and we're getting a transcript. THE COURT: I'm going to sustain. Beyond the scope. (Continued on next page) ``` | OBJECTS: The image contains text and a page number (Page 89 of 197), but no other objects are visible. | SETTING: The setting appears to be a legal proceeding, likely a courtroom, given the presence of a judge's name (THE COURT) and the formal language used. | ACTIVITY: The activity depicted is a legal hearing or trial, with a discussion about obtaining a transcript and a ruling from the judge. | NOTABLE: The document is part of a legal case, specifically Case 1:20-cr-00330-PAE, and is related to a motion or argument regarding a transcript. The judge has sustained the motion, indicating that the request for a transcript is within the court's jurisdiction.", "char_count": 1034}, {"efta_number": "DOJ-OGR-00014107", "page_number": 63, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 90 of 197 LCHCmax3 Young - redirect (In open court) Q. Are you aware of any witnesses in this case who were recorded during their interviews? MS. COMEY: Objection, your Honor. THE COURT: Sustained. MS. MENNINGER: No further questions, thank you. MS. COMEY: Nothing, your Honor. THE COURT: Agent Young, you may step down. You are excused. Thank you. (Witness excused) Mr. Pagliuca, defense may call its next witness. MR. PAGLIUCA: Thank you, your Honor. Our next witness is Dr. Eva Dubin. THE COURT: Eva Dubin may come forward. EVA ADNERSSON DUBIN, called as a witness by the Defendant, having been duly sworn, testified as follows: Please be seated. Once you're seated, please remove your mask. And if you could speak directly into the microphone and state and spell your name for the record, please. THE WITNESS: My name is Eva Andersson. I also go by Eva Andersson Dubin. THE COURT: Could you spell your name, please. THE WITNESS: E-v-a A-n-d-e-r-s-s-o-n. THE COURT: And Dubin is spelled D-u-b-i-n? ``` | OBJECTS: - Paper document with text - Microphone - Witness stand - Courtroom setting | SETTING: - Courtroom - Open court session - Legal proceeding | ACTIVITY: - Legal proceeding in a courtroom - Witness being sworn in - Questions being asked to the witness - Objections raised by attorneys - Witness excused from testifying | NOTABLE: - The document is a legal transcript from a court case, specifically Case 1:20-cr-00330-PAE. - The witness being called is Dr. Eva Dubin. - The witness is required to remove their mask and state their name for the record. - The court is asking the witness to spell their name clearly.", "char_count": 1756}, {"efta_number": "DOJ-OGR-00014107", "page_number": 64, "text_content": "[VISION] | PEOPLE: - The witness is described as \"Dr. Dubin\" and is referred to as \"Mr. Dubin\" by the lawyer. - The lawyer is identified as \"Mr. Pagliuca.\" - The judge is referred to as \"your Honor.\" | TEXT: ``` THE WITNESS: Right. THE COURT: You may inquire, Mr. Pagliuca. MR. PAGLIUCA: Thank you, your Honor. DIRECT EXAMINATION BY MR. PAGLIUCA: Q. Good morning. Is it Dr. Dubin? A. Yes. Q. Dr. Dubin, where do you live, not the address, but just generally. A. I live in New York City. Q. Thank you. And how old are you, Dr. Dubin? A. I'm 60. Q. And I take it you are married by your description of your last name? A. Yes. Q. And what is your husband's name? A. Glenn Dubin. Q. How long have you been married to Glenn Dubin? A. 28 years. Q. And do you and Mr. Dubin have any children? A. Yes, we do. Q. How many children do you have? A. We have three children. Q. What are the ages of your children, starting with the oldest? ``` | OBJECTS: - The text is typed on a white background. - There are no visible objects in the image. | SETTING: - The setting appears to be a courtroom or legal proceeding. - The text indicates that the witness is being examined by a lawyer named Mr. Pagliuca, and the judge is referred to as \"your Honor,\" suggesting a formal legal environment. | ACTIVITY: - The activity depicted is a direct examination of a witness named Dr. Dubin by Mr. Pagliuca. The lawyer is asking questions about the witness's personal information, such as their residence, age, marital status, and family details. | NOTABLE: - The witness is identified as Dr. Dubin, and the lawyer is questioning him about his personal life, including his residence, age, marriage, and children. - The setting is a formal legal proceeding, indicated by the presence of a judge and the use of legal terminology. - The witness's name is repeated multiple times, which could indicate a focus on his identity or role in the case.", "char_count": 1915}, {"efta_number": "DOJ-OGR-00014107", "page_number": 65, "text_content": "[VISION] | PEOPLE: - There are three people mentioned in the conversation. The first person is referred to as \"Dubin,\" and their gender is not specified. The second person is a female who is almost 28 years old. The third person is a male who is almost 26 years old. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 92 of 197 LCHCmax3 Dubin - direct 1. 27, 25, and 20. They are all about to be 21, 26, and 28. 2. I see. They're about to have their next birthdays? 3. Correct. 4. It took a second to process that. I'm not going to ask you their names, but what are their genders, starting with the 25, almost going to be 28? 5. Female. 6. I'm sorry. 27, almost going to be 28. Female. 25, almost going to be 26? 7. Male. 8. And 20, almost going to be 21? 9. Female. 10. So two girls and a boy? 11. Right. 12. What does Mr. Dubin do for employment? 13. He is self-employed. 14. And is he in the financial industry? 15. Correct. 16. And are you employed as a medical doctor? 17. I am not. 18. Were you employed as a medical doctor? 19. I was. 20. And when you were employed as a medical doctor, what, generally, did you do? 21. I was an internist. ``` | OBJECTS: - The image contains text from a legal document, specifically a court transcript. | SETTING: - The setting appears to be a courtroom or legal proceeding, as indicated by the formal language and structure of the document. | ACTIVITY: - The activity in the image is a legal deposition or questioning, where one party is asking questions about the ages and genders of three individuals, followed by a discussion about employment and medical profession. | NOTABLE: - The document is from a case filed on August 10, 2022, and it is page 92 of 197 pages.", "char_count": 1727}, {"efta_number": "DOJ-OGR-00014107", "page_number": 66, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document\n\n763\n\nLCHVMAX2\nMS. COMEY: Objection to\nMay I confer, your Honor?\nTHE COURT: Yes.\n\n(Counsel conferred)\n\nMS. COMEY:\n\nWe've conferred, your Honor.\n\nwhen the boots were obtained\n\nFiled 08/10/22\nYoung — direct\n\nfoundation.\n\nObjection withdrawn.\n\nTHE COURT: Okay.\nMS. MENNINGER: Yes.\nBY MS. MENNINGER:\nQ. Are you aware of the tim\nMs. Farmer?\nA. I don't recall the specit\n\nsometime this year.\n\nfic date,\n\nfall,\n\nfF trial\n\nbut\n\ndoes that make --\n\nxact mont\n\nPage 67 of 197\n\nLet me rephrase that.\n\nth.\n\nis\n\nthat\n\nxact time\n\n[ think.\n\nQ. In June of this year,\n\nA. I don't —-— I don't remember th\nQ. Okay. It was earlier than this\nA. That's fair.\n\nQO. So it wasn't in the midst o:!\nthe point that I need to make.\n\nA. I don't —-— I don't remember th\nQ. Okay. I can pull up the report,\nGive me one second.\n\nA. Okay.\n\npreparation,\n\nframe.\n\nI know that it was\n\nfair?\n\n[ guess is\n\nQ. We'll pull that up in just a minute and come back to it.\n\nThank you though.\n\nSOUTHERN D\n\nSTR\n\nCT RE\n\nPORTERS, P.\n\n2608\n\nfrom\n\n(212) 805-0300\n\nDOJ-OGR-00014173\n\n", "char_count": 1174}, {"efta_number": "DOJ-OGR-00014107", "page_number": 67, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 94 of 197 LCHCmax3 Dubin - direct 1 approximately 1990 or 1991, did you and Mr. Epstein remain 2 friends? A. Yes, we did. 4 And after you stopped dating Mr. Epstein, did you have 5 regular contact with Mr. Epstein on a friend basis? A. Yes, we did. 7 Both when you were dating Mr. Epstein and after you were 8 dating Mr. Epstein, did you travel on airplanes, either owned 9 or controlled by Mr. Epstein? A. Yes, I did. 11 Did you sometimes travel with Mr. Epstein himself? A. Yes, and my family. 13 And did you sometimes travel without Mr. Epstein on the 14 plane, but with other people? A. I cannot recall if I traveled without Mr. Epstein on the 16 flight. 17 When you traveled with Mr. Epstein, do you recall traveling 18 with other adults, as well? A. There were other adults, as well. I don't recall -- 20 Sure. And I'm not asking for names. I'm just asking 21 generally, do you recall traveling with Mr. Epstein on his 22 planes with other adults? A. Yes, I did. 24 And I think you said that sometimes you and your family 25 would travel with Mr. Epstein on Mr. Epstein's planes; is that ``` | OBJECTS: The image contains text and a page number (Page 94 of 197), but there are no visible objects such as furniture, vehicles, electronics, bags, or jewelry. | SETTING: The image appears to be a legal document or transcript, likely from a court case or legal proceeding. It is formatted like a standard legal document with numbered lines and a header indicating the case number, document number, and date filed. | ACTIVITY: The activity depicted is a legal deposition or interview, where a witness is being questioned about their relationship with Mr. Epstein and their travels with him. | NOTABLE: The document is from a federal case (indicated by \"U.S. DISTRICT COURT\") and involves a witness named LCHCmax3 who is being questioned about her relationship with and t\n... [truncated, 2120 chars — for the full page use /api/corpus/document/DOJ-OGR-00014107/67 or ?id=DOJ-OGR-00014107&page=67]", "char_count": 2120}, {"efta_number": "DOJ-OGR-00014107", "page_number": 68, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 95 of 197 LCHCmax3 Dubin - direct right? A. That's correct. Q. I take it traveling and being around Mr. Epstein after you stopped dating him -- let me back up. When did you and Mr. Dubin get married? A. We got married at 1994 on my birthday. Q. And after 1994, did you and Mr. Dubin continue to be friendly with Mr. Epstein and travel with Mr. Epstein? A. Yes. Q. After you had children with Mr. Dubin, did Mr. Epstein get to know your children? A. Yes, he did. Q. And were you and Mr. Dubin comfortable with the relationship between Mr. Epstein and your children? A. Yes, we were. Q. Did it appear to you that Mr. Epstein was fond of your children? A. Yes, he was. Q. And did it appear to you that your children were fond of Mr. Epstein? A. Yes, they were. Q. Would you describe the relationship between your children and Mr. Epstein as an uncle-like relationship? A. I would. Q. Did they have a nickname for Mr. Epstein? ``` | OBJECTS: The image contains text from a legal document, but no physical objects are present. | SETTING: The setting is an indoor environment, likely a courtroom or legal office, given the formal nature of the text and the reference to a legal case number and document number. | ACTIVITY: The activity depicted is a legal deposition or interview, where a witness is being questioned about their relationship with Mr. Epstein and their interactions with him. | NOTABLE: The document is from a legal case, specifically Case 1:20-cr-00330-PAE, and it involves a witness named LCHCmax3 who is being questioned by someone referred to as \"Dubin - direct.\" The questions revolve around the witness's relationship with Mr. Epstein, including when they got married, their continued friendship, and the relationship between Mr. Epstein and their children.", "char_count": 1902}, {"efta_number": "DOJ-OGR-00014107", "page_number": 69, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 97 of 197 LCHCmax3 Dubin - direct (At the sidebar) MS. MOE: Thank you. Your Honor, this is an issue I believe we raised in advance of trial about the relevance of asking witnesses about uncharged conduct and whether the defendant or Epstein committed crimes in other instances that are not charged. I think the foundation here is about the entirety of a very broad relationship between, I think, the 1980s and the present, and the question is whether, over several decades, she was aware of any kind of inappropriate conduct with other people. It's extraordinarily broad. And as we briefed in advance of trial, there is no relevance, it's inappropriate to suggest that there are uncharged conduct on other occasions is probative of what happened with the particular individuals at issue in this case. So we think this line of questioning is inappropriate. I would also note, your Honor, as we briefed in advance of this witness's testimony, we don't believe there is a foundation to suggest that this person was in the room with Jane. We think our notes on this are clear, that Jane has expressly said that this person was not involved in sexualized massages. So we think that questions that are designed to impeach and the misimpression that defense counsel has created are inappropriate. And for those reasons, we would object. THE COURT: So the specific objection is to other than ``` | OBJECTS: The image contains text but no visible objects. | SETTING: The setting appears to be a legal proceeding, likely a courtroom or a similar formal environment, given the presence of legal documents and the formal language used. | ACTIVITY: The activity depicted is a legal argument or discussion taking place during a court hearing or trial. A lawyer is addressing the court regarding the relevance of certain evidence and questioning related to uncharged conduct and the inv\n... [truncated, 2476 chars — for the full page use /api/corpus/document/DOJ-OGR-00014107/69 or ?id=DOJ-OGR-00014107&page=69]", "char_count": 2476}, {"efta_number": "DOJ-OGR-00014107", "page_number": 70, "text_content": "=\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nI\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 71 of 197 2612\nLCHVMAX2 Young — direct\n\nA. No, it was actually drafted in October of 2019. The date\nyou're referring to is the date that it was serialized to the\ncase file.\n\nQ. Okay. So it was drafted -- it was typed up on October 3rd,\n\na couple weeks after th\n\nA. Yes.\n\nQ.\n\nA. Correct.\nQ.\n\naccuracy on the document,\n\nA. No, the date o\n\nthe reports.\n\ninterview?\n\nAnd we don't have a notice of\n\nright?\n\nAnd then it was entered into the system in\n\nwhen anyone reviewed it\n\nntry is when our supervisor signs of\n\nDecember?\n\nfor\n\non\n\ncould have you turn on this document to page\n\nFull\n\nparagraph. In\n\nQ. Okay. So if\n2, and direct your attention to the fourth\nthe middle of that paragraph is a sentence\n\nWo W fe\n\napologize.\n\nthat begins with the\nthat sentence.\n\nt to use the last name.\n\nNot to\n\n\"Jane\"\n\nfor her\n\nI don't see where\n\nPG ew\n\nword \"in. could have you read\nTHE COURT: caution you no\nMS. MENNINGER: Yes, your Honor.\nuse the witness's last name, but to substitute\nname.\nMS. COMEY: Sorry, your Honor.\nwe're being referred to.\nMS. MENNINGER: On page 2 of O01 in the\nparagraph, in the middle of the paragraph.\nMS. COMEY: Got it. Thank you.\nSOUTHERN DISTRICT REPORTERS,\n(212) 805-0300\n\nFull\n\nFourth\n\nDOJ-OGR-00014177\n\n", "char_count": 1385}, {"efta_number": "DOJ-OGR-00014107", "page_number": 71, "text_content": "=\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\na\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX2\n\nae\n\nAre you rei\n\nQO. That's correct.\n\nA. Okay. \"I\n\nbrothers at\n\nn\n\nEps\n\nDocument 763\nYoung -— direct\n\nJust that sen\n\njust want to make sure\n\nthe beginning,\n\ntein's house.\"\n\ncence.\n\nFiled 08/10/22\n\nI'm in the right spot.\n\nferring to \"In the beginning\"?\n\nPage 72 of 197 2613\n\nKate would be with her mother and\n\n(Continued on next page)\n\nSOUTH\n\nPRN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nLD\n\nDOJ-OGR-00014178\n\n", "char_count": 557}, {"efta_number": "DOJ-OGR-00014107", "page_number": 72, "text_content": "[VISION] | PEOPLE: - A person named LCHCmax3 is mentioned. - Another person named Dubin is mentioned. - A person named Mr. Pagliuca is mentioned. - A person named Ms. Moe is mentioned. - A person named Ms. Lundberg is mentioned. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 100 of 197 LCHCmax3 Dubin - direct (In open court) THE COURT: Go ahead, Mr. Pagliuca. MR. PAGLIUCA: Thank you, your Honor. BY MR. PAGLIUCA: Q. Dr. Dubin, so after you stopped dating Mr. Epstein, and let's focus on roughly 1994 through, let's say, 2004, did you observe any inappropriate conduct between Mr. Epstein and any teenage females? A. I did not. MR. PAGLIUCA: I'd like to show you some pictures that have been admitted under seal. So we just need to show those to the witness, the Court, and I will tell the government which exhibits those are. I'm happy to show them to the government. MS. MOE: Thank you, your Honor. I have those. THE COURT: Can you give the trial mark and yes, for the Court and the witness. MR. PAGLIUCA: Yes, your Honor. So the first exhibit is Government Exhibit 241, which I believe has been admitted under seal previously. MS. MOE: That's correct, your Honor. THE COURT: Okay. Thank you. MR. PAGLIUCA: So this will be for the Court and the witness. And do we have that up, your Honor? THE COURT: We do. MR. PAGLIUCA: If I could ask Ms. Lundberg to expand ``` | OBJECTS: - Paper document with text. - Legal documents and exhibits. - Courtroom setting. | SETTING: - A courtroom with a judge, attorneys, and witnesses present. - The setting appears formal and official, typical of a legal proceeding. | ACTIVITY: - A legal proceeding is taking place, with questions being asked and exhibits being discussed. - The judge is addressing the attorneys and the witness. - The attorney is showing exhibits to the witness and the court. | NOTABLE: - The discussion involves a witness named Dr. Dubin and references to a person named Mr. Epstein. - The exhibits mentioned are under\n... [truncated, 2148 chars — for the full page use /api/corpus/document/DOJ-OGR-00014107/72 or ?id=DOJ-OGR-00014107&page=72]", "char_count": 2148}, {"efta_number": "DOJ-OGR-00014107", "page_number": 73, "text_content": "[VISION] | PEOPLE: - The photograph shows two people. One person is closer to the foreground and appears to be an adult male with short hair. The other person is further back and appears to be a child, possibly a young boy or girl, with short hair. | TEXT: - \"Government Exhibit 241, the photograph that is closest to the foreground in the picture.\" - \"BY MR. PAGLIUCA:\" - \"Q. Do you see that, Dr. Dubin?\" - \"A. I do.\" - \"Q. Do you recognize anyone in that expanded part of exhibit 241?\" - \"MS. MOE: I'm sorry, your Honor, the question is without saying that person's name. I just wanted to make sure that was clear.\" - \"Q. The question was very simple. Do you recognize anyone?\" - \"Q. Okay. Do you recognize one or two people in that photograph?\" - \"A. Two people.\" - \"Q. And without saying -- well, is one of the people Mr. Epstein?\" - \"A. That's correct.\" - \"Q. And without saying the name of the other person, is the other person one of your children?\" - \"A. Yes.\" - \"Q. Okay. And in terms of the age range, do you recall whether this is your now 27, 25, or 20?\" - \"A. The 20.\" - \"Q. I'm assuming you were aware that Mr. Epstein had this\" | OBJECTS: - A photograph - A piece of paper with handwritten text | SETTING: - An indoor setting, likely a courtroom or legal proceeding, given the presence of a judge and the formal questioning format. | ACTIVITY: - A legal proceeding, specifically a court hearing or deposition, where a witness is being questioned about a photograph. | NOTABLE: - The photograph is being used as evidence in a legal case. - The witness is identifying individuals in the photograph, including someone named Mr. Epstein. - The witness is also asked about the age of the individuals in the photograph. (1 repetitive lines removed)", "char_count": 1757}, {"efta_number": "DOJ-OGR-00014107", "page_number": 74, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763\n\nFiled 08/10/22\n\nPage 75 of 197 2616\n\nLCHCmax3 Young -— direct\ner E could have you turn to page 5, and the last full\nparagraph on that page, I'm going to read this, the first\n\ncouple sentences here and just let me know\nwrong. I'll substitute the name Jane again.\nA. Okay.\n\nthere wer\n\ntimes wher\n\nif I read anything\n\nOkay?\n\nQO. When Jane was asked if\n\nEpstein, Maxwell, and her in the room,\n\nEpstein progressed incidents sexually with\n\nback and\n\nback to the group setting.\n\nJane was not\n\nit was only\n\nsure. As\n\nJane, it would go\n\nforth between just being solely with Jane and going\n\nthat same document.\n\nto just read one\n\nDid I read that right?\nAy. YSS.\nQ. And now I want to turn to page 7 of\nAre you there?\nA. Yes.\nQ. And the last full paragraph, I'm going\nsentence that begins on the fourth line of\nThis relates to the New Mexico trip. She,\nspecific abuse that may have occurred.\n\nDo you see that?\nA. Yes.\nQ. And then just a few lines later, there\n\nnotation and it carries onto the next page.\n\nthat.\n\nJane was asked if\n\noccurred in New Mexico and she stated that\n\nthat paragraph.\n\nJane, did not recall\n\nis a separate\n\nI'm going to read\n\nshe recalled any specific abuse that\n\nshe was not sure.\n\nSOUTHERN D\n\nSTRICT REPORTERS,\n(212) 805-0300\n\nPG ew\n\nDOJ-OGR-00014181\n\n", "char_count": 1417}, {"efta_number": "DOJ-OGR-00014107", "page_number": 75, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 76 of 197 2617\nLCHCmax3 Young -— direct\n\nDid I read that accurately?\n\nA. Yes.\n\nQ. And then on that same page, 8, in the fourth full\n\nparagraph, the second sentence reads: Her first trip to New\n\nYork was to just go and have fun.\n\nDid I read that correctly?\n\nAvs Yes.\n\nQ. And I think there is one more on page 12 of this document.\n\n£ could direct your attention to the fourth full paragraph,\nthe last thr sentences of that paragraph. Are you there?\nA. I'm not sure which paragraph.\nQ. The fourth full paragraph. So it's the second from the\nbottom.\n\nA. Thank you.\n\nQ. And then the last three lines of that paragraph. From when\n\nJane met Epstein to when she moved to New York, she lived in\n\nthe same house in Florida. This house was in a gated community\n\ncalled Bear Lakes. It was a three-bedroom house.\n\nDid I read that correctly?\n\nA. Yes.\n\nMS. MENNINGER: And if I could just briefly go back to\n\nthe Annie Farmer issue. f could pull up on the screen for\n\nthe witness and the Court 3514-26.\n\nQ. Do you have that in front of you?\n\nA. I do.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014182\n", "char_count": 1278}, {"efta_number": "DOJ-OGR-00014107", "page_number": 76, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 104 of 197 LCHCmax3 Dubin - direct ever seen any documents that are supposed to be flight records of Mr. Epstein's plane flights? A. I have, yes. Q. And do you recall seeing those records in media publications? A. Yes. Q. And when you saw those records in the media publications, did you believe whatever you saw in the media to be accurate or inaccurate? MS. MOE: Objection, your Honor. Can we be more specific? THE COURT: Please. Q. Did you read whatever you saw in the media that purported to be the flight records? MS. MOE: Same objection, your Honor. MR. PAGLIUCA: I'm not sure what the objection is, your Honor. THE COURT: The flight records you're referring to, what exactly, timeframe, quantity? MR. PAGLIUCA: I think it's -- THE COURT: If you could add specificity, then we'll see from there. BY MR. PAGLIUCA: Q. Do you recall what you saw in the media when you looked at what looked like flight records in the media? ``` | OBJECTS: - A legal document with case information and page numbers - A court proceeding with questions and objections - A reference to Mr. Epstein's plane flights - A mention of media publications and flight records | SETTING: - A courtroom setting with a judge, lawyer, and witness - The document is from a legal case, specifically Case 1:20-cr-00330-PAE - The date of filing is 08/10/22, and the page number is 104 out of 197 | ACTIVITY: - A legal proceeding where a witness is being questioned about documents related to Mr. Epstein's plane flights - The lawyer is objecting to the line of questioning - The judge is asking for more specificity regarding the flight records | NOTABLE: - The reference to Mr. Epstein suggests that the case may involve him or his activities - The document is from a federal court case, as indicated by the \"Southern District\" reference - The presence of a direct examination label indicates that this is\n... [truncated, 2036 chars — for the full page use /api/corpus/document/DOJ-OGR-00014107/76 or ?id=DOJ-OGR-00014107&page=76]", "char_count": 2036}, {"efta_number": "DOJ-OGR-00014107", "page_number": 77, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\nKn\nOY\n\na\n~]\n\nKn\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCma\n\nx3\n\nCROSS—\n\nBY MS.\n\nen Go\n\nA. Go\n\nbE XAMINATION\n\nCOMEY :\n\nDocument 763 Filed 08/10/22 Page 78 of 197 2619\n\nYoung —- cross\n\nod morning, Agent Young.\n\nod morning.\n\nQ. Will you please tell the jury what you did before becoming\n\nan FBI agent?\n\nA. Iwas a child adolescent forensic interviewer.\n\nQ. What is a child adolescent forensic interviewer?\n\nA. Iwas trained in a research-based protocol to conduct\n\ninterviews of children to gather information when there ar\n\nallega\n\nfrom y\n\ntions of child abuse.\n\nMS. MENNING\n\nBR:\n\nObjection, your Honor. 702.\n\nMS. COMEY: have no intention of eliciting --\n\nMS. MENNINGER: -—- and no disclosure and —-\n\nTHE COURT: [ understand, Ms. Menninger. Let me hear\nou at the side, pleas\n\n(Continued on next page)\n\nSOUTH\n\nE RN\n\nDISTRICT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014184\n\n", "char_count": 960}, {"efta_number": "DOJ-OGR-00014107", "page_number": 78, "text_content": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 79 of 197 2620\nLCHCmax3 Young — cross\n\n1 (At the sidebar)\n\n2 THE COURT: Where is this going?\n\n3 MS. COMEY: Your Honor, I believe Agent Young will\n\n4 testify about her experience conducting interviews and her\n\n5) experience and training both before being at the FBI and as an\n6 FBI agent in practices of conducting non-suggestive interviews.\n7 This is relevant both because the defense asked a number of\n\n8 questions about how they conduct interviews, so it's within the\n9 scope of the direct. And also, the defens licited expert\n\n10 testimony from Dr. Loftus about how suggestive questioning and\n1] leading questioning can lead to implanted memories. And the\n\n12 premise, the basis for admitting that opinion ina letter that\n13 was submitted to your Honor just this week was that there was\n14 going to be a suggestion by the defense that the agents who\n\n15 conducted interviews here conducted them in a leading fashion.\n16 So this is responsive directly to the premise of that expert\n\n17 testimony.\n\n18 MS. MENNINGER: We were just precluded from asking any\n19 questions about investigative techniques.\n20 THE COURT: [ mean, you want to open the door on how\n21 interviews were conducted of these witnesses, that opens the\n22 door. [ think it's beyond the scope.\n23 MS. MENNINGER: t is beyond the scope, your Honor.\n24 MS. COMEY: apologize, your Honor. I don't\n25 understand what your Honor means by open the door.\n\nSOUTHE\n\nRN D\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014185\n\n", "char_count": 1548}, {"efta_number": "DOJ-OGR-00014107", "page_number": 79, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 107 of 197 LCHCmax3 Dubin - direct mean the flight records that are in evidence? MS. MOE: That's not correct, your Honor. The entirety of the flight records in evidence are not public. That's the exact reason why portions of them are under seal and redacted. So we're not talking about the same flight records. MR. PAGLIUCA: Well, I disagree, but the point is, we had a live witness who reviewed what purported to be in the media her travel with Mr. Epstein. That media exposure has influenced other people and I believe, frankly, influenced other people, relative to my client, putting my client on flights saying my client did things. It is the exposure to this information. This witness, I believe, will testify, and has so indicated to the government, that what she viewed was inaccurate information. That's the import of it. THE COURT: So the theory is media defined broadly, could be a blog, a tweet, contains any inaccurate information, it is relevant to ask this witness as to the accuracy of that? MR. PAGLIUCA: It is inaccurate as to her personally. THE COURT: I understand. But let's say you pull from some blog post, something perhaps inaccurate; relevant to ask this witness? MR. PAGLIUCA: About her and flight records. THE COURT: Whatever it is from whatever source, there is flight records that show she went to the moon, you should ask her about it? ``` | OBJECTS: The image contains text, but no physical objects are visible. | SETTING: The setting appears to be a courtroom or legal proceeding, as indicated by the presence of a judge (referred to as \"your Honor\") and the formal language used in the conversation. | ACTIVITY: The activity depicted is a legal discussion or argument, likely related to a court case involving flight records and media exposure. | NOTABLE: The conversation involves a judge, a lawyer named Mr. Pagliuca, and a witness name\n... [truncated, 2262 chars — for the full page use /api/corpus/document/DOJ-OGR-00014107/79 or ?id=DOJ-OGR-00014107&page=79]", "char_count": 2262}, {"efta_number": "DOJ-OGR-00014107", "page_number": 80, "text_content": "=\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\na\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 81 of 197\n\n2622\n\ncan we strike the answer?\n\nLCHCmax3 Young — cross\n(In open court)\nMS. MENNINGER: Your Honor,\nTHE COURT: Jury will\n\ndisregard the answer regarding\n\nthe agent's training in conducting interviews with children to\n\ngather information.\nMS. COMEY: \"ll move on,\nTHE COURT: Thank you.\n\nBY MS. COMEY:\n\nQ. Agent Young,\n\ninterviews with law ent\n\nA.\n\nYes,\n\nQ. During\n\neverything\n\nmeeting or did she disclose more over\n\nI did.\n\nthose interviews,\n\ndid you participate in all of\n\nForcement ?\n\nwas Jane\n\nthat happened with Maxwell\n\nyour Honor.\n\nand\n\ntime?\n\nJane's\n\nable to talk about\n\nEpstein in a single\n\nA. No, she wasn't able to talk about everything in one\nmeeting. It was a process and she disclosed at different\npoints.\nQ. Did you ever have to stoop interviews with Jane when\ndiscussing abuse involving Epstein and Maxwell?\n\nMS. MENNINGER: Objection, your Honor. Beyond the\nscope.\n\nTHE COURT: Sustained.\n\nQ. Were yo\n\nabout Jef\n\nUl\n\nrey\n\nable to cover everything that Jan\n\ninterview?\n\nSOU\n\nremembered\n\nTH\n\nPRN\n\nD\n\nSTR\n\nCT RE\n\nPORT\n\n(212)\n\n805-0300\n\nEpstein and Ghislaine Maxwell in a single\n\nBRS, Pes\n\nDOJ-OGR-00014187\n\n", "char_count": 1302}, {"efta_number": "DOJ-OGR-00014107", "page_number": 81, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 82 of 197 2623\n\nLCHCmax3 Young — cross\n\nMS. MENNINGER: Objection. Beyond the scope, your\n\nHonor.\n\n25\n\nTHE COURT: Sustained.\n\nQ. Who was present in the room for interviews with Jane?\n\nA. Her attorneys and Assistant United States Attorneys,\n\nmyself, my partner. In the initial interviews, it was a larger\n\ngroup. Later, in later interviews, we condensed it down to\n\nmyself and another AUSA.\nQ. And in your more recent interviews with Jane, who was in\n\nthe room?\n\nMS. MENNINGER: Objection, your Honor. Beyond the\n\nscope. I didn't ask about recent ones.\n\nTHE COURT: Sustained.\n\nQ. I think you already addressed this a little bit on direct,\n\nbut just to be clear, are the reports that were read into the\n\nrecord just now verbatim?\n\nA. No.\n\nQ. Are they transcripts?\n\nA. No.\n\nQ. What are they?\n\nA. They're a summary of the interview with Jane.\n\nQ. Did you ever ask Jane to review your reports to confirm\n\nthey were accurate?\n\na\n\nNo.\n\nQ. To your knowledge, was Jane ever shown those reports before\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014188\n", "char_count": 1235}, {"efta_number": "DOJ-OGR-00014107", "page_number": 82, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\nKn\nOY\n\na\n~]\n\nKn\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax3\n\nshe testi\n\nA. No,\n\ncounsel?\n\nshe was not.\n\nMS. COMEY:\nTHE COURT:\nMS. COMEY:\nTHE COURT:\nMS. COMEY:\nTHE COURT:\n(Contin\n\nSOUTH\n\nDocument 763\n\nYoung — cross\n\nYour Honor, may I\n\nYou may.\n\nYour Honor, may I\n\nYou may.\n\nYour Honor,\n\nOkay.\n\nued on next page)\n\nFiled 08/10/22 Page 83 of 197 2624\n\nFied in court during this trial?\n\nhave a moment?\n\nconfer with defense\n\nI think we need to approach.\n\nE RN\n\nD\n\nSTRICT R\n\nG\n\nPORT\n\nBRS, Pes\n\n(212) 805-0300\n\nDOJ-OGR-00014189\n\n", "char_count": 611}, {"efta_number": "DOJ-OGR-00014107", "page_number": 83, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax3\n\n(At the sidebar)\n\nMS. COMEY: Your Honor,\n\naway from wher\n\nWwW wer\n\nat the prior sidebar.\n\nDocument 763\n\nYoung —- cross\n\nFiled 08/10/22 Page 84 of 197 2625\n\nI'm transitioning entirely\n\n[ was about to\n\nswitch to eliciting some prior consistent statements of Jane's.\n\nunderstand defen\n\nBut for efficien\n\nshe's on the s\n\nMS. M\n\nto prior consistent s\n\ncy purposes,\n\nI do believe the door has been opened\n\nse counsel would objec\n\nENNINGER:\n\nmean,\n\nfor that, but\n\nyour Honor,\n\nt as beyond the scope.\n\nI was going to ask her now while\n\ntand about these prior consistent statements.\n\nopening the door\n\ntLatements in this manner will then, on\n\nrecross, I think open the door to any number of other prior\n\ninconsistent s\nhad to go thro\n\nprior inconsis\n\ntatements that your Honor just ruled out, and we\n\ntent statements we did.\n\nugh an entire process to get in the very few\n\nThe government hasn't\n\neven told us now which prior consistent statement that they're\n\n2)\n\nfFfering.\n\nTHE COURT:\n\nsustained with the opportunity\n\nthe witness for rebuttal.\n\nto confer if\n(Continued on next page)\nSOUTHERN DISTRICT REPORTERS,\n(212) 805-0300\n\nRebuttal if it's beyond the scope. So\n\nthey want to recall\n\nPG ew\n\nDOJ-OGR-00014190\n\n", "char_count": 1353}, {"efta_number": "DOJ-OGR-00014107", "page_number": 84, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763\n\nLCHCmax3\n\n(In open court\n\nMS. COMEY: No\n\n)\n\nYoung -— redirect\n\nurther questions,\n\nMS. MENNINGER:\n\nBriefly,\n\nTHE COURT: Th\n\nREDIRECT EXAMINATION\n\nBY MS. MENNINGER:\n\nk you.\n\nFiled 08/10/22\n\nyour Honor.\n\nPage 85 of 197 2626\n\nyour Honor.\n\nQ. You used these interviews of Jane in the grand jury;\n\ncorrect?\n\nA. Not all of them. The interviews prior\n\nQ. Selective ones; right?\n\nA. I'm not sure what you're —-\n\nQO. You chose which of\n\nthe grand jury; correct\n\nMS. COMEY: Objection,\n\nto the grand jury.\n\nthese statements of Jane to present to\n\n?\n\nTHE COURT: Sustained.\n\nyour Honor.\n\nQ. You were just asked on cross examination whether Jane had\nan opportunity to review these notes before she testified;\nCOLrESGE ?\nA. Yes.\nQ. You could have shown her the notes before she testified;\nright?\nA. That's not our practice. We don't -- we don't show\nwitnesses notes taken by law enforcement.\nQ. You couldn't have done it?\nA. It's not ethical.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014191\n\n", "char_count": 1148}, {"efta_number": "DOJ-OGR-00014107", "page_number": 85, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 86 of 197 2627\n\nprior reports with her;\n\nHer memory is her\n\nfor you to record interviews;\n\nSituations to be\n\nfor other situations; correct?\n\nuals who are in custody, but we don't\n\nIt's not our practice.\n\nor not?\n\nJustice obtaining\n\nLCHCmax3 Young - redirect\n\n1 QO. You chose not to review her\n\n2 correct?\n\n3 A. Again, we don't —- we don't do that.\n\n4 memory and we take the best notes we can, but we don't compare\n5 our notes with her. That's not appropriate.\n\n6 Q. You chose not to record the interviews?\n\n7 A. No, we don't record.\n\n8 Q. The FBI protocol provides\n\ny) correct?\n10 A. No, it doesn't.\n11 Q: The FBI protocol provides for custodial\n12 recorded; correct?\n\n13 A. Yes, that's correct.\n\n14 Q. And makes it optional\n\n15 A. We don't -- we don't record witness interviews.\n16 Q. I'm asking you about FBI protocol.\n\n17 A. Yes, we record individ\n\n18 record victim witness interviews unless they're a minor.\n19 Q. It's not an option?\n20 A. [t's not something we do.\n21 Q. Is it an option under the FBI protocols\n\n22 MS. COMEY: Objection, your Honor.\n\n23 THE COURT: Sustained.\n\n24 Q. Are you familiar with the Department of\n\n25 evidence protocols?\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORTERS,\n\n(212)\n\n805-0300\n\nDOJ-OGR-00014192\n\n", "char_count": 1279}, {"efta_number": "DOJ-OGR-00014107", "page_number": 86, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 87 of 197\n\nLCHCmax3 Young - redirect\n1 MS. COMEY: Your Honor, I'm going to object. It's\n2 beyond the scope.\n3 THE COURT: Overruled. just want you to use words\n4 to be specific about what you're referring to.\nS MS. MENNINGER: have a document that we have marked\n6 for identification as AY-1. [ can show it to the government.\n7 THE COURT: Please.\n8 Q. Are you familiar with the Department of Justice protocols\n9 on electronic recording of statements?\n10 MS. COMEY: Your Honor, I'm going to object. Beyond\n11 the scope. And I'd want to be heard if there is going to be\n12 further questions.\n13 (Continued on next page)\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n\nSOUTHERN D\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nLD\n\n2628\n\nDOJ-OGR-00014193\n", "char_count": 790}, {"efta_number": "DOJ-OGR-00014107", "page_number": 87, "text_content": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 88 of 197\nLCHCmax3 Young - redirect\n1 (At the sidebar)\n2 MS. COMEY: Your Honor, this is not an FBI protocol.\n3 [ think all of the predicate questions leading up to this\n4 document was about FBI protocols. This is a Department of\n5) Justice protocol that references the United States Marshal\n6 Service. So I would object to further questioning or reading\n7 from this.\n8 MS. MENNINGER: t talks about the policy applicable\n9 to FBI agents in the very first sentence.\n10 MR. EVERDELL: Your Honor, this is from the Justice --\n11 THE COURT: Just a second.\n12 MR. EVERDELL: I'm sorry, your Honor.\n13 MS. COMEY: Your Honor, I would also note that\n14 believe I have walked away from opening the door on\n15 interrogating the methods used to conduct --\n16 THE COURT: You asked if it was recorded. I mean —-\n17 MS. COMEY: That is true, your Honor.\n18 THE COURT: [ think it's the only reason it is within\n19 the scope.\n20 MS. COMEY: Your Honor, I did not ask if it was\n21 recorded. I believe Ms. Menninger asked if it was. asked if\n22 it was a transcript.\n23 THE COURT: Let me check. The question on cross was,\n24 are they transcripts, are they verbatim. Not about recording.\n25 MS. MENNINGER: Right. But the recording would give\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212%) 805-0220\n\n2629\n\nDOJ-OGR-00014194\n", "char_count": 1347}, {"efta_number": "DOJ-OGR-00014107", "page_number": 88, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763\n\nLCHCmax3\n\nus a transcript.\n\nMS. COMEY: Not necessarily,\n\nbeing recorded right now and we're ge\n\nTHE COURT: I'm going to sustain.\n\n(Continued on next page)\n\nFiled 08/10/22 Page 89 of 197 2630\nYoung -— redirect\n\nyour Honor. We're not\n\ntting a transcript.\n\nBeyond the scope.\n\nSOUTHERN\n\nD\n\nSTR\n\nCT RE\n\nPORTERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014195\n\n", "char_count": 502}, {"efta_number": "DOJ-OGR-00014107", "page_number": 89, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax3\n\nQ. Are you aware of\n\nDocument 763\n\nYoung -— redirect\n\n(In open court)\n\nFiled 08/10/22\n\nPage 90 of 197 2631\n\nany witnesses in this case who were\n\nNo further questions,\n\nyour Honor.\n\nyour Honor.\n\nrecorded during their interviews?\nMS. COMEY: Objection,\nTHE COURT: Sustained.\nMS. MENNINGER:\nMS. COMEY: Nothing,\nTHE COURT: Agent Young,\nexcused. Thank you.\n\n(Witness excused)\n\nMr. Pagliuca, def\n\nMR. PAGLIUCA:\nwitness is Dr. Eva Dubin.\n\nTHE COURT: Eva\n\nEVA ADNERSSON DUBIN\n\ntd\n\nThank you,\n\ncalled as a witness by the De\n\nhaving been\n\nyour mask.\n\nAnd 11\n\nduly sworn,\n\nPlease be seated.\n\nthank you.\n\nyou may step down. You are\n\nand state and spell your name\n\nTHE\n\nG\n\nWITNESS:\n\nEva Anderss\n\non\n\nDubin.\n\nina\n\nCOURT:\n\n, WLTNESS:\n\nina\n\nCOURT:\n\nCould you spell your name,\n\ntp\nG\nGa\n\nAnd Dubin is spelled D\n\ntesti\n\nfor\n\nMy name is\n\nfense may call\n\nyour\n\nDubin may come\n\nfied as\n\nits next witness.\n\nHonor.\n\nfendant,\n\nEva Andersson.\n\nV-a\n\nA-n-d\n\nOur next\n\nforward.\n\nfollows:\n\nOnce you're seated, please remov\nF you could speak directly into the microphone\n\nthe record, please.\n\nalso go by\n\nplease.\n\nrF-S-S—-O-n.\n\nu-b-i-n?\n\nSOUTH\n\nE RN\n\nD\n\nSTR\n\nCT R\n\nG\n\nPORT\n\nERS,\n\n(212)\n\n805-0300\n\nLD\n\nDOJ-OGR-00014196\n\n", "char_count": 1336}, {"efta_number": "DOJ-OGR-00014107", "page_number": 90, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax3\n\nT\n\nEF WITNESS:\n\nma\n\nM\n\nR. PAGLIUCA:\n\nO\nve)\n\nRCT EXAMINATION\n\nBY MR. PAG\nQO. Good m\nAvs Yes.\n\nQO. Dr. Du\n\ngenerally.\n\nLIUCA:\n\norning. Is i\n\nbin, where do you\n\nDocument 763\n\nRight.\n\nThank you,\n\nt\n\nCOURT: You may inquire,\n\nDr.\n\nA. I live in New York City.\nQ. Thank you. And how old\nA. I'm 60.\n\nQ. And I\n\nlast name?\n\nA. Yes.\n\nDubin - direct\n\nMr.\n\nFiled 08/10/22\n\nDubin?\n\nlive,\n\nare you, Dr.\n\nPage 91 of 197 2632\n\nPagliuca.\n\nyour Honor.\n\nnot the address,\n\nDubin?\n\nbut just\n\ntake it you are married by your description of your\n\nQ. And what is your husband's name?\n\nA. Glenn\n\nQ. How long have you been married to Glenn\n\nA. 28 yea\nQO. And do\n\nA. Yes, w\n\nDubin.\n\nrs.\nyou and Mr.\n\ne do.\n\nQ. How many children do you have?\n\nA. We hav\n\nthr children.\n\nQ. What are the ages of\n\noldest?\n\nyour children,\n\nDubin?\n\nDubin have any children?\n\nstarting with the\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212\n\n) 805-0300\n\nPG ew\n\nDOJ-OGR-00014197\n\n", "char_count": 1068}, {"efta_number": "DOJ-OGR-00014107", "page_number": 91, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 92 of 197 2633\nLCHCmax3 Dubin —- direct\n\nA. 27, 25, and 20. They are all about to be 21, 26, and 28.\n\nQ. I see. They're about to have their next birthdays?\n\nA. Correct.\n\nQ. It took a second to process that. I'm not going to ask you\n\ntheir names, but what are their genders, starting with the 25,\nalmost going to be 28?\n\nA. Female.\n\nQ. I'm sorry. 27, almost going to be 28. Female. 25, almost\n\ngoing to be 26?\n\nA. Male.\n\nQ. And 20, almost going to be 21?\nA. Female.\n\nQ. So two girls and a boy?\n\nA. Right.\n\nQ. What does Mr. Dubin do for employment?\n\nA. He is selfemployed.\n\nQ. And is he in the financial industry?\n\nA. Correct.\n\nQ. And are you employed as a medical doctor?\n\nA. I am not.\n\nQ. Were you employed as a medical doctor?\n\nA. I was.\nQ. And when you were employed as a medical doctor, what,\n\ngenerally, did you do?\n\nA. I was an internist.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014198\n", "char_count": 1084}, {"efta_number": "DOJ-OGR-00014107", "page_number": 92, "text_content": "=\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\na\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHCmax3\n\nDocument 763\nDubin - direct\n\nFiled 08/10/22 Page 93 of 197 2634\n\nQ. And were you or are you licensed to practice medicine in\n\nthe State of New York?\n\nA. am.\nQ. Just briefly, where did you at\nA. attended medical school\n\nStockholm for three and a hal\n\nf years,\n\nttend medical school?\n\nat the Karolinska Institute in\n\nand then UCLA medical\n\nfrom UCLA medical school?\n\na residency for internal medicine?\n\nschool.\n\nQ. And did you graduate\n\nA. Yes, I did.\n\nQ. Did you complet\n\nA. Yes, I did.\n\nQ,\n\nmedicine?\n\nA. In Lennox Hill Hospital.\n\nQO. Here in New York\n\n?\n\nAnd where did you complete your residency for internal\n\nAy. YSS.\nQ. I want to ask you some questions about a man named Jeffrey\nEpstein. Did you know Mr. Epstein?\nA. Yes, I did.\nQ. And how did you know Mr. Epstein?\nA. We dated off and on from the start of 1983.\nQ. So 1983 until approximately when did you date Mr. Epstein\noff and on?\nA. Approximately 1990, 1991.\nQ. Okay. And after you stopped dating Mr. Epstein in\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014199\n\n", "char_count": 1190}, {"efta_number": "DOJ-OGR-00014107", "page_number": 93, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHCmax3\n\napproximately 1990 or 1991,\n\nA.\nQ.\n\nregular contact with Mr. Eps\n\nfriends?\n\nYes, we did.\n\nDocument\n\nAnd after you stopped da\n\n763 ~=Filed 08/10/22 Page 94 of 197 2635\n\nting Mr.\n\nDubin - direct\n\ndid you and Mr. Epstein remain\n\nEpstein, did you have\n\ntein ona\n\nfriend basis?\n\nEpstein and after you were\n\ndid you travel on airplanes, either owned\n\nwith Mr.\n\nEpstein himself?\n\nA. Yes, we did.\n\nQ. Both when you were dating Mr.\ndating Mr. Epstein,\n\nor controlled by Mr. Epstein?\n\nA. Yes, I did.\n\nQ. Did you sometimes travel\n\nA. Yes, and my family.\n\nQ.\n\nplane, but with oth\n\nA.\n\nQ.\n\nAnd did you sometimes travel without Mr. Epstein on the\n\ncannot recall\n\ner people?\n\nflight.\n\nWhen you traveled with Mr.\n\nwith other adults,\n\nas well?\n\nif I traveled without Mr. Epstein on the\n\nEpstein, do you recall traveling\n\nA. There were other adults, as well. I don't recall --\nQ. Sure. And I'm not asking for names. I'm just asking\ngenerally, do you recall traveling with Mr. Epstein on his\n\nplanes with other adults?\n\nA.\n\nQ.\n\nwould travel\n\nYes, I did.\n\nAnd I think you said\n\nwith Mr. Epstein on Mr.\n\nthat sometimes you and your family\n\nEpstein's planes; is that\n\nSOUTHERN DISTRICT REPO\n(212) 805-03\n\nRTERS, P.C.\n\n00\n\nDOJ-OGR-00014200\n\n", "char_count": 1366}, {"efta_number": "DOJ-OGR-00014107", "page_number": 94, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nDocument 763 __— Filed 08/10/22\n\nPage 95 of 197 2636\n\nEpstein\n\nafter you\n\nLCHCmax3 Dubin —- direct\nright?\nA. That's correct.\nQ. I take it traveling and being around Mr.\nstopped dating him -- let me back up.\nWhen did you and Mr. Dubin get married?\nA. We got married at 1994 on my birthday.\nQ. And after 1994, did you and Mr.\n\nfriendly with Mr. Epstein and\n\nae\n\nQ.\n\nYes.\n\nAfter you had children with Mr. Dubin, did Mr.\n\ntravel with Mr.\n\nto know your children?\n\nA,\n\nQ.\n\nYes, he did.\n\nAnd were you and Mr. Dubin comf\n\nrelationship between Mr.\n\nDubin continue to be\n\nEpstein?\n\nEpstein get\n\nFortable with the\n\nEpstein and your children?\n\nA. Yes, we wer\n\nQ. Did it appear to you that Mr. Epstein was fond of your\nchildren?\n\nA. Yes, he was.\n\nQ. And did it appear to you that your children were fond of\nMr. Epstein?\n\nA. Yes, they were.\n\nQ. Would you describe the relationship between your children\nand Mr. Epstein as an uncle-like relationship?\n\nA. I would.\n\nQ. Did they have a nickname for Mr. Epstein?\n\nSOUTHERN DISTR\n\n(212) 805-0300\n\nCT REPORTERS, P.\n\nDOJ-OGR-00014201\n\n", "char_count": 1202}, {"efta_number": "DOJ-OGR-00014107", "page_number": 95, "text_content": "[VISION] | PEOPLE: There are no visible people in the image. | TEXT: ``` Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 123 of 197 LCHVMAX4 Dubin - direct Q. That was going to be my next question. THE COURT: Just to make sure I'm right, this is RR; correct? MR. PAGLIUCA: It is RR, your Honor. THE COURT: Okay. MR. PAGLIUCA: We can take that down. Q. That's all I'm doing with the flight records. I just have a few more questions, Dr. Dubin. THE COURT: Go ahead. Q. Dr. Dubin, during the 1994 to 2004 time frame, were you ever introduced to any other person named Eva who was dating Mr. Epstein? A. Not that I can recall. Q. Were you ever introduced to anyone else named Eva who had a close relationship, to your knowledge, with Mr. Epstein? A. Not that I can recall. Q. Okay. And I need to ask a couple of final questions about the person that we identified in Exhibit 12, the person that we're calling Jane. And I apologize for asking these questions, okay? Have you ever been in a group sexual encounter with the person we are calling Jane? A. Absolutely not. Q. Okay. Have you ever been in a group sexualized massage with Jane? ``` | OBJECTS: The image contains text and a page number (Page 123 of 197), but there are no visible objects such as furniture, vehicles, or bags. | SETTING: The setting appears to be a courtroom or legal proceeding, as indicated by the presence of a court reference (THE COURT) and legal terminology. | ACTIVITY: The activity depicted is a legal proceeding, specifically a deposition or testimony, where a witness (Dr. Dubin) is being questioned by an attorney (Mr. Pagliuca) about his interactions with a person named Eva and another individual named Jane. | NOTABLE: The conversation involves sensitive topics, including sexual encounters and relationships, which suggests the context may be related to a legal case involving privacy or confidentiality.", "char_count": 1897}, {"efta_number": "DOJ-OGR-00014107", "page_number": 96, "text_content": "Case 1:20-cr-00330-PAE\nLCHCmax3\n\nDocument 763 Filed 08/10/22 Page 97 of 197 2638\n\nDubin - direct\n\n1 (At the sidebar)\n\n2 MS. MOE: Thank you. Your Honor, this is an issue\n\n3 believe we raised in advance of trial about the relevance of\n\n4 asking witnesses about uncharged conduct and whether the\n\n5 defendant or Epstein committed crimes in other instances that\n\n6 are not charged. I think the foundation here is about the\n\n7 entirety of a very broad relationship between, I think, the\n\n8 1980s and the present, and the question is whether, over\n\n9 several decades, she was aware of any kind of inappropriate\n\n10 conduct with other people. It's extraordinarily broad. And as\n11 we briefed in advance of trial, there is no relevance, it's\n\n12 inappropriate to suggest that there are uncharged conduct on\n\n13 other occasions is probative of what happened with the\n14 particular individuals at issue in this case. So we think this\n15 line of questioning is inappropriate.\n16 I would also note, your Honor, as we briefed in\n17 advance of this witness's testimony, we don't believe there is\n18 a foundation to suggest that this person was in the room with\n19 Jane. We think our notes on this are clear, that Jane has\n20 expressly said that this person was not involved in sexualized\n21 massages. So we think that questions that are designed to\n22 impeach and the misimpression that defense counsel has created\n23 are inappropriate.\n24 And for those reasons, we would object.\n25 THE COURT: So the specific objection is to other than\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014203\n\n", "char_count": 1593}, {"efta_number": "DOJ-OGR-00014107", "page_number": 97, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-\nLCHCmax3\n\nwhat\n\ntimeframed.\n\nin which the witness testit\n\nmassages with -\n\nMS. MO\n\nindividuals who are at issue in this case.\n\njury whether Maxwell and\n\nother people,\n\nPAE\n\nSo you want th\n\nGI\n\nknowledge about\nthis case. The\n\nnot at issue in\n\nthe question\nmisconduct\n\nabsence of\n\nDocument 763\nDubin - direct\n\nFiled 08/10/22\n\ntim\n\nfram\n\nYes,\n\nTHE\n\nCOURT:\n\nwhich the witness testifies.\n\nMR.\n\nJust so the record is clear,\n\nlitigated at al\n\nPAGLI\n\nUCA:\n\nyour Honor,\n\nmisconduct wit\n\ncan do that,\n\nthis case is not relevant.\n\nthink you should narrow th\n\nyour\n\n[ don'\n\npretrial.\n\nabout Ms. Maxwe\n\npretrial.\n\nll or not being there,\n\nThis really is\n\nfoundational to the n\n\nPage 98 of 197\n\n2639\n\nallowed in overruling your motion to preclude is\nnarrowed to the window\n\nfied that there was sexualized\n\nand limited to particular\n\nIt's not before the\nEpstein committed misconduct with\n\nis whether she has relevant\n\nwith the people who are at issue in\n\nth other people who are\n\nHonor.\n\ntim\n\nin\n\nfram\n\nt believe this was\nThis witness was not questioned\n\nwhich were litigated\n\next quest\n\ntion,\n\nwhich is going to be aft\n\nthen into the relevant t\n\nactivity,\n\nactivity.\n\nOut\n\nrelevant,\n\ne)\n\nthat activity,\n\nr she stopped dating him,\n\nt's act\n\nany of\nSo tha\n£ this into\n\nyour Honor,\n\nthat.\n\nimeframe,\n\nually the nex\n\nBut it seems\n\nfrankly because if\n\ntO me\n\ndid she see any of\n\nt quest\n\nwhich is\n\nthis\n\nfF which she considered to be inappropriate\n\nSO\n\ntion.\n\nto be logically\n\nshe had seen any of\n\nSOUTHERN\n\nDISTR\n\nCT RE\n\nPORTERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nI'm moving\n\nI doubt she would have been dating him or would\n\nDOJ-OGR-00014204\n", "char_count": 1755}, {"efta_number": "DOJ-OGR-00014107", "page_number": 98, "text_content": "=\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nI\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax3\n\nbe on his planes, et cet\n\nknowledge about Mr. Epstein,\n\nduring\n\nMr.\n\nEps\n\nthe relevant timet\n\ncom\n\n25\n\nTHE COURT: You'v\n\nmove on.\n\nMR. PAGLIUCA:\n\nthen move on.\n\nYes,\n\nDocument 763\nDubin - direct\n\nra.\n\nrame,\n\ntein during the relevant time!\n\nSo it is\n\nwhy her children are\n\nFiled 08/10/22\n\nfoundational\n\nabout why she was with\n\nPage 99 of 197 2640\n\nfor her\n\nMr. Epstein\n\nwith\n\nfortable with the children.\n\nalready\n\nSo I think you have\n\nI am.\n\n(Continued on next page)\n\nFrame.\n\nstablished she\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nLD\n\nwas\n\n-—- you'll\n\nTHE COURT: I'll sustain on the current question and\n\nDOJ-OGR-00014205\n\n", "char_count": 781}, {"efta_number": "DOJ-OGR-00014107", "page_number": 99, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax3\n\n(\n\nT\n\nM\n\nIn open court)\n\nH\n\nma\n\nCOURT:\n\nR. PAGLIUCA:\n\nBY MR.\n\nOG; Dr.\n\nlet's\n\nobserve any inappropriate conduct between Mr.\n\nDubin,\n\nPAGLIUCA:\n\nteenage females?\nA. I did not.\nMR. PAGLIUCA: I'd\n\nhave been admitted under seal.\n\nDocument 763\nDubin - direct\n\nGo ahead, Mr.\n\nThank you,\n\nfocus on roughly 1994 through,\n\nto the witness, the Court, an\nexhibits those are.\nMS. MOE: Thank you,\nTHE COURT:\n\nthe Court and the witness.\n\n1s Government\n\nMR.\n\nunder seal\n\nPAGLIUCA:\n\nExhibit 241,\n\nYes,\n\nwh\n\nd Iwill t\n\nFiled 08/10/22\n\nPagliuca.\n\nyour Honor.\n\nso after you stopped dating Mr.\n\nPage 100 of 197\n\nEpstein,\n\nell\n\nyour Honor.\n\nyour Honor\n\nich I\n\nwitness.\n\nMS. MOE: That's correct, your Honor.\nTHE COURT: Okay. Thank you.\nMR. PAGLIUCA: So this will be\n\nAnd do we have that up,\n\nT\n\nM\n\npreviously.\n\n‘ So the\n\nlet's say,\n\nSo we just need to show\n\nthe government\n\nCan you give the trial mark and yes,\n\nyour Honor?\n\nHF COURT: We do.\nR. PAGLIUCA: £ could ask Ms. L\nSOUTHERN DISTRICT REPORTERS,\n(212) 805-0300\n\n2641\n\nand\n\ndid you\n\nEpstein and any\n\nlike to show you some pictures that\n\nthose\n\nwhich\n\nI'm happy to show them to the government.\n\nI have those.\n\nfor\n\nfirst exhibit\n\nbelieve has been admitted\n\nfor the Court and the\n\nundberg to expand\n\nDOJ-OGR-00014206\n\n", "char_count": 1402}, {"efta_number": "DOJ-OGR-00014107", "page_number": 100, "text_content": "be\n\nNO\n\nCase 1:20-cr-00330-PAE\n\nLCHC\n\nGove\n\nfore\n\nmax3\n\nDocument 763\nDubin - direct\n\nrnment Exhibit 241,\n\nFiled 08/10/22 Page 101 of 197 2642\n\nthe photograph that is closest to the\n\nground in the picture.\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nBY M\n\nQ.\nA.\nQ.\n\n241°?\n\nwith\nthat\nQ.\nA.\nQ.\nphot\n\nA.\n\nO\n\nae\n\nQ.\nothe\nA.\nQ,\nthis\nA.\n\nQ.\n\nR. PAGLIUCA:\n\nDo you see that,\n\nI do.\n\nMS. MOE:\n\nDr.\n\n\"m sorry,\n\nDubin?\n\nyour\n\nout saying that person's name.\n\nwas clear.\n\nThe question was very simple.\n\nI do.\n\nOkay. Do you recognize one or\n\nograph?\n\nTwo people.\n\nAnd without saying -- well, is\n\nEpstein?\n\nThat's correct.\n\nAnd without saying the name of\n\nrv person one of your children?\n\nYes.\n\nOkay. And in terms of\n\nis your now 27,\n\n25,\n\nF the age\n\nor 20?\n\nThe 20.\n\nDo you recognize anyone in that expanded part of exhibit\n\nHonor, the question is\n\njust wanted to make sure\n\nDo you recognize anyone?\n\ntwo people in that\n\none of the people\n\nthe other person, is the\n\nrange, do you recall whether\n\nI'm assuming you were aware that Mr. Epstein had this\n\nSOUTH\n\nE RN\n\nD\n\nSTR\n\nCT RE\n\nPORTERS, PwC.\n\n(212)\n\n805-\n\n0300\n\nDOJ-OGR-00014207\n\n", "char_count": 1187}, {"efta_number": "DOJ-OGR-00014107", "page_number": 101, "text_content": "=\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nI\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax3\n\npicture?\n\nA. I hav\n\nDocument 763\nDubin - direct\n\nnever $\n\nMR.\n\nGovernment\n\nand the Cou\n\nPAGLI\n\nExhibit\n\nrt. If\n\ncenter of t\n\nQ. Again,\nphotograph?\nA. Ido.\nQ. And is\nA. Correct\nQ. And is\n\nA. Correct\nQO. And is\n\nin the othe\n\nhat bookcase.\n\none of\n\none of\n\nthat the same child\n\nvr photograph?\n\nDr. Dubin,\n\nUCA:\n\n248,\n\nwe coul\n\nthose people\n\nthos\n\nFiled 08/10/22\n\nn this picture before.\n\np\n\nlease.\n\nEpstein?\n\nA. Different child.\n\nQO. And ord\n\nA. 27.\n\nQ. So this is your oldest child\n\nright?\n\nA. Correct\n\ner age,\n\nwhich child\n\np\n\nopl\n\nor\n\na\n\nPage 102 of 197 2643\n\nIf we could now show the witness\n\nThis is just for\n\nld expand the photograph\n\ndo you recognize two people\n\nthe witness\n\nthat's in the\n\nin that\n\nf your children?\n\ndifferent child that we saw\n\nis\n\nthis?\n\nin this photograph; is that\n\nQ. And do you have any sense of when this photograph might\n\nPG ew\n\nhave been taken?\nA. I have never seen this photo before.\nMR. PAGLIUCA: Then if we can look at Government\nSOUTHERN DISTRICT REPORTERS,\n(212) 805-0300\n\nDOJ-OGR-00014208\n\n", "char_count": 1171}, {"efta_number": "DOJ-OGR-00014107", "page_number": 102, "text_content": "ay\n\nCase 1:20-cr-00330-PAE\nLCHCmax3\n\nExhibit 249, please.\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\nKn\nOY\n\na\n~]\n\nKn\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nDocument 763 ‘Filed 08/10/22 Page 103 of 197 2644\n\nAgain,\n\nDubin - direct\n\nthis is under seal and just for\n\nthe witness.\nQ. I don't know if you need that expanded or not, Dr. Dubin,\nbut we can if you need it expanded.\nTHE COURT: F they can make it a little larger.\nMR. PAGLIUCA: Certainly, your Honor.\nQ. Do you recognize that person, without saying the name,\nDr. Dubin?\nA. I do not.\nMR. PAGLIUCA: Thank you. We can take that down.\nTHE WITNESS: Possible to have some water?\nTHE COURT: Yes. I'm sorry.\nMR. PAGLIUCA: May I approach, your Honor?\nMS. MOE: can do it.\nTHE COURT: Thank you.\nTHE WITNESS: Thank you.\nMR. PAGLIUCA: Let me know when you're ready,\nDr. Dubin.\nTHE WITNESS: I'm ready.\nMR. PAGLIUCA: Thank you.\nBY MR. PAGLIUCA:\nQ. Dr. Dubin, earlier we discussed traveling on Mr. Epstein's\nairplanes. I want to talk about some, what have been admitted\nas flight records with you.\n\nFirst of al\n\nl,\n\nprior to coming to co\n\nSOUTH\n\nE RN\n\nD\n\nSTR\n\nCT REPORTERS, P.C.\n\n(212)\n\n805-0300\n\nurt today, have you\n\nDOJ-OGR-00014209\n\n", "char_count": 1193}, {"efta_number": "DOJ-OGR-00014107", "page_number": 103, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 _ Filed 08/10/22 Page 104 of 197 2645\nLCHCmax3 Dubin - direct\n\never seen any documents that are supposed to be flight records\n\nof Mr. Epstein's plane flights?\n\nA. I have, yes.\n\nQ. And do you recall seeing those records in media\n\npublications?\n\nA. Yes.\n\nQ. And when you saw those records in the media publications,\ndid you believe whatever you saw in the media to be accurate or\ninaccurate?\n\nMS. MOE:\n\nObjection, your Honor. Can we be more\n\nE\n\nspecific?\n\nTHE COURT: Please.\n\nQ. Did you read whatever you saw in the media that purported\nto be the flight records?\nMS. MOE: Same objection, your Honor.\n\nMR. PAGLIUCA: I'm not sure what the objection is,\n\nyour Honor.\n\nTHE COURT: The flight records you're referring to,\n\nwhat exactly, timeframe, quantity?\n\nMR. PAGLIUCA: I think it's —-\n\nTHE COURT: f you could add specificity, then we'll\n\nsee from there.\n\nBY MR. PAGLIUCA:\n\nQ. Do you recall what you saw in the media when you looked at\n\nwhat looked like flight records in the media?\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014210\n", "char_count": 1203}, {"efta_number": "DOJ-OGR-00014107", "page_number": 104, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 _ Filed 08/10/22 Page 105 of 197 2646\nLCHCmax3 Dubin —- direct\n\nA. I don't really recall exactly what saw. Saw my name\n\nand flights.\n\nQ. Do you recall when you saw these in the media?\n\nA. I can't recall.\n\nQ. When you read what you believed to be flight records in the\n\nmedia,\n\ndid anything strike you as being inaccurate in what was\n\nbeing published\n\nfrom your memory?\n\nMS. MOE: Same objection, your Honor.\nTHE COURT: ‘ll permit response to this question. So\n\nwhen you read what you believed to be\n\nin the\n\nflight records\n\nmedia,\n\ndid anything strike you as being inaccurate?\n\nA. I saw that the media had copied the\n\nflight book\n\nincorrectly.\n\nQ. Okay. What did you believe was incorrect\n\nhad copied incorrectly?\n\nin what the media\n\nMS. MOE: Your Honor, we'd object. There is evidenc\nin the record that he can ask the witness about. I'm not sure\nwhat we're talking about even at this point.\n\nMR. PAGLIUCA: can discuss this at sidebar if you\nwant, your Honor. [ think it's relevant.\n\nTHE COURT: We'll give the jury their morning break\n\nand we'll discuss it.\n\nMembers of the jury,\n\n(Continued on next page)\n\nSOUTHERN D\n\nSTR\n(212)\n\nCT REPORTERS, P.C.\n805-0300\n\nwe'll take a 15-minute break.\n\nDOJ-OGR-00014211\n\n", "char_count": 1364}, {"efta_number": "DOJ-OGR-00014107", "page_number": 105, "text_content": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 106 of 197\nLCHCmax3 Dubin —- direct\n\n1 (Jury not present)\n\n2 THE COURT: You may step down, Dr. Dubin.\n\n3 (Witness excused)\n\n4 Go ahead, Ms. Moe.\n\n5 MS. MOE: Yes, your Honor. Thank you. So as the\n\n6 Court is aware, there are flight records in evidenc We would\n7 certainly have no objection to Mr. Pagliuca asking this witness\n8 whether she recognizes them, whether they're accurate, the\n\n9 like, that is entirely appropriate, but I think it's very\n\n10 confusing to ask about what her memory is of what she saw in\n\n11 the media and whether that's accurate. I think there is no way\n12 for the jury to tell what witness we're talking about, whether\n13 it's the items in evidenc [ think the proper way to do this\n14 is to show the witness the flight records and ask whether\n\n15 they're accurate or not. If we're talking about things that\n\n16 are not in evidence and whether things that are not in evidence\n17 are accurate, I don't s the relevance of it, and that, of\n\n18 course, wouldn't be appropriate.\n\n19 THE COURT: What is the relevance, Mr. Pagliuca?\n20 MR. PAGLIUCA: I think the relevance is patent, your\nal Honor.\n\n22 THE COURT: Perhaps, but not to me.\n\n23 MR. PAGLIUCA: Here's why. These flight records were,\n24 in some fashion, leaked to the media.\n\n25 THE COURT: When you say these flight records, you\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\n2647\n\nDOJ-OGR-00014212\n", "char_count": 1437}, {"efta_number": "DOJ-OGR-00014107", "page_number": 106, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 107 of 197\n\n2648\n\nLCHCmax3 Dubin —- direct\n1 mean the flight records that are in evidence?\n2 MS. MOE: That's not correct, your Honor. The\n3 entirety of the flight records in evidence are not public.\n4 That's the exact reason why portions of them are under seal and\n5 redacted. So we're not talking about the same flight records.\n6 MR. PAGLIUCA: Well, I disagree, but the point is, we\n7 had a live witness who reviewed what purported to be in the\n8 media her travel with Mr. Epstein. That media exposure has\n9 influenced other people and I believe, frankly, influenced\n10 other people, relative to my client, putting my client on\n1] flights saying my client did things. It is the exposure to\n12 this information. This witness, I believe, will testify, and\n13 has so indicated to the government, that what she viewed was\n14 inaccurate information. That's the import of it.\n15 THE COURT: So the theory is media defined broadly,\n16 could be a blog, a tweet, contains any inaccurate information,\n17 it is relevant to ask this witness as to the accuracy of that?\n18 MR. PAGLIUCA: It is inaccurate as to her personally.\n19 THE COURT: [ understand. But let's say you pull from\n20 some blog post, something perhaps inaccurate; relevant to ask\n21 this witness?\n22 MR. PAGLIUCA: About her and flight records.\n23 THE COURT: Whatever it is from whatever source, there\n24 is flight records that show she went to the moon, you should\n25 ask her about it?\n\nSOU\n\nTHERN\n\nD\n\nSTR\n\nCT RE\n\nPORT\n\nBRS, Pes\n\n(212)\n\n805-0300\n\nDOJ-OGR-00014213\n", "char_count": 1577}, {"efta_number": "DOJ-OGR-00014107", "page_number": 107, "text_content": "Case 1:20-cr-00330-PAE\nLCHCmax3\n\nDocument 763\n\nFiled 08/10/22\n\nDubin - direct\n\nPage 108 of 197\n\n2649\n\n1 MR. PAGLIUCA: No, I'm not asking her about flight\n\n2 records going to the moon.\n\n3 THE COURT: So it does matter what you're asking her\n\n4 about.\n\n5) MR. PAGLIUCA: Of course.\n\n6 THE COURT: So I'll sustain at least on that ground,\n\n7 401, 403.\n\n8 MR. PAGLIUCA: Okay. I understand.\n\n9 THE COURT: We can take our break.\n\n10 (Recess)\n\n11 THE COURT: So I note, I did, at 11:54, Ms. Menninger,\n12 receive an application. I think one of the things I asked for\n13 was a proposed order, which I don't see.\n14 When would the government like to respond?\n15 MS. COMEY: Your Honor, Mr. Rohrbach is currently\n16 writing our response. I suspect we can get it to your Honor by\n17 the beginning of the lunch break.\n18 THE COURT: Thank you. And Mr. Pagliuca, just want\n19 to make sure, we're moving on from the media?\n20 MR. PAGLIUCA: Yes.\n21 THE COURT: All right.\n22 MS. MOE: Very briefly, your Honor, to flag some\n23 logistics that Mr. Pagliuca and I worked out. My understanding\n24 is that he intends to publish a redacted version flight\n25 records —-—\n\nSOUTH\n\nERN D\n\nSTR\n\nCT REPORT\n\nBRS, Pes\n\n(212)\n\n805-0300\n\nDOJ-OGR-00014214\n", "char_count": 1216}, {"efta_number": "DOJ-OGR-00014107", "page_number": 108, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax3\n\nTHE COURT:\n\n25\n\nmoment. I apologize.\n\nDocument 763\n\nThank you.\n\nDubin - direct\n\nMS. MOE: To flag in advance,\n\nintends to of\n\nfer a redacted version of\n\nFiled 08/10/22\n\nGo ahead.\n\nIT think Mr.\n\nPage 109 of 197 2650\n\nCan we have the witness wait outside for a\n\nPagliuca\n\na government exhibit\n\nthat we've agreed upon but is not yet in evidence,\n\nanticipate that he'll of\n\ngovernment exhibit,\n\nthat will be\n\n(Cont\n\nfer a redacted version of\n\ntinued on next page)\n\nthe exhibit that is published.\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nBRS, Pes\n\n(212)\n\n805-0300\n\nand so I\n\nfF the\n\nwhich we prepared and we won't object. And\n\nDOJ-OGR-00014215\n\n", "char_count": 781}, {"efta_number": "DOJ-OGR-00014107", "page_number": 109, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 _ Filed 08/10/22 Page 110 of 197 2651\nLCHVMAX4 Dubin - direct\n\nTHE COURT: Okay.\n\nMR. PAGLIUCA: So the Court knows, Exhibit 662 is the\nflight logs. We're going to offer 662-R. I will be -- I would\nbe publishing 662-R to everyone when I refer to 662-R. There\nare two instances where I will need to refer to 662, and I will\nonly display those to the witness and the Court.\n\nMS. COMEY: And just to clarify, your Honor, when\n\nMr.\n\nRodgers testified, w\n\nmany more redactions.\n\noffered a version o\n\nAnd after conferral\n\nwit\n\nf 662-R that had\n\nth the defense,\n\nthis new 662-R is a much more narrowly tailored redacted\n\nPagliuca,\n\nversion; so it will replace th\noffered.\nTHE COURT: Okay.\nPerhaps a different mark for clarity.\nMR. PAGLIUCA: I'm happy to call it\nit 662-RR.\nMS. COMEY: That's fine, your Honor.\nTHE COURT: Great. Thank you.\nOkay. And just to be clear, Mr.\nrecords are introduced,\n\n662-R that was previously\n\nand we can remark\n\nwhen those\n\nI'm just trying to avoid the sidebars,\n\nis it then going to be about any comparison with what she saw\n\nin the media?\n\nMR. PAGLIUCA: No.\nTHE COURT: Okay.\nMR. PAGLIUCA: I didn't think you would let me do\nSOUTHERN DISTRICT REPORTERS, P.\n(212) 805-0300\n\nDOJ-OGR-00014216\n\n", "char_count": 1366}, {"efta_number": "DOJ-OGR-00014107", "page_number": 110, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 111 of 197 2652\n\nLCHVMAX4\n\nthat, so --\n\nDubin - direct\n\nTH\n\nmake sure w\n\nina\n\nCOURT: That doesn't always stop you. I wanted to\n\nwere on the same pag\n\nMR.\n\nPAGLIUCA: Like any good lawyer, your Honor -—-\n\nTH\n\nina\n\nCOURT: There's no doubt about the zealousness of\n\nanyone in this room.\n\nAre we ready?\n\nMR. PAGLIUCA: I am ready to resume.\n\nMS. MOE: Yes, your Honor. Thank you.\n\nTHE COURT: Now we can get the witness and bring in\nthe jury. Thank you, Ms. Williams.\n\n(J\n\nTH\n\nwith your d\n\nDr ss\n\nury present)\n\nmu\n\nE COURT: All right. Mr. Pagliuca, you may continue\n\nirect examination of Dr. Dubin.\n\nDubin, I remind you, you are under oath.\n\nYou may inquire.\n\nMR. PAGLIUCA: Thank you, your Honor.\n\nAt this point, based on the discussion with the\ngovernment, I would offer Government Exhibit 662-RR at this\npoint, your Honor.\n\nMS. MOE: No objection.\n\nTHE COURT: Thank you. 662-RR is admitted.\n\n(Defendant's Exhibit 662-RR received in evidence)\n\nMR. PAGLIUCA: And for the record, your Honor, as we\n\ndiscussed,\n\n662-RR is the redacted version of 662, which are the\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014217\n\n", "char_count": 1298}, {"efta_number": "DOJ-OGR-00014107", "page_number": 111, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX4\n\nDocument 763\nDubin - direct\n\nDave Rodgers\n\nTHE COURT: Thank you.\nMR. PAGLIUCA: Thank you,\nBY MR. PAGLIUCA:\nQ. Dr. Dubin, I'd like to just go through a\n\nflight records.\n\nbut they've been admitted in evidence.\n\nquestions.\n\nAnd I\n\nflight records.\n\nFiled 08/10/22\n\nPage 112 of 197 2653\n\nyour Honor.\n\nfew examples of\n\nunderstand these are not your records,\n\njust a few examples, okay?\n\nMR. PAGLIUCA:\nGX-662, now marked RR, at page 30,\nQ. Do you have tha\n\nTHE COURT:\n\nMR. PAGLIUCA: I will,\n\nIt's going to be\n\nthe page.\n\nget a cont\n\nIf we can show Dr.\n\nplease.\n\nyour Honor.\n\nI want to ask you some\n\nI'm not going to go through all of the entries,\n\nDubin, please,\n\nt on your screen, Dr. Dubin?\n\nIt's up and you'll need to enlarge.\n\nwe can blow up the entry with the 26 on the side.\n\nthat been expanded, your Honor?\n\n; COURT:\n\n=\nqh\nEl\n\nPAGLI\n\nCOURT:\n\nMR.\n\nPAGLI\n\nUCA:\n\nUCA:\n\nTH\n\nina\n\nCOURT\n\nIt has.\n\nflight number 587,\n\nwhich is in the middle of\n\nAnd this can be displayed for everyone.\n\nOh, yes,\n\nyes.\n\nThis is RR.\n\nFirmation that it's RR?\n\nRight.\n\n[ don't see a mark on it, but can we just\n\nfirst page that we can\n\nMR. PAGLIUCA: We have the\nSOUTHERN DISTRICT REPORTERS,\n(212) 805-0300\n\nPG ew\n\nDOJ-OGR-00014218\n\n", "char_count": 1359}, {"efta_number": "DOJ-OGR-00014107", "page_number": 112, "text_content": "Case 1:20-cr-00330-PAE Document763 _ Filed 08\n\n/10/22 Page 113 of 197 2654\n\nLCHVMAX4 Dubin - direct\n\n1 display for you, your Honor. And I've shown this to the\n\n2 government.\n\n3 THE COURT: It says R, but --\n\n4 MR. PAGLIUCA: We added an R during the break.\n\n5 THE COURT: Okay. All right. Yes.\n\n6 MR. PAGLIUCA: Might inquire, your Honor?\n\n7 THE COURT: You may. And yes, this may be published.\n\n8 MR. PAGLIUCA: Thank you, your Honor.\n\n9 And now if we can blow up -- this is RR. We need to\n10 go to page 30, please. And the 26 in the middle, those two.\n1] BY MR. PAGLIUCA:\n\n12 Q. Do you see those entries, Dr. Dubin?\n\n13 A. Yes, I do.\n\n14 Q. Now, this is a long time ago, and I expect that you don't\n\n15 remember this flight; is that correct?\n\n16 A. What year is this flight?\n\n17 QO. 1994.\n\n18 A. I do not remember the flight, no.\n\n19 Q. Okay, then that's fine.\n\n20 just wanted to ask you some questions about some of\n21 the names that are listed, and this is the remarks section.\n\n22 When wetre looking to the right, there is JE. Do you\n23 know who that refers to?\n\n24 A. I assume it's Jeffrey Epstein.\n\n25 Q. Okay. And then there is Eva Andersson, A-N-D-E-R-S-S-O-N.\n\nSOUTHERN D\n\nSTR\n\nCT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014219\n\n", "char_count": 1236}, {"efta_number": "DOJ-OGR-00014107", "page_number": 113, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\nKn\nOY\n\na\n~]\n\nKn\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22\n\nLCHVMAX4 Dubin — direct\n\nThat would be you?\n\nA. Correct.\n\nQO. And then someone named Frances Jardine.\n\nDo you recall Frances Jardine?\n\nPage 114 of 197 2655\n\nA. TIT recall Frances. I did not know that her last name was\nJardine.\nQ. Do you recall that that was someone that Mr. Epstein was\n\ndating in 1994?\n\nA. Yes.\n\nQ. Okay. It appears from this flight record that you and\nMr. Epstein and Frances Jardine went to DCA -- which I will\nrepresent to you is Washington, D.C. airport -- and then\n\nreturned the same day. And I guess the question is do you\n\nrecall making that trip?\n\nMS. MOE: Your Honor, I'd object to counsel\n\ntestifying.\n\nMR. PAGLIUCA: I'm just orienting the witness, your\n\nHonor.\n\nTH\n\nPA\n\nCOURT: All right.\n\nget to direct questions.\n\nll allow it, but then let's\n\nMR. PAGLIUCA: Yes, your Honor.\n\nQ. Do you recall making this trip?\nA. I do not.\nQ. Okay.\nMR. PAGLIUCA: If we can go down to the second to the\n\nSOUTHERN DISTRICT R\n\nG\n\nPORT\n\nERS,\n\n(212) 805-0300\n\nLD\n\nDOJ-OGR-00014220\n\n", "char_count": 1159}, {"efta_number": "DOJ-OGR-00014107", "page_number": 114, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 115 of 197 2656\nLCHVMAX4 Dubin - direct\n\nlast entry.\n\nQ. And again, I'm directing your attention to the people\nthere. Do you recognize this as yourself, Mr. Epstein, and\nagain, Frances Jardine?\n\nA. Ido.\n\nQ. Okay. And I'm assuming, again -- and this is in 1994 --\nthat you don't have a specific memory of this flight; is that\nright?\n\nA. I do not remember this flight.\n\nQ. Okay.\n\nMR. PAGLIUCA: If we can now turn to page 39 of\n662-RR. The entry -- fourth and fifth entries from the top.\nThis would be November '95, November 21st, November 26th.\n\nQ. Can you see that, Dr. Dubin?\nA. Yes, I can.\nQ. Okay. In the remarks column, the exhibit reflects JE, AS\n\nDo you know who \"AS\" might have been?\n\nMS. MOE: Objection.\n\nA. I don't.\n\nTHE COURT: Overruled. Overruled.\n\nYou may answer. Do you know?\n\nTHE WITNESS: I don't know who \"AS\" is.\n\nQ. Okay. Then there is Eva. That would be you; is that\ncorrect?\nA. That's correct.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014221\n\n", "char_count": 1151}, {"efta_number": "DOJ-OGR-00014107", "page_number": 115, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nAnd then baby.\n\nThis is November 21st,\n\nLCHVMAX4\n\nQ. Glen,\nA. Yes.\n\nQ.\n\nA. What\n\nQ.\n\nA. Yes,\n\nQ. Okay.\n\nbring a nanny with you af\nA.\nQO.\n\nwhich is in New Jersey,\n\nQ.\n\nA.\n\nMost\n\nOkay.\n\nthat would be Glen\n\ndate is this?\n\nI did.\n\nDocument 763\nDubin - direct\n\n1995.\n\nFiled 08/10/22\n\nDubin?\n\nAnd then there is an entry,\n\nlikely, yes.\n\nAnd this record re\n\none\n\nfemale.\n\nFlects a\n\nMS. MOE: Same objec\n\nTHE COURT: I'11\n\nMR. PAGLIUCA: Underst\n\nto Pal\n\nFlight\n\nm\n\ntion,\n\nsustain now.\n\nBeach Island.\n\nyour Honor.\n\nMove on.\n\ntood, your Honor.\n\nis not leading.\n\nDo you recall taking this\nhusband and child to Palm Beach?\n\nI don't recall.\nMS. MOE: Objection.\nTHE COURT: I'm sorry.\nMS. MOE: Objection to leading.\nMR. PAGLIUCA: \"Recall\"\nTHE COURT: ‘ll allow it.\nMR. PAGLIUCA: Thank you.\n\nI don't recall this specific trip,\n\na\n\nO\n\nOkay.\n\nNow I'd like to turn to GX-12,\n\nno.\n\nSOUTHERN D\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nPage 116 of 197 2657\n\nDid you have a child at that point in time?\n\nDid you\n\nFter you had a child on the plane?\n\nFrom Teterboro,\n\ntrip over Thanksgiving with your\n\nwhich is under seal\n\nDOJ-OGR-00014222\n\n", "char_count": 1263}, {"efta_number": "DOJ-OGR-00014107", "page_number": 116, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 117 of 197 2658\nLCHVMAX4 Dubin - direct\nand should only be shown to the witness and the Court.\nTHE COURT: Okay.\nQ. Dr. Dubin, do you have GX-12 in front of you?\n\nTHE COURT: Just to caution the witness not to read\nthe name on the document; not to say out loud the name on the\ndocument.\n\nA. I have the document, yes.\n\nQ. Okay. And could you just read it to yourself, please, and\nnot read it out loud.\n\nA. Okay.\n\nQ. The exhibit GX-12 has the name of a person. And again,\nwe're not using the name of the person. But want to see if\nyou s the name of the person on GX-12, without saying it?\nA. Yes, I do.\n\nQ. Okay. We are referring to that person as Jane, okay?\n\nA. Okay.\n\nQ. And without saying her name, do you recall meeting the\nperson identified in GX-12 at any point in time?\n\nA. I don't recall ever meeting this person.\n\nQ. Okay.\n\nMR. PAGLIUCA: We can take that down.\n\nI'd like to show the witness GX-662, page 44, which is\nunredacted, so just to the witness and the Court please.\n\nTHE COURT: Okay. Ms. Moe?\n\nMS. MOE: Yes, your Honor.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014223\n\n", "char_count": 1274}, {"efta_number": "DOJ-OGR-00014107", "page_number": 117, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX4\n\nDocument 763\nDubin - di\n\nTHE\n\noe\n\nae\n\nI do.\n\nDo you have\n\nCOURT:\n\nThank you.\n\nthat\n\nMR.\n\nthird lines up\n\nup just\n\nlines\n\n11.\n\nQ. Have you been able to read\n\nA. I can't read everything,\n\nQ. Okay.\n\nsee Jane's name next to the\n\nher name?\n\nPAGLI\n\nUCA:\n\nin front of yo\n\nAnd I'd lik\n\nfrom\n\nfor the Cour\n\nfrom the bottom,\n\nThe person\n\nt and\n\nthe bottom,\n\nthe witne\n\nplease. Tha\n\nthat\n\nbut\n\nthat we're re\n\nFiled 08/10/22\n\nrect\n\nue?\n\ne to\n\npage 44.\n\nss\n\nfocus on\n\nAnd if\n\nthe second\n\nt starts with\n\ny Dts\n\nA» YES.\nQ. Okay. And again, you do not --\nrecall meeting anyone named Jane on this\ncorrect?\nMS. MOE: Objection. Leading.\nTHE COURT: Sustained.\nQ. Do you recall meeting anyone named Jane on this\nA. I don't remember this flight.\nQ. Okay.\nA. Or anyone on this flight.\nQ. Okay. That's fine.\nMR. PAGLIUCA: We can take that down.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212%) 805-0220\n\nflight entry 916,\n\nDubin?\n\nI can read some\n\nferring to as Jane,\n\nflight;\n\nPage 118 of 197\n\nthe second and\nyou could blow\nand third\n\nseven and an\n\nit.\n\nof\n\ndo you\n\nwithout saying\n\nI'm assuming you do not\n\nis that\n\nflight?\n\nAnd can we put\n\n2659\n\nDOJ-OGR-00014224\n", "char_count": 1282}, {"efta_number": "DOJ-OGR-00014107", "page_number": 118, "text_content": "N\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHVMAX4\n\nup 662, page 44-R,\n\njury please, your\n\nTHE COURT:\n\nMS. MOE:\nTHE COURT:\nMR. PAGLI\n\nredacted version,\n\nQ.\n\nDocument 763\n\nn - direct\n\nFiled 08/10/22\n\nPage 119 of 197 2660\n\nntries, and display those to the\n\nDubi\nthe sam\nHonor.\nMs. Moe?\n\nNo objection,\n\nUCA:\n\nAll right.\n\nyour Honor.\n\nGo ahead.\n\nWe need to make sure this is the RR,\n\npage 44. A\n\nnd it is.\n\nThis is the same document that you were just shown just\n\nwith a blackout spot there.\n\nA.\n\nQ.\n\nA,\n\nQ.\n\nYe\n\nOk\n\nCo\n\nSs.\n\nay. And the\n\nrrect.\n\nremarks section?\n\nA.\n\nQ.\n\nTh\n\ne first one\n\nDo you recognize any\n\nor the\n\nof t\n\nSECco\n\nDo you see\n\nmu\n\nhe other\n\nthat, Dr.\n\nflight entry has \"Eva\" in it?\n\nindividuals\n\nDubin?\n\nlisted in the\n\nnd one?\n\nLet's start with the\n\nsecond one.\n\nA,\n\na 10 > 10 > 10\n\n10\n\nDo\n\nYe\n\nI recognize\nSs.\n\nrecognize So\n\ntheir\n\nphie.\n\nname\n\ns?\n\nWho do you recognize Sophie as being?\n\nSo\n\nOk\n\nOk\n\nphie Biddle\n\nay. Do you\n\nI believe she\n\nay. And do\n\nwas someone that worked for Jef\n\nknow what she did?\n\nwas a massage therapist.\n\nfirst one and then move on to the\n\nrey.\n\nyou recognize any other names on those\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nBRS, Pes\n\n(212\n\n) 805-0300\n\nDOJ-OGR-00014225\n\n", "char_count": 1300}, {"efta_number": "DOJ-OGR-00014107", "page_number": 119, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22\nLCHVMAX4\n\nentries?\n\nOkay. Anyone else in that entry,\n\nAnd then below that,\n\nDubin - direct\n\nthe name Jeff\n\ncan't read the name after Jeff Schantz.\n\nA. I've heard\n\nhe is.\n\nQO.\n\nA.\n\nQ. Neither can I.\nrecognize?\n\nA.\n\nQ. Okay. And\n\nsee my husband's name, yes.\n\nPage 120 of 197 2661\n\nSchantz, but I can't remember who\n\nwhich is 915?\n\ndo you see any names that you\n\nthen the next entry, flight 916, do you see any\n\nnames that you recognize in that entry?\n\nsee my name, I see JE, see Sophie.\n\nA.\ncomes after Sophie.\nQ. That's fine.\n\nMR. PAGLIUCA: We\n\nTH\n\nma\n\nCOURT:\n\nAnd if\n\nfourth entries\n\nfF we can go\n\nfrom the bot\n\ncan take that down\n\nMR. PAGLIUCA: Thank you, your Honor.\n\nfocus on som\n\nname Celina Midelfart?\n\nQ. I want to\nthe\n\nA. I do.\n\noF\n\nMr. Epstein in\n\nto the entries that\ncttom.\none named well,\n\nDo you recognize that as someone that was\n\nthe '97 time frame?\n\nSOUTHERN DISTRICT REPORTERS, P.\n\n(212) 805-0300\n\nI can't read what\n\nnow.\n\nI'd like to next show the witness 662-RR, page 49.\n\nAnd if it's 662-RR, it may be published.\n\nare the fifth and\n\ndo you recognize\n\ndating\n\nDOJ-OGR-00014226\n\n", "char_count": 1265}, {"efta_number": "DOJ-OGR-00014107", "page_number": 120, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 121 of 197 2662\n\nLCHVMAX4 Dubin - direct\nMS. MOE: Objection. Leading.\nTHE COURT: Sustained.\nQ. Do you know Celina Midelfart?\nA. I know who she is, yes.\nQ. How do you know who she is?\nA. She was a girlfriend of Jeffrey Epstein's.\nQ. Okay. This flight appears to be on August 20th and 23rd,\n1997. Do you have any memory of being on this flight?\nA. I don't remember this flight at all.\nQ. Okay.\n\nMR. PAGLIUCA: Next I'd like to turn to 662\nunredacted. So this should be just for the witness and the\nCourt, please. Page 55, third line up from the bottom. If we\ncan expand that, please.\n\nQ. Do you have that in front of you, Dr. Dubin?\n\nA. It's only one entry, right?\n\nQ. Yes, just one entry. Thank you.\n\nAy. YSS.\n\nQ. Okay. And again, I want to focus on the names in that\nentry, which is from 1998. And it looks like it's May 3rd,\n1998. And without saying the name that we're not saying, do\n\nyou see that name in that entry?\n\nA. Yes,\nQ. Okay.\nrecognize,\n\nI do.\n\nAnd ar\n\nther\n\nwithout saying who they are at\n\nSOU\n\nother names in\n\nthat entry\n\nTHERN D\n\nSTR\n\nCT\n\nREPORT\n\nERS,\n\n(212)\n\n8\n\n05-0300\n\nLD\n\nthat you\n\nt this point?\n\nDOJ-OGR-00014227\n\n", "char_count": 1307}, {"efta_number": "DOJ-OGR-00014107", "page_number": 121, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763 ‘Filed 08/10/22\n\nDubin - direct\n\nPage 122 of 197 2663\n\nyour children's names on this flight list?\n\nyou see that you and your husband are on\n\nt entry that I would like to look at, and\n\nwe can use the redacted version for this, so this will be\n\nAnd may we publish this, your Honor?\n\nI'd like to look at the entry eight\n\ns up from the bottom which begins with a 19. And expand\n\nAnd again, focusing on the remarks section, do you\n\nyour children on that flight, without\n\nSure. Okay. This is from TIST to PBI;\n\nLCHVMAX4\n\n1 A. YO@8s\n\n2 Q. Okay. Is one of\n\n3 A. Yes.\n\n4 Q. And that's fine.\n\nS And then do\n\n6 this flight as well?\n\n7 A. Correct.\n\n8 Q. And then the las\n\n9\n\n10 662-RR, page 114.\n\n11 MR. PAGLIUCA:\n\n12 THE COURT: Yes.\n13 MR. PAGLIUCA:\n\n14 line\n\n15 that, please.\n\n16 Q. Do you see that entry, Dr. Dubin?\n17 A. Ido.\n\n18 Q.\n\n19 recognize names there?\n20 A. I do.\nal Q. And are some of\n22 identifying them by name?\n23 A. Yes, misspelled name.\n24 or\n25 A. I don't know what TIST is.\n\nSOUTH\n\nBERN DISTRICT REPORTERS,\n(212) 805-0300\n\nLD\n\nis that right?\n\nDOJ-OGR-00014228\n\n", "char_count": 1106}, {"efta_number": "DOJ-OGR-00014107", "page_number": 122, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763\n\nLCHVMAX4\n\nFiled 08/10/22 Page 123 of 197 2664\nDubin - direct\n\nQ. That was going to be my next question.\n\nTH\n\nina\n\ncorrect?\n\nMR. PAGLIUCA:\n\nTH\n\nma\n\nMR. PAGLIUCA:\n\n1O\n\nfed)\n\nCOURT: Just to make sure\n\nCOURT: Okay.\n\nI'm right, this is RR;\n\nIt is RR, your Honor.\n\nWe can take that down.\n\nThat's all I'm doing with the\n\nfew more questions, Dr.\n\nDubin.\n\nTHE COURT: Go ahead.\n\nFlight records. I just have\n\nQ. Dr. Dubin, during the 1994 to 2004 time frame, were you\n\never introduced to any other person named Eva who was dating\n\nMr. Epstein?\n\nA. Not that I can recall.\n\nQ. Were you ever introduced to anyon\n\nclose relationship, to your knowledge,\n\nA. Not that I can recall.\n\nQ. Okay. And I need to ask aco\n\nthe person that we identi\n\nlse named Eva who had a\n\nwith Mr. Epstein?\n\nuple of final questions about\n\nFied in Exhibit 12, the person that\n\nwe'tre calling Jane. And I\n\nquestions, okay?\n\napologize\n\nfor asking these\n\nHave you ever been in a group sexual encounter with\n\nthe person we are calling Jane?\n\nA. Absolutely not.\n\nQ. Okay. Have you ever been in a group sexualized massage\n\nwith Jane?\n\nSOUTHERN\n\nD\n\nSTRICT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014229\n\n", "char_count": 1316}, {"efta_number": "DOJ-OGR-00014107", "page_number": 123, "text_content": "=\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\na\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 124 of 197 2665\n\nL\n\nAs\n\nQ.\n\nC\n\nB\n\nQ.\n\nA.\n\nO\n\nae\n\nO\n\nA,\n\n—\nLG\nPi\n\nQ.\n\nn\n\nA,\n\nA,\n\nQ.\n\nCHVMAX4 Dubin - cr\nIT have not.\nThank you.\nMR. PAGLIUCA: That's all\nThank you.\nTHE COURT: Okay. Ms. Moe\nMS. MOE: Thank you, your\nROSS—-EXAMINATION\nY MS. MOE:\nGood afternoon, Dr. Dubin.\nGood afternoon.\nTo be clear, your first name is\nThat's correct.\nAre you the only person named E\nIt's a very, very common name i\n\nFurope, and here.\n\named Eva?\n\nMany —-—\n\nMR. PAGLIUCA: Your Honor,\n\nf these questions.\n\nTHE COU\n\nMany, many,\n\nDo you know\n\n25\n\nA.\n\nver met?\n\nSOUTHERN DISTRICT RE\n(212) 805-\n\nRT: Overruled.\n\nmany.\n\nthe first name of\n\nOSs\n\nIT have, your Honor.\n\nHonor.\n\nEva; is that correct?\n\nva in the whole wide world?\n\nn the Scandinavia, northern\n\nIn the course of your life, have you met many, many people\n\nobject to the relevanc\n\nvery person Jeffrey Epstein\n\nAbsolutely not.\n\nPORTERS, PwC.\n\n0300\n\nDOJ-OGR-00014230\n\n", "char_count": 1063}, {"efta_number": "DOJ-OGR-00014107", "page_number": 124, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX4\n\nQ. You were asked some gq\nwith Jeffrey Epstein\nperiods in particular.\n\nDocument 763 _——«CFFile\n\n, SO\n\nA.\ngo t\n\nQ.\n\njury what kind of\n\nA.\n\nBeach?\n\nNot that often.\n\no Palm\n\nAnd when you say\n\nd 08/10/22 Page 125 of 197 2666\n\nDubin - cross\n\nuestions on direct about your contacts\n\nFocusing on the time\n\nframe\n\nI want to ask you about some time\n\nfrom 1994 to 2004, how\n\noften did you spend time in Jef\n\nrey\n\nEpstein's house in Palm\n\nWe live in New York City and we would only\n\nBeach on vacat\n\n\"not\n\nthat\n\noften\n\nVery hard to say because t\n\nQ.\n\nofte\nA.\nreme\nQ.\nday-\nA.\n\nQ.\n\ngoing on in your li\n\nand,\n\nQ.\n\nPalm\n\nYes,\n\nMaybe\n\nmber.\n\nBeach specifica\n\nlly?\n\njust focusing on\n\nto-day basis?\n\nAbsolutely not.\n\nhere's\n\nPalm\n\nfour times per year.\n\nDid you know what was going\n\nI'm going to ask you just a\n\nin particular,\nYes, we wer\nAnd in 1995, you\n\nBeach\n\ntions and occasionally long weekends.\n\n\" can you explain for the\n\nq\nT\n\nFrequency we're talking about?\n\nso many years. But in\n\nn were you in that house in Palm\n\nIt's\n\nfrom 1994 to 2004, how\nBeach?\nhard -—- I really can't\n\non in that house ona\n\nfew questions about what was\n\nfe during those years, focusing on the 1990s\n\nbetween 1994 and 2000.\n\nIn 1994, were you living in\n\nParis?\n\nvr first child was born; is that right?\n\nSOUTH\n\nE RN\n\nD\n\nSTR\n\nCT REPORTERS, P.C.\n\n(212)\n\n805-0300\n\nDOJ-OGR-00014231\n\n", "char_count": 1494}, {"efta_number": "DOJ-OGR-00014107", "page_number": 125, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22 Page 126 of 197 2667\n\nLCHVMAX4 Dubin - cross\n1 A. That's correct.\n2 Q. And then your second child was born later in the 1990s?\n3 A. 1997.\n4 Q. And so you had a lot going on in the 1990s; is that right?\n5) A. That's correct.\n6 Q. I want to ask you now about your relationship with Jeffrey\n7 Epstein and Ghislaine Maxwell. And in particular, I want to\n8 ask you about your observations of the relationship between\n9 Ghislaine Maxwell and Jeffrey Epstein.\n10 Did you ever have any conversations with Jeffrey\n11 Epstein about the nature of his relationship with Ghislaine\n12 Maxwell?\n13 MR. PAGLIUCA: Your Honor, I'm going to object to this\n14 as being hearsay, calling for a hearsay response.\n15 THE COURT: Just a moment.\n16 Sustained.\n17 Q. Dr. Dubin, based on your conversations -- well, I'll\n18 withdraw that and rephrase.\n19 Did you have occasions in the 1990s to observe the\n20 interactions between Ghislaine Maxwell and Jeffrey Epstein?\n21 MR. PAGLIUCA: I'm going to object to this as being\n22 vague, time frame, and lacking in foundation.\n23 THE COURT: Foundation, overruled.\n24 Time frame, sustained.\n25 Q. Dr. Dubin, focusing on the time frame from 1994 to 2000,\n\nSOUTHERN\n\nDISTRICT R\n\nBPORTERS, P.C.\n\n(212) 805\n\n—0300\n\nDOJ-OGR- 00014232\n\n", "char_count": 1298}, {"efta_number": "DOJ-OGR-00014107", "page_number": 126, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 127 of 197 2668\n\nLCHVMAX4 Dubin - cross\n\n1 during those years, did you have occasion to observe the\n\n2 interactions between Ghislaine Maxwell and Jeffrey Epstein?\n\n3 A. Yes. can't remember specific things, but yes.\n\n4 Q. In general, based on your observations of their\n\n5 interactions, at the time, was it your understanding that they\n6 were in a relationship?\n\n7 MR. PAGLIUCA: Your Honor, objection.\n\n8 Lack of foundation.\n\n9 THE COURT: Overruled. You may answer.\n\n10 A. It's hard to define, I think, \"relationship.\" But they\n\n11 were living in the same house.\n\n12 Q. And did you have an understanding at the time that they had\n13 an open relationship?\n14 MR. PAGLIUCA: Objection. Lack of foundation.\n15 THE COURT: Sustained.\n16 Q. Based on your observations and interactions with Maxwell\n17 and Epstein, did you have an understanding during the years\n18 we've been talking about that they had an open relationship?\n19 MR. PAGLIUCA: Objection. Lack of foundation.\n20 THE COURT: I'll take an answer to the question.\n21 Do you need to hear it again?\n22 THE WITNESS: Yes, please.\n23 THE COURT: Based on your observations and\n24 interactions with Ms. Maxwell and Mr. Epstein, did you have an\n25 understanding during the years we've been talking about that\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014233\n\n", "char_count": 1390}, {"efta_number": "DOJ-OGR-00014107", "page_number": 127, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22 Page 128 of 197 2669\n\nLCHVMAX4 Dubin - cross\n\n1 they had an open relationship?\n\n2 THE WITNESS: I can't really say that I knew whether\n3 they did or did not.\n\n4 BY MS. MOE:\n\n5) Q. Based on your interactions with them in the 1990s, it was\n6 your understanding at the time that Maxwell was responsible for\n7 navigating all of the details of Mr. Epstein's personal life;\n8 is that correct?\n\n9 MR. PAGLIUCA: Object to the lack of foundation, your\n10 Honor. And it's also a compound question.\n\n11 THE COURT: Sustained.\n\n12 Q. In the 1990s, what was your understanding of what Maxwell's\n13 role was in Epstein's life?\n\n14 MR. PAGLIUCA: Again, I object to the lack of\n\n15 foundation and the time frame, your Honor.\n\n16 THE COURT: Sustained.\n\n17 Q. Focusing on the time period from 1994 and 2000, did you\n\n18 have an understanding of what Maxwell's role was in Epstein's\n19 life?\n20 A. I think I do.\n21 Q. What kinds of things did you see Maxwell doing for Jeffrey\n22 Epstein between 1994 and 2000?\n23 A. I can't say that saw what she did, but my understanding\n24 was that —-\n25 MR. PAGLIUCA: I'm going to object to the rest of\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212%) 805-0220\n\nDOJ-OGR- 00014234\n\n", "char_count": 1243}, {"efta_number": "DOJ-OGR-00014107", "page_number": 128, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX4\n\nthis, your Honor,\n\nDocument 763 ‘Filed 08/10/22 Page 129 of 197 2670\n\nDubin - cross\n\nas being lacking in foundation and hearsay.\n\nTHE COURT: Sustained.\n\nOx From your conversat\n\nand 2000, what kinds of\n\nshe did for Jeff\n\nions with Ghislaine Maxwell between 1994\n\nthings would she tell you about that\n\nrey Epstein?\n\nMR. PAGLIUCA:\n\nYour Honor, this is beyond the scope of\n\nmy direct examination, so object to this as well.\n\nTHE COURT: Sustained.\nQ. On direct examination, you were asked some guestions about\nyour memories of meeting people. Do you remember being asked\n\nthose questions?\n\nA. When were th\n\nquestions?\n\nQ. My question is do you remember Mr. Pagliuca asking you some\n\nquestions about whether you remembered meeting certain people?\n\nA. On the flights?\n\nQO. Yes.\nA. Yes, I do.\nQ.\n\nDr. Dubin,\n\nSo I want to ask you a\n\nfew questions about your memory.\n\nwithout getting into any personal medical\n\ndetails, are you having some issues with your memory?\n\nA. Yes, I do.\n\nQ. Again, without getting into details because I don't want to\n\ninvade your privacy,\n\nmean by that?\n\ncan you just explain for the jury what you\n\nfor me to remember anything far back. And\n\nA. It's very hard\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014235\n\n", "char_count": 1399}, {"efta_number": "DOJ-OGR-00014107", "page_number": 129, "text_content": "=\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nI\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHVMAX4\n\nsometimes I can't ev\n\nQ.\n\nDocument 763\n\nDubin -\n\nmember\n\nfamily notices it and I\n\nmedical conditions?\n\nn\n\nMR. PAGLIUCA:\n\nr\n\nFiled 08/10/22\n\nCross\n\nPage 130 of 197 2671\n\nthings from last month. And my\n\nnotice it and it's been an issue.\n\nAnd is that because you've b\n\nn treated\n\nYour Honor, I think\n\nscope of what needs to be discussed at this\n\nrelated to\n\na\n\nTHE COURT:\n\nMS. MOE: Yes,\n\nTH\n\nma\n\nCOURT:\n\nNothing\n\nMS. MOE: Yes,\n\nDHE COURT:\n\n[ believe it is.\n\nMS. MOE:\n\nGI\n\nTHE COURT:\n\n(Counsel con\n\nMS. MOE: No\n\nThank you.\n\nTH\n\nPA\n\nCOURT:\n\nIs this\n\nyour Honor.\n\nmedical issues?\n\nyour Honor.\n\n‘ll allow\n\nit.\n\nJust one moment,\n\nOkay.\n\nThank you,\n\nthing\n\nferred)\n\nfurther,\n\nMr.\n\nMR. PAGLIUCA:\n\nTHE COURT:\n\nDr. Dubin,\n\nThank you.\n\nYou are excused. Thank\n\nTHE WITNESS:\n\nDr. Dubin.\nPagliuca.\n\nI have no redirect,\n\nyou may step down.\n\nyou.\n\nThank you so much.\n\n(Witness excused)\n\nfor particular\n\nthis is beyond the\n\npoint.\n\nthe last question?\n\n—- just the question is, is it\n\nyour Honor.\n\nyour Honor.\n\nyour Honor.\n\nSOUTH\n\nPRN\n\nDISTRICT\n\nREPORTERS,\n\n(212) 805-0300\n\nLD\n\nDOJ-OGR- 00014236\n\n", "char_count": 1222}, {"efta_number": "DOJ-OGR-00014107", "page_number": 130, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 131 of 197 2672\n\nHVMAX4 Healy direct\n\nTHE COURT: All right. Defense may call -- we have\nout ten minutes before the lunch break. Defense may call its\nxt witness.\n\nMS. MENNINGER: At this time we call Michelle Healy.\n\nTHE COURT:\n\nCHELLE HEALY\n\nMichelle Healy may come\n\ncalled as a witness by the Defendant,\n\nhaving been duly sworn,\n\nTHE COURT:\n\ntestified as\n\nYou may inquire.\n\nMS. MENNING\n\nBR:\n\nRECT EXAMINATION\n\nLC\n1\n2 ab\n3 ne\n4\n5\n6 M\n\"\n8\n)\n10\n11 D\n12 BY\n13 Q.\n14 A.\n15 Q.\n16 A.\n17 Gs\n18 A.\n19 Q.\n20 A.\n21 Gs\n22 A.\n23 Q.\n24 A.\n25 Q.\n\nMS. MENNINGER:\n\nGood afternoon,\n\nGood afternoon.\nHow old are you?\n\nI'm 47.\n\nMs.\n\nH\n\nealy.\n\nAnd where do you live?\n\nlive in Dallas\n\nAre you married?\n\nam.\n\n, Llexas.\n\nAnd what do you do\n\nI'm a housewife.\n\nWhat does your husband do?\n\nHe's an architect.\n\nThere in Texas?\n\nThank you,\n\nfor a living?\n\nSOUTH\n\nE RN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nLD\n\nforward.\n\nfollows:\n\nyour Honor.\n\nDOJ-OGR-00014237\n\n", "char_count": 996}, {"efta_number": "DOJ-OGR-00014107", "page_number": 131, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 132 of 197 2673\n\nLCHVMAX4 Healy direct\nA. No, in Albuquergue, New Mexico.\n\nQ. And do you have any siblings?\n\nA. I have a sister.\n\nQO. What's her name?\n\nA. Shannon.\n\nQO. And where does she live?\n\nA. She lives in Albuquerque.\n\nQ. Was there a point in time in which you lived in New York?\nA. Yes.\n\nQ. When was that?\n\nA. I'm born and raised in New York.\n\nSo 1974 to about 1999.\n\nI grew up on Long Island.\n\nwant to direct your attention to years around the mid\n\n\"O06 or so\n\nWhere were you working in around 1996?\n\nJ. Epstein and Company.\n\nQ. And I\n\"00s, to\nA. Okay.\nSF\nA.\nSF\n\nA,\n\nQ.\n\nae\n\nAnd how did it come to pass that you were working at J.\n\nHow did I\n\nYes.\n\nEpstein and Company?\n\nNeeded somebody to\n\njust\n\nso IL\n\nGreat\n\nfilled in.\n\nwas just\n\n. So what\n\nthere\n\nreceive the job?\n\nfill in\n\nto fil\n\nt was your previo\n\n. My sister was working there,\n\nl in.\n\nus job?\n\n[ had a previous job that I was working\n\nSOUTHERN\n\nDISTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR- 00014238\n\n", "char_count": 1154}, {"efta_number": "DOJ-OGR-00014107", "page_number": 132, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 _ Filed 08/10/22 Page 133 of 197 2674\n\nLCHVMAX4 Healy direct\n\nA. Iwas working at Pete's Tavern.\n\nQ. And I think you said your sister was working at J. Epstein;\nis that right?\n\nA. Yes, she was a receptionist.\n\nQ. And at some point did someone ask you to come fill in? Do\n\nyou know who that was?\n\nAs can't recall that.\nQ. Okay. But your sister was working there before you?\nA. Yes.\n\nQ. And when you came to fill in, what job did you do when you\n\ncame to fill in at J. Epstein and Company?\n\nA. Just errands.\n\nQ. And where was J. Epstein and Company?\n\nA. 457 Madison Avenue.\nQ. How long did you end up working at J. Epstein and Company?\nA. [ think I was there from 1996 until about 1999.\n\nQ. And where did you go in 1999?\n\nae\n\nI went to New Mexico.\n\nO\n\nSo just focusing on that period of time, 1996 to 1999,\n\nwhile you were working at J. Epstein and Company, did you meet\n\nJeffrey Epstein?\n\nAy. YSS.\n\nO. ow did you meet him?\n\nA. e was my boss.\n\nQ. And what were your roles and responsibilities during that\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014239\n", "char_count": 1227}, {"efta_number": "DOJ-OGR-00014107", "page_number": 133, "text_content": "=\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nI\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 134 of 197 2675\nLCHVMAX4 Healy direct\n\nntire thr year period?\nA. I was receptionist for a good part of the time. So I did\nerrands, answered phones, and then I was his assistant for a\nbit. So really running around New York City working for my\nbosses.\nQ. Okay. And when you were working as a receptionist, where\nwere you Situated within the office?\nA. So if you walk into the office, you come out of the\nelevator, I'm the first desk. I'm the first person that you\nwould have seen.\nQ. Okay. So if people came to visit the office in that time\nperiod, you were the first person that they would see?\nA. Yes.\nQ. And when you were working as Mr. Epstein's assistant, were\nyou in a -—- sitting in a different place in the office?\nA. Iwas just in the front of the office.\nQ. Okay.\nBye OG)\nQ. And also when you're sitting in the front of the office,\ncould visitors see you when they came to visit?\nA. Yes.\nQ. Can you remember the names of some of your coworkers when\nyou worked in the office between '96 and '99?\nA. Yes. There was Kimberly, there was Lauren, there was Eric,\n\nthere was Darren,\n\nSOUTHERN D\n\nthere was Jeff,\n\nand that's about all\n\nSTR\n\nCT REP\n\nORTERS, P.C.\n\n(212) 805-0\n\n300\n\ncan\n\nDOJ-OGR-00014240\n\n", "char_count": 1371}, {"efta_number": "DOJ-OGR-00014107", "page_number": 134, "text_content": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 135 of 197 2676\n\nLCHVMAX4 Healy direct\n\n1 remember.\n\n2 Q. Did you ever meet Ghislaine Maxwell?\n\n3 A. I did.\n\n4 Q. And who was she?\n\n5 A. She was my boss as well.\n\n6 Q. Do you see her in the courtroom?\n\n7 A. Ido.\n\n8 Q. And where is she and what is she wearing?\n\n9 A. She is right there, and she's wearing a black mask.\n\n10 MS. MENNINGER: f the record could reflect\n\n1] identification of Ghislaine Maxwell.\n\n12 THE COURT: It may so reflect.\n\n13 MS. MENNINGER: Thank you.\n\n14 Q. What kinds of things did you see Ghislaine doing in the\n15 office?\n\n16 A. She oversaw properties and decorating and, you know, that\n17 kind of stuff.\n\n18 Q. Were you reporting directly to her?\n\n19 A. I reported to her and I reported to Jeffrey as well.\n20 Q. And when you talked about running all over New York, what\n21 kinds of things were you doing in your roles running around New\n22 York?\n23 A. To be guite honest, it's a long time ago. If documents\n24 needed to be dropped off or picked up or just really -- I\n25 really can't answer it because it's so long ago, to be quite\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014241\n", "char_count": 1179}, {"efta_number": "DOJ-OGR-00014107", "page_number": 135, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 136 of 197 2677\n\nLCHVMAX4 Healy direct\n\nhonest.\n\nQ. And how old were you in '96?\n\nA. I was born in 1974, so in my twenties.\n\nQ. What were your impressions of Ghislaine Maxwell as a boss?\nA. She's fantastic.\n\nQ. Why do you say that?\n\nA. She taught me a lot. I respected her.\n\nshe was great.\n\nQ.\n\nyou were talking\n\nA.\n\nQ.\n\nae\n\nO\n\nof\n\nA.\n\nQ.\n\nA.\n\ninto a very bad car acciden\n\nwas kind enough to take me\n\nNo.\n\nother people?\n\nNo.\n\nIn your capacity\n\nDid she ever tell you\n\nto them?\n\nShe was tough. But\n\nnot to look people in the eye when\n\nany other location besides 457 Madison?\n\nNo.\n\nThe only time\n\nDid you ever go to any of\n\nI went,\n\nI went\n\nt and\n\nthere.\n\nDid she ever give you directions about how you should speak\n\nof running around, did you ever work out\n\nMr. Epstein's properties?\n\nto Zorro Ranch.\nbroke her jaw.\n\nI was working,\n\nto set eyes on my sister because she was so hurt.\n\nQ.\n\nA,\n\nO\n\nAnd where was your sister working at that time?\n\nShe was on the ranch.\n\nAnd do you know how long she worked on the ranch?\n\nSOUTH\n\nE RN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nMy sister got\n\nAnd Ghislaine\n\nbut at least\n\nDOJ-OGR-00014242\n\n", "char_count": 1315}, {"efta_number": "DOJ-OGR-00014107", "page_number": 136, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nWas it a short period of\n\nLCHVMAX4\n\nA. I don't\nQ.\n\nAvs\n\nQ.\n\nDocument 763\n\nHealy\n\ndirect\n\nFiled 08/10/22\n\nIt was multiple years.\n\nPage 137 of 197 2678\n\nF time or multiple years?\n\nAnd this accident that you described her being injured,\n\nthat happened while she was working at Zorro Ranch?\n\nA. Yes.\n\nQ. And is that the time that you went to visit her?\n\nA. Yes. And that's the only time that I went anywhere.\n\nQ. I want to ask you a little bit about some of the other\npeople. Did you come to know a woman named Emmy Tayler?\n\nA. I did.\n\nQ. And do you know where Emmy Tayler was from?\n\nA. I think London.\n\nQ. Did she have an accent?\n\nA. Yes.\n\nQ. Did you socialize with Ms. Tayler?\n\nA. I did.\n\nQ. And can you just kind of describe what types of things you\nand Ms. Tayler would do together?\n\nA. V were friends. You know, we would go out. You know,\n\nagain, it's\n\nQ.\n\nA.\n\noe\n\na\n\nWas she\n\nI think\n\nAnd you\n\nYeah.\n\nso long ago.\n\nabout your age?\n\nSO.\n\nguys hung out together just in the city --\n\nsocialize with her\n\nNot on a regular basis, but did I\nSOUTHERN DISTRICT REPORTERS,\n(212) 805-0300\n\nLD\n\nDOJ-OGR-00014243\n\n", "char_count": 1247}, {"efta_number": "DOJ-OGR-00014107", "page_number": 137, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 138 of 197 2679\n\nLCHVMAX4\n\non occasion?\nQ. Okay.\n\nMS.\n\nHealy direct\n\nYes.\n\nMENNINGER: want to show the witness and the\n\nCourt only an exhibit that's been previously entered under\n\nseal, Government Exhibit 12.\n\nTHE\n\nak\n\nMS.\n\nCOURT: Okay. Just the witness and the Court.\n\nMENNINGER: Yes.\n\nQ. And Michelle, I'm going to ask you to take a look at this\n\ndocument, no\nit and see i\n\nA. I do.\n\nt read anything out loud, but just take a look at\n\nf you see a name listed there.\n\nQ. Okay. And without saying the name, I want to direct you\n\nthat we're going to refer to that person as Jane, okay?\n\nA. Okay.\n\nQO. And so\n\nT'll refer to her as Jane, and you should only refer\n\nto her as Jane.\n\nA. Okay.\nQ,\nA. Yes.\nQ,\nA.\n\nQ. Where do\n\nDo you recognize Jane's real name?\n\nIs that someone that you met?\n\nI did meet her.\n\nyou recall meeting Jane?\n\nA. In the office. I was told that it was Jeffrey's\ngoddaughter.\nQ. And you were in the office and she was in the office?\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014244\n", "char_count": 1195}, {"efta_number": "DOJ-OGR-00014107", "page_number": 138, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\nKn\nOY\n\na\n~]\n\nKn\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nDocument 763\nHealy\n\ndirect\n\nLCHVMAX4\n\nA. Yes.\n\nQ-\n\nthe office?\n\nA. know her mom ——\n\nQ.\n\nA. No. I know her mom.\n\nfrequently, if\n\nDo you remember her being with anyon\n\nAnd don't say her mom's name.\n\nJane.\n\nQ.\n\nAnd do you remember getting phone calls\n\nFiled 08/10/22\n\nPage 139 of 197 2680\n\nlse when she came to\n\nHer mom would come in quite\n\nBut\n\ndidn't see much of\n\n[ remember correctly.\n\nher mother that you answered?\n\nfrom either Jane or\n\nA. The mother would call to speak to Jeffrey; but Jane, no.\n\nQ. How old did Jane appear to you when you saw her in the\n\noffice?\n\nA. never even thought about it. She looked like a grown-up\n\nto me.\n\nQ. Was she wearing makeup and -—-\n\nA. She had a lot of makeup on.\n\nQ. Did you ever socialize with Jane?\n\nA. When I was out with Emmy. Emmy was closer to her, like\n= didn't socialize with Jane. But on occasion, maybe\n\ntwice, she would have been there. But, again, it wasn't on\n\nlike a -- I didn't even have her phone number, let's just put\n\nit that way.\n\nQ.\n\nAt the time you were working at J.\n\nhanging out with\n\nSO\n\nEmmy in the\n\nlate '90s\n\nEpstein and Company and\n\nin New York, was there\n\nUTH\n\nE RN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014245\n\n", "char_count": 1343}, {"efta_number": "DOJ-OGR-00014107", "page_number": 139, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX4\n\nany\n\nA.\n\nQ.\n\nyou\n\nae\n\nHealy\nother Michelle that you saw in the of\nNo.\n.\nare aware of?\nNot that I'm aware of.\n\nQ.\n\nWas there any ot\n\nwith Jane?\n\nAs\n\nQ.\n\ncan't speak\n\nDocument 763\n\ndirect\n\nfor her.\n\nNot that I can recall.\n\nI'm sorry to ask you this,\n\nFiled 08/10/22\n\nPage 140 of 197 2681\n\nFice, for example?\n\nas there any other Michelle that hung out with Emmy that\n\nBut she had a lot of friends, so\n\nther Michelle that you saw when you saw Emmy\n\nbut were you ever involved in\n\nany group sexualized massages with Jane?\n\nA,\n\nQ.\n\nAbsolutely not.\n\nWere you ever involved in any group sexualized massages\n\nwith Jeffrey Epstein?\n\nA.\n\nQ.\n\nJe\n\nAbsolutely not.\n\nrey Epstein or anyone around the o\n\nthrough Jeffrey\n\nA.\n\nQ.\n\nEpstein\n\nAbsolutely not.\n\nHave you been contacted by the FB\n\nes\n\nconnection with this case?\n\nA,\n\na 10\n\nO\n\nYes.\n\nWhen was the\n\ncan't give\n\nfirst\n\nDid you have anything to do with massages in your job with\n\nFfice that you met\n\nto speak to them in\n\ntime they contacted you?\n\nyou the exact date.\n\nWas it within the last week?\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014246\n\n", "char_count": 1263}, {"efta_number": "DOJ-OGR-00014107", "page_number": 140, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nHealy - cross\n\nFiled 08/10/22\n\nPage 141 of 197 2682\n\ncould have one moment, your\n\nLCHVMAX4\n\n1 A. YO@8s\n\n2 MS. MENNINGER: E\n\n3 Honor.\n\n4 THE COURT: You may.\n\nS (Counsel conferred)\n\n6 MS. MENNINGER:\n\n7 Thank you.\n\n8 THE COURT: Ms. Comey?\n9 MS. COMEY: Thank you,\n10 CROSS-EXAMINAT ION\n1] BY MS. COMEY:\n12 Q. Good afternoon.\n13 A. Good afternoon.\n14 Q. Are you the only Michelle in the world?\n15 A. I hope not.\n16 Q. Have you met other peopl\n17 A. sure have.\n18 Q. Okay. Do you know th\n\n19 Jeffrey Epstein interacte\n20 A. No.\nal Q. Do you know whether he\n22 A. No.\n23 Q. You worked in Jeffrey\n24 A. Yes.\n25 Q. You did not work in any of\n\nNo further questions,\n\nyour Honor.\n\nnamed Michelle?\n\ne first name of\n\nyour Honor.\n\nd with in the\n\nEpstein's of\n\nlate\n\nfice;\n\nhis homes;\n\nvery person that\n\n\"90s?\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nLD\n\nhad masseuses named Michelle?\n\ncorrect?\n\nis that right?\n\nDOJ-OGR-00014247\n\n", "char_count": 965}, {"efta_number": "DOJ-OGR-00014107", "page_number": 141, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 142 of 197 2683\n\nLCHVMAX4 Healy - cross\n\n1 A. No.\n\n2 Q. You've never visited his Palm Beach house, have you?\n\n3 A. Nope.\n\n4 Q. Just got to finish the question so the court reporter can\n5) get it all down. So just let me finish, okay?\n\n6 You've never been to the Palm Beach house; is that\n\n7 right?\n\n8 A. Correct.\n\n9 Q. Okay. Have you ever been to his New York residence?\n\n10 A. Just to drop off documents, but never spent any time there.\n11 It was just you delivered something.\n\n12 Q. So you were never a guest at that home?\n\n13 A. No.\n\n14 Q. Never stayed over at that home?\n\n15 A. No.\n\n16 Q. Never went beyond the front entrance of that home?\n\n17 A. No.\n\n18 QO. Okay.\n\n19 And the only home you've ever been inside of was on\n20 Zorro Ranch one time?\nal A. Yes.\n22 Q. You never flew on any of Jeffrey Epstein's private planes,\n23 did you?\n24 A. No.\n25 Q. You never traveled with Jeffrey Epstein, did you?\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014248\n\n", "char_count": 1033}, {"efta_number": "DOJ-OGR-00014107", "page_number": 142, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 _ Filed 08/10/22 Page 143 of 197 2684\nLCHVMAX4\nA. No.\n\nMS. COMEY: May I have a moment, your Honor?\n\nTHE COURT: You may.\n\n(Counsel conferred)\n\nMS. COMEY: Nothing further.\n\nTHE COURT: Okay.\n\nMS. MENNINGER: No redirect. Thank you, your Honor.\n\nTHE COURT: Okay. Thank you, Ms. Healy.\n\nYou may step down. You are excused. Thank you.\n\n(Witness excused)\n\nTHE COURT: And we'll break for lunch, members of the\njury.\n\nMs. Healy, if you could just step this way.\n\nThank you.\n\nAnd then,\n\nWe'll see you in about an hour.\n\nmembers of\n\nthe jury, enjoy your lunch.\n\nThank you.\n\n(Jury not present)\n\nLHE COURT\n\nAll right.\n\nLet's see.\n\nMatters to take up.\n\nMS. MOE:\n\nYes,\n\nyour Honor.\n\nWe just\n\nwanted to\n\nfollow up on an issue we'd raised\n\nthis morning about confirming that AUSA Alex Rossmiller has\n\nbeen released from defense subpoena.\nTHE COURT: Ms. Menninger.\nMR. PAGLIUCA: Given the Court's rulings, your Honor,\n\nSOUTHERN D\n\nSTR\n\nCT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014249\n\n", "char_count": 1128}, {"efta_number": "DOJ-OGR-00014107", "page_number": 143, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHVMAX4\n\nDocument 763 =F\n\niled 08/10/22 Page 144 of 197 2685\n\nI don't really think there would be any need to have them under\n\nHonor. We'll let him know.\n\nyour Honor.\n\nsubpoena. So, yes, the answer is yes.\nTHE COURT: Yes. Okay.\nMS. MOE: Thank you, your\nTHE COURT: Okay. Other matters?\nMS. MOE: Not from the government,\nMR. EVERDELL: Your Honor,\n\nI think just over the Lunch\n\nbreak the parties are going to confi\n\nAnd we should hopeful\n\nwe return. But we'll use\n\nask for a little bit more\n\ndown and marked properly,\n\nTH\n\nma\n\nCOURT: Okay.\n\n[ think this is yours,\n\nthe lunch break to do\n\nMs.\n\nfer over some stipulations.\n\nly have things hammered out on those when\n\nthat. We may\n\ntime just to get everything written\n\nbut that's the next task.\n\nI will look\n\nMenninger. So\n\nat during lunch break the application that came ina little\n\nfor assistance of\n\nbefore noon\n\nAnd I\n\nsubpoena. think we just got\ngovernment.\n\nMs.\n\nthe marshals to enforce the trial\n\nthe letter from the\n\nJust quickly,\n\nlooked very briefly at your declaration,\n\nMenninger,\n\n[ think your -- just\n\nand it indicated that\n\nyou've made ef\n\nForts to contact this witness,\n\nbut there's no\n\nThank you.\n\nI don't believe the\n\ndetails. Do you know if the witness is represented?\nMS. MENNINGER: do not.\nTHE COURT: Could you pull up the mic.\nMS. MENNINGER: Your Honor,\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014250\n\n", "char_count": 1527}, {"efta_number": "DOJ-OGR-00014107", "page_number": 144, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX4\n\nDocument 763 Filed 08/10/22 Page 145 of 197 2686\n\nwitness is represented in connection with this case.\n\nTHE\n\nMS.\n\nthis witness\n\nCOURT: Okay.\n\nMENNINGER:\n\nThere was no counsel appointed for\n\nas there were with other witnesses.\n\nTHE\n\nCOURT: And so the efforts made to contact the\n\nwitness consisted of what?\n\nMS.\n\nMENNINGER:\n\nYour\n\nmyself. I can get the detail\n\nmaking the calls,\ncalls.\n\nhave that on me at the moment.\n\nHonor, I was not the one doing it\n\nfrom my assistants who were\n\nand also our investigator that was making the\n\ncan get the dates and times of the calls. I don't\n\nTHE COURT: Okay. [ think I need to understand, since\nI'm -- given where we are and what I'm -- in the trial, and I\nsee that the subpoena —-- so the subpoena was -- the return date\nwas for the first day of trial.\n\nSo I would like details as to what efforts were made\n\nto contact the witness.\n\ntestimony that you're seeking\n\nI guess the other question is the\n\nfrom this witness is the same\n\nessentially as the last two witnesses?\n\nMS.\n\nMENNINGER:\n\nt's\n\nvery similar, your Honor.\n\nThere's only one distinction with this one. On this one, Jane\n\ntold the government\n\narly on\n\nabout what was going on.\n\nthe exact verbiage.\n\nSo it was highly specif\n\nthat Kelly could confirm her story\n\nThat's in the 3500. I can pull up\n\nAnd she also gave the woman's last name.\n\nFerence that this -- she also said\n\nFic rel\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014251\n\n", "char_count": 1597}, {"efta_number": "DOJ-OGR-00014107", "page_number": 145, "text_content": "=\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\na\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nDocument 763\n\nFiled 08/10/22\n\nPage 146 of 197\n\nlved in the massages in a way that the\n\nlaimed to have been.\n\nWhen did you receive that 3500 material?\n\nLCHVMAX4\nthat this person was invol\nlast two witnesses were cl\nTHE COURT:\nMS. MENNINGER:\n\nOctober 11th,\n\nTHE\n\nCOURT:\nsomething?\n\nMS. MOE:\n\nGl\n\nI think\n\nMs.\n\nmaterials.\n\njury,\n\nOk\n\nYour Honor,\n\nMe\n\nWith respect to\n\nyour Honor.\n\nay. And Ms.\n\nmninger is referring to the\n\nMoe,\n\nI was just going to\n\nthe testimony was about a Kelly.\n\nthe matters that are b\n\nSo in\n\nThat would probably have been on\n\ndid you have\n\nclarify.\n3500\n\nth\n\nfor\n\nthat respect, the\n\ntestimony would have to mirror the past two witnesses about are\n\nyou a person named Kelly.\n\nrecognize the Court's quest\n\nBut\nmaterial. And when the def\njust want to clarify\n\nin\n\nns was on\n\nterms of the anticipated scope of\n\ncan't\n\ntestimony.\n\ncross-examination of\n\ninvestigative steps,\n\nima\n\nJa\n\nth\n\nwhat we've just seen no\n\nMS. MENNINGER:\nof Jane, which was, Do\nit --\n\nTH\n\nma\n\nCOURT:\n\nyou didn't ask --\n\nAn\n\nnotice of\n\ntion was about 3500\n\nthis\n\nissue,\n\nthe\n\ngine, given that record and\nne and the Court's other rulings about\nat there would be anything other than\nw twice.\n\nActually, asked one other question\nyou recall her last name? Because I had\nd she said yes, if remember, and then\n\nSOUTH\n\nPRN\n\nDISTR\n\nCT RE\n\nPORTERS,\n\n(212)\n\n805-0300\n\nPG ew\n\n2687\n\nDOJ-OGR-00014252\n", "char_count": 1516}, {"efta_number": "DOJ-OGR-00014107", "page_number": 146, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nDocument 763 ‘Filed 08/10/22 Page 147 of 197 2688\n\nLCHVMAX4\n\nMS. MENNINGER: Well, at the time, because I was not\nin touch with that witness, I didn't know if we were going to\nmove to have her testify under her first name, given -—-\n\nTHE COURT: And did you so move?\n\nMS. MENNINGER: did not with respect to this witness\nbecause I hadn't spoken to her. The witnesses that we've\nmoved ——\n\nTHE COURT: Right. But so you've never sought\n\nanonymity with respec\n\nt to this witness.\n\nMS. MENNINGER: That's correct.\n\nMS. MOE: also add, your Honor, that when defense\ncounsel wanted to put in the record the first and last names of\nfolks when there were sensitivities, they wrote them down on a\npiece of paper. There were a million different ways to get\n\nthat before the jury,\n\nMS.\n\nand they chose not to.\n\nM\n\nENN\n\nNG\n\nBR:\n\nunderstand that the cross -- or the\n\ndirect would be based on what the questions were of Jane. I'm\n\nnot here to dispute that.\n\nof who it is.\n\nshe told the\n\nI'm just telling the Court in terms\n\nShe told the government the last name and what\n\nTH\n\nina\n\nCOURT:\n\ngovernment.\n\nL un\n\nderstand. Which just indicates that\n\nthe defense has been on notice of this person, which I presume\n\nis what -- since October,\n\ninvolved in the sexualized massages.\n\nas someone who Jane indicated was\n\nI presume that's why you\n\nnoticed this person Kelly as a defense witness and issued a\n\nSOUTH\n\nE RN\n\nD\n\nSTRICT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014253\n\n", "char_count": 1593}, {"efta_number": "DOJ-OGR-00014107", "page_number": 147, "text_content": "=\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\na\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330\nLCHVMAX4\n\n-PAE\n\nDocument 763\n\ntrial subpoena weeks ago.\n\nFiled 08/10/22\n\nPage 148 of 197 2689\n\nMS. MENNINGER: Yes, your Honor.\ncan make a representation about the number of names\nthat were mentioned in the volumes of 3500 material. I know\n\nyour Honor has received the t\n\nstifying Witness 1, but I can\n\ntell your Honor there was approximately 500 nontestifying\n\nwitnesses with similar volumes\n\nindividuals.\n\ndoesn't mean tha\n\nSo the\n\nTHE COURT:\n\nat 11:54, it was almost --\n\nI'm jus\n\nOf\n\nfact that\nt's the day we\n\nCOur sé\n\nLaA.?\n\nof interviews with those\n\nwe received it on October 11th\n\nsaw this\n\nt trying to understand why I\n\nFair enough.\n\ngot an application\n\n54, seeking enforcement of a\n\ntrial subpoena regarding a witness who's been disclosed, a\n\npotential defense witness who's been disclosed for months, who\n\nthe defense noticed and attempted to serve a subpoena on, who,\n\nunlike the other witnesses the defens\n\nsubpoena on, you received no contact.\n\nmillion -- and I\nteam —- both tea\n\njust a little ha\n\nI know you're busy.\n\nmean that genuinely,\n\nrd to understand,\n\nwould exclude the witness.\n\n(Continued on next page)\n\nI get that.\n\nobviously.\n\nunless maybe you thought\n\nattempted to serve a\n\nYou have a\n\nI know this\n\nms are working extremely hard. This one is\n\nSOUTH\n\nPRN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014254\n\n", "char_count": 1482}, {"efta_number": "DOJ-OGR-00014107", "page_number": 148, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 149 of 197 2690\nLCHCmax5\n\nMS. MENNINGER: That was an application, your Honor.\n\nTHE COURT: It was an application. It was an\napplication that you asked to respond to at -- I think it was\n6 o'clock last night. So I didn't get your response on that\nuntil 6 o'clock last night. I ruled as fast as could, which\nmeant last night, I think it was probably after 11:00 p.m. or\n\nclose\n\nreso\n\nhad\n\nthat witness,\n\nun\n\nbut\n\nlu\n\nful ]\n\nto midnight,\n\ntion as soon as\n\nbriefing.\n\nEven i\n\ntil 11:55 a.m. today.\n\njust want to have\n\na determination.\n\nthis issue,\nproduced 3500 materials,\n\nwitnesses,\n\ncould once the issue was raised and I\n\nyou hadn't taken steps to ent\n\nthe\n\nI'm going to look at\n\nfactual record that\n\nMS. MENNINGER: can email chambers as soon as\nther the dates and times of the communication efforts.\nt that in a writing, this way your Honor has a factual\n\nit\n\nthat,\n\nMS. MO\n\nma\n\nJust\n\njust want\n\nwhich was a\n\nI think, earlier\n\nthe particular victims\n\nbut thought it was important to give that\n\nf there hadn't been an application to preclude\nForce the subpoena\nthe materials,\n\nI need to make\n\nCan\n\nrecord\n\nwith respect to developing a record on\n\nto make sure it's clear t\n\nmuch narrower scope.\nthan October,\n\nin this case.\n\nrespect to Jane talked\n\nabout the very,\n\nwe designated them\n\nhat\n\nfor t\n\nwas a letter\n\nestL\n\nwhen we\nfying\n\nAccompanied with\n\nidenti\n\nfying\n\nThe materia\n\nSOUTHERN\n\nDISTR\n\nCT REPORT\n\nBRS, P.\n\n(212)\n\n805-0300\n\nls with\n\nvery limited number of\n\nDOJ-\n\nOGR-00014255\n", "char_count": 1653}, {"efta_number": "DOJ-OGR-00014107", "page_number": 149, "text_content": "=\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\na\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHCmax5\n\npeople who Jane recalled in particular being present\n\nDocument 763\n\nFiled 08/10/22\n\nPage 150 of 197\n\n2691\n\nfor these\n\ngroup sessions. I don't know the exact number off the top of\nmy head, but I think it is just the people who Ms. Menninger\nasked about on cross examination and those particular first\nnames. So I want to make sure the record is clear, that it's\nnot the case that the 3500 materials had hundreds of names of\npeople —--\n\nTHE COURT: Can you just give me one second. Sorry.\nGo ahead.\n\nMS. MOE: just want to make sure the record was\n\nclear that in the materials relating to Jane that we produced\n\nin October, it's not\n\nhundreds of names of people. In fact,\nfive or fewer. But Ms. Menninger has\na very narrative scope. So\n\nis clear on that in terms of when th\n\nit was,\n\njust want to mak\n\nrelevanc\n\nI want\n\nthe case that those materials contain\n\nto say,\n\nthose materials and it's\n\nthe record\n\nsur\n\nhave become apparent and how\n\nTHE COURT: And the\nthat you used to try to contact\nbasis -—- what is the basis to\n\nMS. MENNINGER:\n\nserver,\n\nand with that handover,\n\ncontact information\n\ncall.\n\nwitnesses we've pl\n\nSOUTHERN D\n\nWe had a sta\n\naced on call.\n\nspecific it was.\n\nf that would\n\nthis witness,\n\naddress or contact information\n\ndo you have any\n\nndard letter that we gave to all of\n\nSTR\n\nCT REPORTERS, P.\n\n(212)\n\n805-0300\n\nthe current contact information?\nShe was served personally by a process\nI believe she was handed the\n\nto get in touch with us to be placed on\n\nthe\n\nDOJ-OGR-00014256\n\n", "char_count": 1648}, {"efta_number": "DOJ-OGR-00014107", "page_number": 150, "text_content": "Case 1:20-cr-00330-PAE Document 763\n\nFiled 08/10/22 Page 151 of 197 2692\n\nLCHCmax5\n1 THE COURT: Okay. I will look at it and see what the\n2 request is.\n3 The issue that you noted last night, Ms. Menninger,\n4 that you said needed to be done on Monday, what is that? There\n5) was something last night when we talked about the defense would\n6 likely finish today, you caveated that there was one small\n7 short matter that would be done on Monday, and I don't think\n8 know what that is.\n9 MS. MENNINGER: think it's the witness from London,\n10 your Honor, that you discussed with Mr. Everdell earlier.\n11 MR. EVERDELL: I believe that's what we were referring\n12 to\n13 THE COURT: [ didn't realize that.\n14 MR. EVERDELL: I thought I actually said, your Honor,\n15 another witness, a short witness that we might need to put on\n16 on Monday.\n17 THE COURT: That's the same as what you caveated?\n18 MS. MENNINGER: Yes.\n19 MS. STERNHEIM: Yes, Judge. That's when I said that\n20 we would make sure that we were finished so that we could go\n2] right into the closings.\n22 MS. MOE: Your Honor, on that score, I did not realize\n23 that that was the same witness we were talking about this\n24 morning. If they were aware of this witness yesterday, that\n25 name was not on the witness list provided to the government,\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014257\n\n", "char_count": 1375}, {"efta_number": "DOJ-OGR-00014107", "page_number": 151, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 152 of 197 2693\n\nLCHCmax5\n\nthere weren't any 26.2 materials disclosed.\n\nSO\n\nthis person was,\n\n[ think, from that record, they're aware of who\n\nthey were planning on calling them on Monday,\n\nand had still not disclosed to the government they were\n\nplanning to call\n\nJust to echo our concern\n\nthis person or who they were.\n\nfrom this morning about why\n\nwe're hearing about this so late and why the case would be held\n\nover for a Late disclosed witness\n\nTHE\n\n25\n\nwhat they wer\n\nCOURT: What was the government's understanding of\n\nMS.\n\nthe issue rel\n\nMOE: We didn't know.\n\nEl\n\nwas a plaincl\n\nwhen defens\n\nothes police officer\n\nKingdom, that's what we thought that was ret\n\nreferred to a witness pot\n\nin\n\nreferring to for Monday?\n\nAnd we were confused about\n\ntential\n\nlated to the person who had asked for anonymity who\n\nthe United Kingdom. So\n\nly from the United\n\nferring to. We did\n\nnot realize that was a reference to someone who had not been\n\ndisclosed to\n\nthe government.\n\nMR.\n\nPVERDELL: Your Honor\n\ntf\n\nI believe the way the\n\nsequence worked, there was a different witness from the U.K.\n\nthat, days ago,\n\nwe said we might need to call, and anticipated\n\nMonday because of the number of witnesses we thought we were\n\ngoing to call. That is somebody d\n\nThen,\n\nday, I said there may be ano\n\nwas referring to the same witness.\n\nj\n\nas we were talking about it,\nther short wit\n\nWe hadn't given the name of\n\nfferent.\n\ntness on Monday.\n\nI believe the other\n\nSOUTHERN DISTRICT R\n\nG\n\nPORT\n\nERS,\n\n(212) 805-0300\n\nPG ew\n\nDOJ-OGR-00014258\n\n", "char_count": 1703}, {"efta_number": "DOJ-OGR-00014107", "page_number": 152, "text_content": "Case 1:20-cr-00330-PAE Document763 _ Filed 08\n\n/10/22 Page 153 of 197 2694\n\nLCHCmax5\n\n1 that person because, at that point, we were still trying to\n\n2 gather the information to see if he could be a witness.\n\n3 didn't -- there was nothing to disclose at that point because\n\n4 we were still working this out to make sure we had this person\n5 lined up and they would be a witness with relevant admissible\n\n6 information.\n\n7 His 26.2 material would be a one-page or maybe a\n\n8 two-page declaration, which could be reviewed in 10 minutes, so\n9 I don't think that's an issue. The name of the person is sort\n10 of irrelevant. We said it was going to be a witness -- sorry,\n11 your Honor. And I believe the Court did say, I'm looking at\n\n12 the transcript on page 25 --\n13 THE COURT: This is from yesterday?\n14 MR. EVERDELL: Yes, it's from December 16th, so that\n15 is yesterday, at page 2534, I had said, think if we went over\n16 in the morning, even if we had this one witness, it would be\n17 very brief, so we could have almost a full day on Monday. The\n18 Court responds okay. So finishing tomorrow or a very short\n19 witness on Monday means closings on Monday and then a charge to\n20 the jury. Okay, I'll permit that, so long as it does not\n2] interfere with that schedule.\n22 So we were on the assumption that we could get this --\n23 THE COURT: I didn't know until now that that --\n24 something in the course of the conversation, my memory of it is\n25 that it was Ms. Menninger who noted that there was one small\n\nSOUTHERN DISTR\n\n(212\n\n) 805-0300\n\nCT REPORTERS, P.C.\n\nDOJ-OGR-00014259\n", "char_count": 1583}, {"efta_number": "DOJ-OGR-00014107", "page_number": 153, "text_content": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 154 of 197 2695\nLCHCmax5\n1 thing that needed to be do on Monday. I didn't understand\n2 until this moment that that was the same person who you've\n3 raised this morning as a witness regarding Ms. Maxwell -—- the\n4 timing of Ms. Maxwell's residence at the Kinnerton address.\ni) MR. EVERDELL: Yes. And I'm sorry I wasn't clear\n6 about that, your Honor. think there has been a lot going on,\n7 but apologize about that. That was who I was referring to\n8 there because the other person who we had put the name on the\n9 witness list who is from the U.K., we had decided not to call\n10 that person before yesterday. It was this one that I was\n1] referring to. And I can even give the name now so we're not\n12 talking about an anonymous person.\n13 MS. MOE: Yes, your Honor. As I stand here, still\n14 don't know who this person's name was and it hasn't been\n15 produced and the defense is out of witnesses. I think this is\n16 the definition of a delayed disclosure. We're at the\n17 conclusion of the defense's case and I'm learning for the first\n18 time the name of this witness. still haven't received their\n19 26.2 material. And it's clear the defense has been on notice\n20 of -—-\n21 MR. EVERDELL: It's not true at all. We did not know\n22 about this witness until yesterday. His name is Kevin Moran,\n23 and he is the owner of the Nags Head Pub across the street from\n24 44 Kinnerton Street. We did not know about him until very,\n25 very recently. I'll have to get the exact time. It was within\n\nSOUTHERN D\n\nCT RE\n\nSTR\n\n(212) 805-0300\n\nPORTERS, P.\n\nDOJ-OGR-00014260\n", "char_count": 1613}, {"efta_number": "DOJ-OGR-00014107", "page_number": 154, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHCmax5\n\nthe last day or\n\nDocument 763\n\nwe actually had\n\nbe\n\nfore I prof\n\nwe've been ab\n\nat the end of\n\nthe day,\n\nadditional witness,\n\nYour Honor,\n\nbecause this issue came up at\n\ndiscussed earlier in\n\nle to do that\n\nto confirm tha\n\nfered him as a wit\n\nthat's who\n\nactually,\n\nthe day,\n\nFiled 08/10/22\n\ntwo that we knew this about this person.\n\ntness in this case.\n\nt and that's\n\nPage 155 of 197\n\nAnd\n\nt he had relevant information\n\nAnd now\n\nth when,\n\non yesterday,\n\n[ told the Court that we may have one\n\nI was referring to.\n\n2696\n\nI'm sorry.\n\nand we\n\nfelt like we had to\n\nIt was yesterday\n\nfFrer the property issue was\n\nFind\n\nsomebody who could establish her residency at 44 Kinnerton\n\ninstead of not just her ownership.\n\nMr. Moran.\n\nTHE\n\nCOURT:\n\nThe government moved to preclude th\n\nKinnerton.\n\nMR.\n\nEVERDELL:\n\nthat's the basis --\n\n[ mean,\n\nagain,\n\nWe w\n\nre abl\n\nto find\n\nsomehow.\n\nfind it amusing,\n\nown\n\nI understand the Court's ruling and if\n\nrship documents on\n\nLim Leptamge Lee\n\nit because it was ownership,\n\nin because\n\nyour Honor ——\n\nresidence\n\nI gather\n\nnot\n\nI think you persuaded\n\nfrom\n\nI'm sorry.\n\nthat was what\n\nTHE COURT: 'm letting it in.\nqueried the relevance of\nresidence, but I'm letting it\nme that you can argue the inference of\nownership.\n\nMR. EVERDELL: And,\n\nTHE COURT: Just -—- all along,\nthe defense intended to do,\n\nto establish timing of\n\nresidence;\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\n(212)\n\n805-0300\n\nBRS, Pes\n\nDOJ-OGR-00014261\n\n", "char_count": 1591}, {"efta_number": "DOJ-OGR-00014107", "page_number": 155, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 156 of 197 2697\n\nLCHCmax5\n\ncorrect?\n\nMR. EVERDELL: That's right, your Honor.\n\nTHE COURT: You didn't see a need to find other\n\nwitnesses regarding --\n\nMR. EVERDELL: And the reason why we had to is because\n\nthat is what we were planning to do all along, to show when she\n\nwas at that place.\n\nHowever, when we litigated this issue and discussed it\n\nyesterday, the Court the government raised the deposition\n\ntranscript from the defendant who said, in sort of an offhand\n\nway, if you read the transcript, '92, '93 was when I was there.\n\nThen it became an issue of when she was actually residing there\n\nas opposed to when she owned it. We thought if the stipulation\n\nwas going to have to involve that testimony, as well, we then\n\nnow needed a witness, because the facts we believe to be true\n\nwas that she was not only -- did not own it until then, she was\n\nnot there, she did not reside there, she wasn't renting it.\nThere was another couple that was in that house living there\nuntil she owned it, purchased it, and then owned it, and then\n\nmoved in.\n\nTHE COURT: So really, this is a new let me s if\n\nI get this right.\n\nMR. EVERDELL: Your Honor, if I can add one more\n\nthing. She had another residence in London prior to the\n\nKinnerton Street residenc\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014262\n", "char_count": 1491}, {"efta_number": "DOJ-OGR-00014107", "page_number": 156, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 157 of 197 2698\nLCHCmax5\n\nTHE COURT: And that's in the record; right?\n\nMR. EVERDELL: We're going to have to add that as part\nof the stipulation. We have the land registry records for that\nresidence now, as well, showing her ownership of that\nresidence, but we still want to be able to counter what I think\nis an incorrect inference to the jury that she wasn't there.\nYes, I understand there is a deposition where she made an\noffhand reference and got the years wrong, but we now have a\nwitness who can actually say what we believe to be true, which\n\nis that she wasn't living there either until\n\nTHE\n\nCOURT:\n\nMR.\n\nEVERDELL:\n\nAnd sometimes details are of\n\nshe owned it.\n\nAnd she may have in that deposition\n\ngotten the place wrong because she had the prior place in\n\nLondon, and Stanhope Mews was the name of the street. At that\ntime in '92, '93, she owned that place. So she may have gotten\nthe place wrong in the deposition.\n\nSo what I think it sets up is a misleading --\nfactually misleading impression for the jury based on an\noffhand deposition transcript quote, one line from a 2019\ndeposition where it's not exactly clear which residence she may\nbe referring to in the first place.\n\nAnd this is an important point for the defense, your\nHonor. We feel like --\n\nTHE COURT: Let me just make sure, because all of\nthis, all of this is impeachment of a witness who says that\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014263\n\n", "char_count": 1615}, {"efta_number": "DOJ-OGR-00014107", "page_number": 157, "text_content": "be\n\nN\n\nWw\n\nws\n\nOn\n\nOY\n\n~l\n\njee\n\nKe\n\nA\nco)\n\nhe\nbe\n\nNO\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nKe\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax5\n\nMs.\n\ntime.\n\nevents that\n\nconduct\n\n—-- contact wi\n\nDocument 763\n\nFiled 08/10/22\n\nR. EVERDELL:\n\nto in\n\nshe testified\n\nth\n\nJeffrey\n\nThat's right.\nthe U.K.,\n\nEpstein\n\nPage 158 of 197\n\nKinner\n\nhouse with\n\nton S$\n\ntreet address.\n\nthe red door across\n\nthe 44 Kinnerton Street --\n\ncross that\n\nthinking,\n\nacross the street.\n\nthinking the same\n\nthinking is we wanted to mak\n\nsaid on di\n\nTH\n\nMR.\n\nCOURT: It\n\nina\n\nfocused on\n\nhuh,\n\nactually did\n\nthing, too.\n\nEVERDELL:\n\nWell, no,\n\nShe even iden\n\nShe testii\n\nti\n\nYou know what,\n\nI wonder if they have a witness\n\nyour Honor.\n\nbecaus\n\nsur\n\nferent occasions to the\n\ntook place in the apartment across\n\nwas one time,\n\naddress,\n\nelse in London.\nsubway tube stops away.\nsay it was the Kensing\n\naddress at Kinnerton Street.\n\nwhich, by the way,\n\nbut she also said it\n\n1s not\n\nIt's nearby,\n\ntf\n\ngovernmen\n\nfrom the Nags Head\n\nthe pub across the street.\n\nWhat\n\nthe events of\ntook place in\n\nfied the pho\n\nfrom\n\nPub,\n\nthe\n\n2699\n\nMaxwell lived at the Kinnerton residence at a particular\n\nfied that the\n\nsexual\n\nto of\n\nthe pub\n\nwe were\n\nthat wi\n\ntha\n\nfrom the Nags\n\nHead\n\nthe event\n\nPub,\n\nhappened at a Kensington\n\nBelgravia\n\nbut it's next\n\nSo we weren't sure\n\nton address or it was\n\nShe committed\n\ntd\n\ndoor,\n\nthe\n\nwhich is\n\nwas an interesting moment during the\n\nI remember\n\nyou were\n\ntness had\n\nLS\n\nthat\n\nit's somewhere\n\nit's several\n\nshe was going to\n\nHE COURT: What date was that?\nR. EVERDELL: What date was what?\nSOUTHERN DISTRICT REPORTERS,\n(212) 805-0300\n\nthe\n\nto the\n\nBelgravia\n\nBelgravia.\n\nDOJ-OGR-00014264\n", "char_count": 1688}, {"efta_number": "DOJ-OGR-00014107", "page_number": 158, "text_content": "be\n\nN\n\n(ee)\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax5\nTHE COURT:\nKinnerton.\nMR. EVERDELL:\nthe 302s to the governmen\nTHE COURT: I'm\nMR. EVERDELL:\nTHE COURT: Yes.\nMR. EVERDELL:\nHonor.\nMS. MOE:\nMR. EVERDELL:\n\nthought we were Jj\n\nthe\n\nDocument 763 ‘Filed 08/10/22\n\nShe had said two di\n\nPage 159 of 197 2700\n\nThat testimony that she committed to the\n\nFferent things in\n\ntalking about at tr\n\nWhat day was in the\n\nI think Kate testifi\n\nt was Monday of last wee\n\nYes.\n\nial.\n\ntrial transcript?\n\ned on 12/6, your\n\nk, your Honor.\n\nAnd in order to counter that, we\n\nust going to use the property records.\n\nBut because then th\n\ngovernment raised\n\nTHE COURT: Right.\nMR. EVERDELL:\nissue of the deposit\n\nanticipating,\n\nwhich\n\nwe\n\nthat is factually inacc\nbet\nthere.\nhave.\nTHE COURT:\nMR. EVERDELL:\nTHE COURT:\nMS.\n\nThe\n\ntion testimony,\n\nthink is misleading,\n\nurate,\n\nYes.\n\nMOE: Your Honor,\n\nfirst is the det\n\nFense now\n\nwe thought, we\n\nwhich we weren't\n\nbecause we think\n\nll, okay, now we\n\nter get somebody who can testify about her actual residency\n\nThat's why we scrambled to find Mr.\n\nIsn't that funny.\n\nMoran, who we now\n\nFrom the pub across the street?\n\njust a few things in response.\n\nhas property records for\n\nSOUTH\n\nE RN\n\nD\n\nSTR\n\nCT REPORTERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014265\n\n", "char_count": 1370}, {"efta_number": "DOJ-OGR-00014107", "page_number": 159, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHCmax5\n\nthe second address,\n\ngovernment.\n\nthe d\n\nDocument 763\n\nFiled 08/10/22\n\nPage 160 of 197 2701\n\nit had not been disclosed to the\n\nfens\n\nconclusion of\n\ncase,\n\nLondon,\n\naddresses is, it's\n\nwhen all of\n\nI think what\n\ntheir explanation\n\nthat she mixed up two properties, and that\nmarginal relevance, if any, of impeachment\ntestimony because ther\n\nMs. Maxwell was living\nrelevant time and det\nThey can't say Ms.\nTHE COURT: Sure they can.\nMS. MOE: My point, your Honor,\n\nthe view is it's easy to mix up two houses,\n\nrelevance of going\n\nproperties\n\nthe lat\n\ngiven\n\nto look into this or respond\n\nsuch a late hour.\n\nin London and records at\n\ndisclosure to\n\nSo we're now having a Friday afternoon,\n\nmini trial about properties\n\nde\nvery telling because, i\nfor Ms. Maxwell's deposit\n\nat the\n\nin\n\nthis could have been anticipated long ago.\nfense counsel has said about mixing up\n\nt appears to be that\n\ntion testimony is\n\nshows that extremely\n\nvalue for Kate's\n\ndoesn't appear to be any dispute that\nin that area of London during the\n\nfFense counsel can't have it both ways.\n\nMaxwell easily confused two properties.\n\ndown this rabbit\n\nhole of\n\nEverybody does that.\n\nis the relevance. Tf\nwhat's the\ntwo different\n\nto it.\n\nthis late stage,\n\nIt's such a sideshow at\n\nespecially\n\nthe government and our inability\n\nThis could have been teed up much earlier.\n\nMR. EVERDELL: I don't know how this could have been\nconsidered a sideshow. This shows that what the witness\ntestified to was a factual impossibility.\n\nTHE COURT: Just like Ms. Maxwell's testimony that she\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212%) 805-0220\n\nDOJ-OGR-00014266\n\n", "char_count": 1760}, {"efta_number": "DOJ-OGR-00014107", "page_number": 160, "text_content": "=\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nI\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHCmax5\n\nDocument 763\n\nFiled 08/10/22\n\nPage 161 of 197\n\n2702\n\nlived there from '92 to '93; right? In fact, your argument is\nit's a factual impossibility that she lived there in '92, '93?\n\nMR. EVERDELL: I'm saying the witness is mistaken\nbased on the property records, yes, your Honor.\n\nMS. MOE: Just like Ms. Maxwell, your Honor. That's\nwhy this is such a sideshow.\n\nTHE COURT: Look, always say, I have so many bridges\nto across, cross the bridge that's in front of me. So what\nis the guestion?\n\nMR. EVERDELL: Well, so, there are, I think, a few\nquestions. We still have to confer on the stipulation to the\n\nKinnerton Street rec\n\nto admit\n\nords.\n\ntitle of both the Ki\n\nMews residenc Tho\n\nby the way, your Hon\n\nthey came from the\n\nnmnnerton Str\n\nthe land registry records showing the trans\n\nt residenc\n\nWe are going to propose being able\n\ner oO\n\nand the\n\nse are both land registry documen\n\nor, those are sel\n\nland registry and\n\nselfauthenticating\n\noreign public doc\n\nadmitted just by\n\nthemselves,\n\nin\n\nfauthenticating\n\nbut we wan\n\nformation.\n\nprosecution should b\n\nfact that they reflect certain\nthe Court said is if we're going\nthose, the defense should be able\n\ne able to admit\n\numents.\n\nthey are\n\nThose c\n\nAnd I\n\nto permit -- sorry.\n\nfrom when Ms. Maxwell said '92, '93.\nSo we have to\nSOUTHERN DISTRICT REPORTERS,\n(212) 805-0300\n\nPG ew\n\nStanhope\nts. And\n\nbecause\n\nan be\n\nt a stipulation to the\nthink what\n\nto be permitted to admit\n\nThe\n\nthat deposition testimony\n\nDOJ-OGR-00014267\n\n", "char_count": 1620}, {"efta_number": "DOJ-OGR-00014107", "page_number": 161, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nDocument 763\n\nLCHCmax5\nTHE COURT: Look,\nnot to admit the testimony?\nMR. EVERDELL: Well,\nmoment, your Honor.\n\nthat last week\n\nhad to respond\n\nYour Honor,\n\nCO Us\n\nCO.\n\nthe government,\n. So it's new in\n\nShe was never shown these documents.\n\nit was during the deposition.\n\nregistry records of\n\nfF the property records.\n\nI mean,\n\nFiled 08/10/22\n\nis there a basis\n\nI think, your\n\nHonor,\n\nPage 162 of 197 2703\n\nfor the government\n\nit's -- one\n\nas we discussed, provided\n\nFormation\n\nFor us that we\n\nvidenc\n\nand there is already\n\nAnd\n\nshe was never shown the\n\nTf you own houses\n\nbut\n\nyour Honor,\n\nthe years, as\n\nfferent years,\n\nin the record that she was\n\nmany different\n\nTHE COURT: [ don't know.\nMR. EVERDELL: I don't know either,\nimagine if you own several places over\nMs. Maxwell has, there is evidenc\nliving in different places over di\nplaces. You might not recall right o\n\nthe\n\ntop of your head\n\nthe exact years that you lived at some address unless you can\n\nrefresh your recollection.\n\nAnd it's also possible that if\n\nyou're being asked a vague question in a deposition and you had\n\ntwo di\n\nfferen\n\nyears you lived in the ot\n\ntalking about\n\nt one and not\n\nt addresses in London,\n\nt the other,\n\nther address\n\nactually talking about today.\n\ntwo property records coming in and the depo coming in,\n\nTHE\n\nCOURT:\n\nfF we get a stip on the two addresses,\n\ninstead of\n\nyou may assume they're\n\nand you may answer the\n\nth 'r\n\non Ww\n\nthe\n\nthen\n\nSOUTH\n\nERN D\n\nSTR\n\nCT RE\n\nPORTERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014268\n\n", "char_count": 1651}, {"efta_number": "DOJ-OGR-00014107", "page_number": 162, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHCmax5\n\nthink both sides argue wha\n\nMR.\n\nEVERDELL:\n\nDocument 763\n\nthink that's right.\n\nis tha\n\nfrom the government\n\nother property records,\n\nwhich we were just getting today because we'r\n\nwith\n\nregistry.\n\nTHE\n\nCOURT:\n\nthis issue that came up.\nI'm happy to show\n\nYou say\n\nFiled 08/10/22\n\nt they want\n\nPage 163 of 197\n\nfrom it; right?\n\nAll\n\nI heard was\n\nt they're now going to object to the\n\nthe Stanhope Mews property records,\n\nWe got them\n\nthey came up.\n\ntrying to deal\n\nfrom the land\n\nthem to the government.\n\nThe whole point of\n\nthis is you want to impeach the witness's testimony as to which\n\nresidence it was; right?\n\nMR.\n\nEVERDELL:\n\nTHE COURT:\n\nto the two different\n\ntestimony coming in,\n\nIs the defense still\n\nthat delays trial?\n\nMR. EVERDELL:\n\nthat one moment.\n\nconfer on\n\nTHE\n\nCOURT: Sure.\n\nMR.\n\nEVERDELL:\n\neven though the sides could argue both sides,\n\nneed additional\n\ngovernment's argument that she didn't\n\ndeposition testimony.\n\nTH\n\nma\n\nCOURT:\n\nThat's the whole point of\n\nthis?\n\nThat's correct.\n\nSo let me just ask, if there is a stip as\n\nis there a need\n\nYour Honor,\n\nYour Honor,\n\nfactual development\n\nproperty ownership records and the depo\n\nfor an additional witness?\n\nseeking an additional witness on Monday\n\nI think we need to just\n\nbecaus\n\nyes, at that point,\n\nwe feel like we\n\nto be able to counter the\n\nreside there based on the\n\nAnd when did you get the depo?\n\nSOUTHERN D\n\nSTR\n\nCT RE\n\nPORTERS, PwC.\n\n(212)\n\n805-0300\n\n2704\n\nDOJ-OGR-00014269\n", "char_count": 1601}, {"efta_number": "DOJ-OGR-00014107", "page_number": 163, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax5\nMR. EVERDELL:\nproduced the depo to us.\nMS. MOE Your\n\nproduced the\n\nnext day, we\n\nthat statement. Of\n\nKinnerton St\n\nDocument 763\n\nFiled 08/10/22\n\nPage 164 of 197 2705\n\ncan't remember when the government\n\nHonor,\n\nCOuUrse,\n\nand it's also a public record.\n\nTHE COURT:\n\nina\n\nany basis it\n\nMS. MOE:\n\njust so\n\nRight.\n\nthe record is clear,\n\ndoesn't come in.\n\nYour Honor,\n\nit's Ms.\n\nI mean,\n\nthis last minute registry issue.\n\ndefense counsel is arguing they need\n\nrebut an inference\n\nonly because the def\n\nns\n\nhappy to just\n\nreason that\n\nbecause the defens\nMR. EVERDELL:\nwilling to stip to just\n\nfrom the government,\nis put\nrest here and no\nthere is a purported need\n\n1s invitin\n\nYour 4H\n\nputtin\n\nthe title ownership without\n\nwilling to do that,\n\nthey're going\n\nth\n\nttin\n\nwe won't n\n\nto put in the deposit\n\need\n\non Friday evening,\ntreet records to the government.\n\nproduced the deposition in which Ms.\n\nMaxwell's\n\nThe question is\n\nwith respect to\n\nit's only being of\n\nit comes in.\n\nthe defense\nThe\nMaxwell made\n\nown deposition\n\nI don't see\n\nthe deposition,\n\nFered to rebut\n\nto call\n\nI want\n\nmake this an issue at all.\n\nfor this\n\nThere is no -- to\n\nthis witness\n\ng this at issue.\n\nthe extent\n\nto\nto be clear it's\nWe would be\nThe\n\nis, again,\n\nthis issue at this late hour.\n\nonor, if the government is\n\ne deposition transcript,\n\ng in the property records showing\n\nwe're\n\nthe extra witness. If\n\ntion transcript and make that\n\nfeel lik\n\nan issue, we\n\ncounter that.\n\nneed th\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORTERS, P.\n\n(212)\n\n805-0300\n\nother witness to be able to\n\nDOJ-OGR-00014270\n\n", "char_count": 1715}, {"efta_number": "DOJ-OGR-00014107", "page_number": 164, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax5\n\nTH\n\nma\n\nCOURT:\nback, you'll\n\nWhat do w\n\ntell me,\n\nDocument 763\n\nWell,\n\nhav\n\nboth sides,\n\nyou'll discuss it and when\n\nwhat the\n\nafter lunch?\n\nMR.\n\nuse the lunch break to hammer out the\n\nEVERDELL:\n\nYour Honor,\n\nfinal\n\nFiled 08/10/22\n\nPage 165 of 197\n\ncome\n\napplication is.\n\n[ think we would like to\n\nstipulations. If\n\nwe can have extra\n\nto be it, is\n\ndocuments,\nbreak.\n\nTHE\n\nCOURT:\n\nare available today\n\ntime to get\n\nthe reading of\n\nthat done,\n\nthe s\n\ntipulations.\n\nI think that's going\n\nTher\n\nar som\n\nSo basically no other defense witnesses\n\nfollowing stips.\n\nquestion,\n\nrebuttal, rebuttal,\n\ntiming of residence on Monday.\n\nis the def\n\nns\n\nrebuttal on points,\n\nAnd then the open\n\nseeking to have potentially this\n\ndefense's application --\nI don't —-\nMS. MENNINGER:\nTHE COURT: [ mean,\nMR. EVERDELL: Yes.\nconferral,\n\nbe an issue,\n\nTHI!\n\nGI\n\nCOURT:\n\nthere is a conferral to be had on the Kelly issue,\n\nyour Honor.\n\nI did ask\n\nt was sent,\n\nyour\n\nthe question is,\n\nWhy don't we\n\nYou'll confer on that.\n\nI don't know when even if\n\nthe witness regarding\n\nthe\n\nHonor.\n\nto what end.\n\nsee about the\n\nwe'll see how that process goes and maybe it won't\n\nI don't know if\n\nbecause\n\ngoing to spend my remaining lunch hour looking at this\nmaterial. Seems to me, best case scenario is if agree with\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\n2706\n\nbut these are things we have to go through over the\n\nfor a proposed order because\n\nDOJ-OGR-00014271\n", "char_count": 1586}, {"efta_number": "DOJ-OGR-00014107", "page_number": 165, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHCmax5\n\nthe order,\n\nproduced today,\n\nDocument 763\n\nMS. MENN\n\nNGER:\n\nbe if\n\ndon't have time.\n\nbreak, so that's 2:\n\nin there of\n\nshe's not prod\n\nBut given\n\ncontinuance\n\n30, it's\n\nfor\n\nwitness's appearance.\n\nTHE\n\nCOURT:\n\nAnything else?\n\ntwo and a halt\n\npurposes of\n\nshe's not produced Monday,\n\nuced by Monday morning,\n\nFiled 08/10/22\n\nthink, your Honor,\n\nthen,\n\nit goes to the marshals and then what?\n\nPage 166 of 197 2707\n\nShe's not\n\nthen what?\n\nour intent would\n\nyou know, we\n\nthat it's 1:30 and there is a lunch\n\nfF hours with a break\n\ntrying to get the\n\nyour Honor.\n\nT'll look at the materials.\n\nThank\n\nThank you.\n\nMS. MOE: Not from the government,\nyou.\n\nTHE COURT: Anything else?\n\nMR. EVERDELL: No, your Honor.\n\nTHE COURT: It will be a long break\nwe'll resume in 45. Okay?\n\nMS. MOE: Yes, your Honor.\n\nMS. MENNINGER: Your Honor, if\n\nthese stipulations,\n\ngovernment's available to\n\nfor the jury,\n\nbut\n\nwe had time to work on\n\nan hour might make sense,\n\nmeet.\n\nthe\n\nbut only if\n\nTHE COURT: I'll give you an hour. It just means the\njury is sitting there for an hour and a half at this point.\nAll right. I'll meet with you in an hour, 2:30.\nI'm sorry. One more thing. Ms. Sternheim, when we\nreturn from lunch, I would intend to allocute Ms. Maxwell on\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212%) 805-0220\n\nDOJ-OGR-00014272\n", "char_count": 1463}, {"efta_number": "DOJ-OGR-00014107", "page_number": 166, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763\n\nLCHCmax5\n\nher right to testify or not testify.\n\nMS. STERNHEIM:\n\n(Recess)\n\nYes.\n\nFiled 08/10/22\n\nThank you.\n\n(Continued on next page)\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nLD\n\nPage 167 of 197 2708\n\nDOJ-OGR-00014273\n\n", "char_count": 381}, {"efta_number": "DOJ-OGR-00014107", "page_number": 167, "text_content": "=\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nI\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX6\n\nTHE\n\nMs.\n\nMS.\n\nCourt's indulgenc\n\nand I\n\nas a result.\n\nSo we very much apprecia\n\nwith the parties.\n\nThere is one issue that\nwanted to raise that we were not\nwould propose that we have\n\ndepending on the result of\n\nthe case up.\n\nTHE\n\nHow\n\nMS.\n\nCOURT:\n\nlong will the reading of\n\nCOMEY :\n\nTHE\n\ntalking an hour,\n\nCOURT:\n\ntha\n\nI believ\n\nthe d\n\nfens\n\nDocument 763 Filed 08/10/22 Page 168 of 197 2709\nAFTERNOON SEs Ss ION\n3:15 P.M.\n\nCOURT: Okay. We have a few things to take up.\nComey.\nCOMEY: Yes, your Honor. We appreciate the\n\nWe've reached a number of stipulations,\n\nbelieve we'll be able to finish the case this afternoon\n\nte the Court's patience\n\nstill\n\nOkay.\n\ntha\n\nAll right.\n\nTen to 15 minutes,\n\nOh,\n\nokay.\n\nSo I\n\nable to reach agreement on.\n\nstips take?\n\nt argument now and then,\n\nthink we can proceed to wrap\n\nyour Honor.\n\ndidn't know 1f£ we were\n\nin which case my suggestion was going to be\n\nlet's do that and then give the jury a break and then finish,\nbut okay. I'll hear the issue.\n\nMs. Menninger.\n\nMS. MENNINGER: Thank you, your Honor.\n\nAs your Honor is aware from prior proceedings in this\ntrial, one of the facts about which there is dispute involves\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014274\n\n", "char_count": 1374}, {"efta_number": "DOJ-OGR-00014107", "page_number": 168, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHVMAX6\n\nDocument 763 ‘Filed 08/10/22 Page 169 of 197 2710\n\nthe date on which Je\n\nrey Epstein began living at 9 East 71st\n\nStreet. Jane contended that she went to only one home over th\n\nyears, she was 14, 15, and 16. Those ar\n\nthe years 1994\nthrough 1996.\n\nseveral\n\nWe ask the Court to take judicial notice of\n\nEvidence 201. These relate to\n\ndocuments under Federal Rule of\n\na case in this district, in this courthouse, United States\n\nThe case\n\nDistrict of New York.\n\nfor the Southern\n\nDistrict Court\n\nnumber is 96 CV 8307,\n\nDenny Chin was the presiding judge, now\n\nSecond Circuit justice. It was United States of America --\n\nTHE COURT: Just a judge. Second Circuit judge.\n\nYou've given him an early promotion.\n\nMS. MENNINGER:\n\nf you could let him know.\n\nUnited States of America v. Jeffrey Epstein and Ivan\n\n1¢e\n\nFisher. It was an action brought by the U.S. Attorney's O\n\nDistrict of New York.\n\nfor the Southern They wer\n\nthe party in\n\ninterest they were the lawyers representing the United\n\nAmerica so the same Southern\n\nStates of in that proceeding,\n\nDistrict of New York o\n\n1Ceé.\n\nIn that proceeding,\n\nEast 69th\n\nprior residence at\n\nGovernment, who had taken pos\n\ngovernment of Iran. And he b\n\n1992.\n\nThe contention in th\n\nthe questions -- Mr. Epstein's\nStreet was leased from the U.S.\nsession of it after -- from the\n\negan a lease in that residence in\n\ne litigation was that he had\n\nSOUTHERN DISTR\n\nCT REPORTERS, P.C.\n\n(212\n\n) 805-0300\n\nDOJ-OGR-00014275\n\n", "char_count": 1599}, {"efta_number": "DOJ-OGR-00014107", "page_number": 169, "text_content": "Case 1:20-cr-00330-PAE Document 763\n\nFiled 08/10/22\n\nPage 170 of 197 2711\n\nLCHVMAX6\n\n1 abandoned living in East 69th in or about January of 1996.\n\n2 Then he leased it to Mr. Fisher, who was a codefendant in the\n\n3 case. And then the U.S. Government sought to evict Mr. Fisher.\n4 So both Mr. Epstein and Mr. Fisher were the defendants in the\n\n5 action.\n\n6 There were, on behalf of Mr. Epstein, two answers\n\n7 filed in the case, answer to cross-claims. These are docket\n\n8 entry numbers 15 and 45 from that action. In the first\n\n9 paragraph of those two answers, Mr. Epstein admitted that in or\n10 about January 1996, he vacated the premises, the premises being\n1] Bast 69th Street. And then subsequent to that, other events\n12 happened.\n13 In an opinion in docket entry 46, Judge Chin issued an\n14 opinion, and he made a finding of fact that Epstein and his\n\n15 family continued to reside at the premises, East 69th, until\n\n16 January of 1996, at which time Epstein abandoned. So that is\n17 an opinion and two answers that we seek to admit under Federal\n18 Rule of Evidence 201, judicial notice.\n\n19 Under the terms of that, your Honor, it is, I believe,\n20 a fact that can be judicially noticed. 201(f) describes what\n21 instructions are given to the jury in the event that it is\n22 criminally noticed; and in a criminal case, the jury is to be\n23 instructed that it may or may not accept the noticed fact as\n24 conclusive. I'm not intending or offering the full documents\n25 that I just cited to your Honor, but the fact of Mr. Epstein's\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014276\n\n", "char_count": 1609}, {"efta_number": "DOJ-OGR-00014107", "page_number": 170, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX6\n\nDocument 763\n\nFiled 08/10/22\n\nPage 171 of 197\n\n2712\n\nadmission that he vacated East 69th in or about January '96,\n\nand then Judge Chin's decision making that finding of fact.\nThere is one other document from that docket that we\n\nseek to admit, but under a separate rule of evidence,\n\n804(b) (1). There was actually a deposition transcript from\n\nMr. Epstein in which he is asked -- and it was taken by the\n\nU.S. Attorney's Office for the Southern District of New York.\n\nAnd he was asked in tha\n\nmoved\n\nStreet\n\nt deposition, Is\n\nin or around\n\nthree times.\n\nAnd Mr.\n\nEpst\n\nfrom the premises\n\nmeaning\n\nthe beginning of\n\n[ believe\n\nit\n\nexactly when.\n\nadmissibl\n\n\"OG?\n\nis around then,\n\nEast 69th -- to 9\n\nbut\n\nit correct that you\n\nBast 71st\n\ntein responded, You asked me that question\n\nI don't know\n\nThis deposition excerpt was appended to a pleading\n\nTHE\n\nCOURT:\n\nMR.\n\nsubstantive point,\n\nStreet\n\nissues we'\n\nI will go\n\nROHRBACH:\n\nb\n\nV\n\nunder 804(b) (1),\nOkay.\n\nYes,\n\nthat was submitted by the U.S.\n\ntheir case at docket number 52.\n\nthrough each of\n\nAttorney's Of\n\nSo\n\nyour Honor.\n\nn talking about.\n\nAnd substantively --\n\nTHE\n\nCOURT:\n\nMR.\n\nROHRBACH:\n\nThis is very much li\n\nMicrophone.\n\nOne at a time,\n\nthe documents,\n\nMr.\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\n(212)\n\n805-0300\n\nBRS, Pes\n\nfice in support of\n\nthe deposition transcript.\n\nI believe that one is\n\nRohrbach.\n\nbut just as a\n\nthis is very much like the 44 Kinnerton\n\nke the 44 Kinnerton\n\nDOJ-OGR-00014277\n", "char_count": 1599}, {"efta_number": "DOJ-OGR-00014107", "page_number": 171, "text_content": "Case 1:20-cr-00330-PAE\nLCHVMAX6\n\nDocument 763\n\nFiled 08/10/22\n\nPage 172 of 197\n\n2713\n\n1 Street documents we've been talking about, in that the legal\n\n2 documents describing when Mr. Epstein abandoned this property\n3 does not reflect where Mr. Epstein was living. As the defense\n4 knows, one of the defense witnesses, who they ultimately\n\n5 decided not to call, would have testified that Epstein was\n\n6 living on East 7J1lst Street prior to 1996.\n\n7 And so if the Court admits this -- this is the reason\n8 this has to go first in the remaining issues. If the Court\n\n9 admits this, the government would put on rebuttal evidence\n10 showing that, in fact, Mr. Epstein lived on 7Jist Street before\n11 he says he abandoned the property in 1996.\n12 So that's sort of a substantive background point.\n13 Moving through the documents, your Honor, Judge Chin's\n14 opinion is a summary judgment opinion. So I think it's quite\n15 clear actually that the facts can reasonably be disputed. The\n16 summary judgment standard, as the Court well knows, is that the\n17 Court -- is that Judge Chin had to take all facts in the light\n18 most favorable to the nonmoving party, which in this case was\n19 not the United States. So I think it very much can be\n20 controverted that the fact in -- the statement in the\n21 background section of Judge Chin's opinion is not a factual\n22 finding about when Mr. Epstein abandoned —--\n23 THE COURT: Can see it?\n24 MS. MENNINGER: What's that, your Honor?\n25 THE COURT: Can see the document?\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212%) 805-0220\n\nDOJ-OGR-00014278\n\n", "char_count": 1577}, {"efta_number": "DOJ-OGR-00014107", "page_number": 172, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX6\n\nMS. MENNINGER: Oh, yes, your Honor. I apologize.\n\nhave copies for\n\nthe Court,\n\nTHE COURT: Okay.\n\nDocument 763 ‘Filed 08/10/22 Page 173 of 197 2714\n\nand I gave a copy to the government.\n\nMR. ROHRBACH: Judge Chin sets out the summary\n\njudgment standard on page 12.\n\nTHE COURT: Yes.\n\nso 201\n\nDo you want to respond to the summary judgment point?\n\n(bob), the Court may judicially notice a fact that\n\nis not subject to reasonable dispute.\n\nMS. MENNINGER: This was the government's motion for\n\nsummary judgment;\n\nand it was Mr. Epstein's admission that\n\nthat's when he vacated th\n\nin terms of tha\n\nanswers and the\n\nto introduce one or the ot\n\npremises. So I don't think that -—-\n\nt's why I think that you need to take both the\n\nsummary judgment together, rather than trying\n\nther. It was the government's\n\nposition that he abandoned in January of '96, and he admitted\n\nthat.\n\nMR. ROHRBACH: The defense is not offering any of\n\nHonor.\n\nMR. RO\n\nHRBACH:\n\nthese documents which contain the government's position, your\n\nMS. MENNINGER: That's not true.\n\nDocket entry 52 is a submission by the government.\n\napologize. I'm talking about the\n\nsummary judgment opinion and the answers, but not the\n\ngovernment's claims,\n\nwhich is not a document -- I'll speak --\n\nSOUTHERN D\n\nSTRICT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014279\n\n", "char_count": 1465}, {"efta_number": "DOJ-OGR-00014107", "page_number": 173, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX6\n\nthe\n\nsummary judgment opinion and\n\nletter,\n\n[ think,\n\nis a sort\n\nDocument 763\n\nFiled 08/10/22\n\nPage 174 of 197 2715\n\nthe answers.\n\nall we have is a summary judgment opinion.\n\nthe basis was\n\nin\n\nwhich Mr.\n\nfor it.\n\nwhat the question was.\n\nwhich applies\n\nwhich is that\n\nAnd I\n\nsuppose\n\nAnd w\n\nto the let\n\nand so there was no reason for the government\nMr. Epstein, in fact,\nresidences.\nWhat mattered in that litiga\nin early 1996, Mr. Epstein made an at\n\nsublet of\nejectment\n\nmatter to the government whether Mr.\n\nthe property;\n\nand back rent\n\ntter and\n\nand so the government was suing\n\nhav\n\nEpstein asserts some\n\nthis was not a material\n\nsom\n\nanswers to cross-clai\n\nof separate matter than the\n\nThos ones wher\n\nak\n\nWe don't know what\n\nfacts to which we don't know\n\nthis brings me to the broader point\n\nEpstein deposition as well,\n\nFact\n\nin that litigation;\n\nfrom Mr.\n\nEpstein.\n\nBut\n\nto litigate when\n\nlived in and was occupying the particular\n\ntion is that at some point\n\ntempt to do an illegal\n\nfor\n\nit did not\n\nproperty in January 1996,\n\nwas no reason\n\nli\n\nlb\n\ntigation.\n\nfore h\n\nfor that\n\nIt just ma\n\nthe background section of\n\nnot a signit\n\nis\n\nactually\n\nabsolute\n\nDecember 1995,\n\nto be litigated in the course of\n\nNovember 1995.\n\nEpstein abandoned the\n\nThere\n\nthat\n\nttered that he abandoned the property\n\nly no reason to\n\ntried to do the illegal\n\nJudge Chin's opinion;\n\nFicant portion of a\n\nfor the same reason,\n\nny of\n\ntake judicial\n\nsublet.\n\nthe other documents.\n\nnotice of\n\nThat's why it's in\nthat's why it's\nThere\n\nit. And\n\nit's not subject to the 804\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014280\n\n", "char_count": 1785}, {"efta_number": "DOJ-OGR-00014107", "page_number": 174, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHVMAX6\n\nhearsay exception.\n\nDocument 763\n\nFiled 08/10/22\n\nPage 175 of 197\n\n2716\n\nMS. MENNINGER: That's not true, your Honor.\n\nIn this litigation, one of the central issues that the\ngovernment -- this same office -- put forth is that\nMr. Epstein's abandoning that property was in violation of the\nlease, which kept him -- which he needed to reside in the\nresidence under the terms of the lease. So it was a central\nfact. It was admitted by Mr. Epstein. It was put forth in\ntheir claims against him, and that is all covered in the\nsummary judgment motion. It was admitted on an answer. It was\n\nthe only admission on that point.\n\nin a deposition.\n\nSO\n\nAnd then it was testified to\n\nI don't think that saying it was not an\n\nissue in the case can possibly withstand scrutiny when you look\n\nat all of\n\nthey said that\ninterviewed this witness,\ncontradic\n\nsaid Mr.\n\nthese.\n\nAlso, the\n\ntion to this.\n\nEpstein wasn't living\n\nthat he was hired in\n\nearly\nrebuttal witness to dispute these documents,\n\ncovered bo\n\n\"96. So\n\nMR.\n\nI don'\n\nth by 201,\n\nROHRBACH:\n\nthey would call to dispute\n\nHe was hired in\n\nthere\n\nDecember of\n\nfactual background about the\n\nthis,\n\nDecember\n\nwitness that\n\nwe've\n\nand his testimony is not at all in\n\nOD «\n\nof He\n\nfir\n\nfor the\n\n'OS,\n\nall\n\nst three weeks\n\nand took possession in\n\nt think there is a basis to call a\n\nof which are\n\nas well as 804(b) (1).\n\nBut as a general point,\n\nThat's not\n\nthere's no ques\n\nSOUTH\n\nERN D\n\nSTR\n\nCT RE\n\nPORTERS, PwC.\n\n(212)\n\n805-0300\n\ntL accurate about this witness.\n\ntion that if\n\nDOJ-OGR-00014281\n", "char_count": 1687}, {"efta_number": "DOJ-OGR-00014107", "page_number": 175, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nit was materi\n\nal that Mr.\n\nin the 69th $\n\non which he s\n\nstarted spending his nights living on 7]\n\nprior to that\n\nTHE\n\n25\n\ntreet home.\n\ntopped living\n\nCOURT:\n\nEpstein st\n\nthere,\n\nmuch\n\nAll right.\n\nseeking admission?\nMS. MENNINGER: Yes, your\nTHE COURT: Forgive me if\nAOE SURE.\nMS. MENNINGER: That's okay.\nZ-9 is the first answer.\n15.\nTHE COURT: Okay.\nMS. MENNINGER: And it wou\nThe same is true of Z-10,\n\nWith respect to Z-7,\n\ncontained on\n\nSentence.\n\nthat's the opinion.\n\npage 4 in the\n\nFirst\n\nFull\n\ntopped living at some point\n\nwas not material the precis\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 176 of 197 2717\nLCHVMAX6\nthey offered evidence like this, the government can and will\ncall rebuttal witnesses to testify about occupancy.\nAs to the point about whether this is a material fact,\n\ndat\n\nless whether he had\n\nHonor.\n\nyou said them before,\n\nld be the\n\nparagraph,\n\nAnd then with respect to Z-8,\n\nthe back of t\n\nhe document.\n\nyour Honor,\n\nIt's paginated page 45 of\n\nlst Street at some point\n\nDo you want to indicate which documents by mark you're\n\nThat was docket entry number\n\nfirst paragraph.\n\nfirst paragraph.\n\nThe\n\nfact is\n\nfirst\n\nit's towards\n\n53, that's\n\nSOUTHERN D\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014282\n\n", "char_count": 1378}, {"efta_number": "DOJ-OGR-00014107", "page_number": 176, "text_content": "Case 1:20-cr-00330-PAE\nLCHVMAX6\n\nDocument 763\n\nFiled 08/10/22\n\nPage 177 of 197\n\n2718\n\n1 where the deposition excerpt was contained.\n\n2 THE COURT: Okay.\n\n3 MS. MENNINGER: And it's on that page 45. It's the\n\n4 first question on that page.\n\ni) THE COURT: All right.\n\n6 I'm sustaining the objection. 201(a) has not been\n\n7 sufficiently established, in light of the posture of the\n\n8 litigation and what was materially in dispute.\n\ny) What's next?\n\n10 MS. MENNINGER: With respect to 804(b) (1), your Honor,\n11 for the deposition excerpt for Mr. Epstein.\n\n12 THE COURT: Okay. Okay. Mr. Rohrbach.\n\n13 MR. ROHRBACH: It is the same objection here, your\n\n14 Honor. Since this is a question about a fact that was the\n\n15 precise -- sorry, let me --\n\n16 THE COURT: It's not the same.\n\n17 MR. ROHRBACH: It's not exactly the same. But let's\n18 look at the language of 804, which is, in order for it to be\n19 offered against a party, the party has to have had an\n20 opportunity and similar motive to develop it.\n21 The government's motive in developing this fact is\n22 completely different than it was in the civil litigation. The\n23 government's motive here is to determine where Mr. Epstein\n24 personally lived. The government's motive in this deposition\n25 was to determine whether he had moved -—- whatever that means —-\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212%) 805-0220\n\nDOJ-OGR-00014283\n\n", "char_count": 1380}, {"efta_number": "DOJ-OGR-00014107", "page_number": 177, "text_content": "=\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\na\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX\n\nfrom on\n\nadvance their claims about\n\nsays,\n\nwas,\n\n6\n\nresidenc\n\nYou asked me\n\nIs it correct\n\nto anot\n\nDocument 763\n\nMS. MENN\n\nNG\n\nthe a\n\nPR:\n\nn\n\ntha\n\nt question\n\nJist in or around the beginning of\n\ntimes.\n\nwhen.\n\nin 1994\n\ntha\n\nCES\n\nthe argument\n\n[ believe\n\nThat's\n\nTHE\n\nCOURT:\n\ntha\n\nthe exact\n\nt you moved\n\nFiled 08/10/22\n\nt ejectment and back rent.\n\nnswer itsel\n\nf, Mr.\n\nPage 178 of 197\n\nther one by a certain date in o\n\nEpste\n\n2719\n\nrder to\n\nin\n\nthree times\n\nfrom\n\n1996?\n\nquestio\n\nWhat was the\n\nMS. MENN\n\nNG\n\nPR:\n\nit\n\nis around th\n\nt's relevant.\n\nAnd the position of\n\nSo I think\n\nNn --\n\nresponse?\n\nen, but\n\nJane was that he was\n\nunder 401,\n\nIt is certainly di\n\nTI don't\n\n. And the gq\n\nthe premises to 9\n\nYou asked me that question thre\n\nknow ex\n\nLiving\n\nit is a question of whet\n\nfferent\n\ntimony —-\n\nDHE COURTS\n\nthat it\n\nthere was a mot\n\nThe fact tha\n\n-- contrary\n\nPR:\n\nruling, that\nMS. MENNING\nHonor. That\ncan offer\njudgment ruling.\nTHE COURT:\nFor\n\nWhat else?\n\nthe same reason,\n\nthan the\n\nt it was asked three times\n\nuestion\n\nBast\n\n©\n\nactly\n\nthere\n\nher\n\nis\n\nto my immediately prior\n\nthis\n\ntive to develop it?\n\nThere was motive to develop it,\n\nwas the whole point of\n\nthe comolaint as well,\n\nOkay.\n\nlitigation.\n\nbut it's in the summary\n\nit's sustained.\n\nSOUTH\n\nERN D\n\nSTR\n\nCT\n\nREPORT\n\nERS,\n\n(212) 80\n\n5-0300\n\nPG ew\n\nDOJ\n\nI mean,\n\nyour\n\n-OGR-00014284\n", "char_count": 1501}, {"efta_number": "DOJ-OGR-00014107", "page_number": 178, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHVMAX6\n\nDocument 763\n\nMR. ROHRBACH:\n\ngovernment, your\n\nHonor.\n\nMS.\n\nCOMEY:\n\nn\n\nhave a number of stipula\n\nNothing else on this\n\nthat case,\n\ntions to\n\nwill be ready to bring the jury back out,\n\nabout 10 or 15 minutes,\n\nOkay.\n\nyour\n\nfinali\n\nat which point\n\nie)\n\nf evidence will be complete.\n\nfe)\nTHE COURT:\nrecord, the withdrawal\nwarrant for the witness Kelly,\nsubpoena.\nMS. MENNINGER:\n\ndiscussions are\n\nYes,\n\nSo\n\nwho hasn't responded to\n\nyour Honor.\n\nFiled 08/10/22\n\nI got the note,\n\nP\n\nage 179 of 197 2720\n\nHonor,\nze, and\n\nand 11\n\nI think\n\nf the request to issue an arrest\n\nPare\n\nthat we would wrap up today.\n\nyour Honor.\n\nTHE COURT: [ know.\nemail. Is that application withdrawn?\nMS. MENNINGER: Yes,\nTHE COURT: To be clear,\nMS. MENNINGER:\narrest Kelly Bovino\nTHE COURT: Okay.\n\nissues that\n\non Monday?\n\nThat's exactly right,\n\nOkay.\n\nWe are working out\n\nwould also not necessitate the wit\n\nyour\n\nthen\n\njust\n\nt a resolution of\n\nCNess\n\nfrom the\n\nI think that we\n\nI think we\n\nt should take\n\nthe presentation\n\nfor the\n\nthe\n\nthe\n\nof\n\nBut you sent my chambers an\n\nwhich application is that?\nThe application to have the marshals\n\nfor nonappearance on her subpoena.\n\nfrom London\n\nHonor.\n\nAnd it would mean that there would be no\n\nMS. COMEY:\nTHE COURT:\nMS. COMEY:\n\nSOU\n\nTH\n\nE RN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\nLD\n\n(212)\n\n805-0300\n\nDOJ-OGR-00014285\n", "char_count": 1477}, {"efta_number": "DOJ-OGR-00014107", "page_number": 179, "text_content": "N\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHVMAX6\n\nDocument 763\n\ngovernment rebuttal case as well.\n\nTH\n\nMS.\n\nCOMI\n\nE COURT:\n\neal\nKe\n\nTHE\n\nMS.\n\nthe case.\n\nTH\n\nma\n\n@\n=\n\n<\nGd\nKe\n\nCOURT:\n\nFiled 08/10/22 Page 180 of 197 2721\n\nAnd no government rebuttal.\n\nNo government rebuttal case.\n\nOkay.\n\nThe parties have reached consensus to end\n\nOkay.\n\nWhile you're working,\n\nthe allocution?\n\nAll right.\n\nMs. Sternheim, are you ready for\n\nMS. STERNHEIM: am.\n\nTHE COURT: Okay.\n\nT'll ask Ms. Maxwell and Ms. Sternheim to stand.\n\nMs. Maxwell, I want to make sure you understand that\nyou have the right to testify in your own defense. You also\nhave the right not to testify.\n\nIf you decide not to testify, I will instruct the jury\n\nthat they may not draw any inf\n\ndecision, a\n\nnd\n\nI wan\n\nwhether to\n\nto the best advice of\n\ntes\n\nbut the decision is yours.\n\nMs.\n\nMaxwell,\n\nTH\n\nED\n\nEFENDANT:\n\nYour\n\nthat fact may not enter into\nt to make sure that you know\n\ntify or not is your decision.\n\nference against you based on that\n\ntheir deliberations.\n\nthat the decision\n\nYou are entitled\n\nyour attorneys in making this decision,\n\ndo you understand that?\n\nHonor, the government has not\n\nproven its case beyond a reasonable doubt;\n\nand so there is no\n\nSOUTH\n\nE RN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nPG ew\n\nDOJ-OGR-00014286\n\n", "char_count": 1396}, {"efta_number": "DOJ-OGR-00014107", "page_number": 180, "text_content": "=\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\na\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHVMAX6\n\nDocument 763 ‘Filed 08/10/22 Page 181 of 197\n\n2722\n\nneed for me to testify.\n\nTHE COURT: All right.\n\nMs. Sternheim, have you discussed the issue with your\nclient?\n\nMS. STERNHEIM: Yes, we hav\n\nTHE COURT: And you've advised her that it is her\ndecision?\n\nMS. STERNHEIM: Yes, we hav\n\nTHE COURT: She's just indicated that her decision is\nnot to testify; is that correct?\n\nMS. STERNHEIM: That is correct.\n\nTHE COURT: Ms. Maxwell, that is correct?\n\nTHE DEFENDANT: Your Honor, that is correct.\n\nTHE COURT: Thank you.\n\nYou may be seated.\n\nMS. STERNHEIM: Thank you.\n\nTHE COURT: All right. Five minutes?\n\nMS. COMEY: Yes, please, your Honor.\n\nTHE COURT: Okay.\n\n(Recess)\n\nTHE COURT: Counsel, are you ready?\n\nMS. COMEY: Yes, your Honor.\n\nTHE COURT: On the defense?\n\nMR. EVERDELL: Yes, your Honor.\n\nTHE COURT: Okay. One thought for Monday. I'm going\n\nSOUTHERN D\n\nSTR\n\nCT REPORTERS, P.C.\n\n(212) 805-0300\n\nDOJ-OGR-00014287\n", "char_count": 1055}, {"efta_number": "DOJ-OGR-00014107", "page_number": 181, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 182 of 197\nLCHVMAX6\n\nto tell the jury to be here at 9, rather than 9:30. We'll take\nas much advantage of the day as we can.\n\nMS. STERNHEIM: Your Honor, the government and I had\nspoken about this. And if it's amenable to the Court -- they\nhaven't spoken yet, but we can talk about this after.\n\nTHE COURT: Okay. Fair enough. Thank you.\n\nAll right. We'll bring in the jury.\n\nMS. COMEY: Yes. Thank you, your Honor.\n\nMS. STERNHEIM: We were going to suggest also\nbeginning at 9. And whether the Court would inquire of the\njury if they would be willing to stay a little later so that we\ncan complete everything on Monday.\n\nTHE COURT: Okay. You don't mean extended time for\ndeliberations, you mean the closings.\n\nMS. STERNHEIM: No, I mean to do the closing\narguments.\n\nTHE COURT: You pushed it off Yes.\n\nMS. STERNHEIM: Closing arguments, rebuttal, charge.\n\nTHE COURT: And what's your best estimate?\n\nWe'll do a shortened lunch too, because we presumably\n\nwon't have issues to work\n\nMS. COMEY:\nargument for Ms.\nrebuttal, it's hard\n\n45 minutes at most.\n\nthrough.\n\nYour Honor,\n\nto estimate.\n\nwe estimate\n\nMoe will be between two and\n\nI doubt it\n\nthat the summation\n\nthree hours. My\n\nwould be more than\n\nSOUTH\n\nCT\n\nERN D\n\nSTR\n\nREPORTERS,\n\n(212)\n\n805-0300\n\nPG ew\n\n2723\n\nDOJ-OGR-00014288\n", "char_count": 1449}, {"efta_number": "DOJ-OGR-00014107", "page_number": 182, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 183 of 197\nLCHVMAX6\n\nTHE COURT: And the defense.\n\nMS. STERNHEIM: It would not exceed the government's\nmain closing argument, and hopefully would be shorter.\n\nTHE COURT: Okay. It will be tight.\n\nSo I'll tell them that we'll start at 9, and that they\n\nshould prepare\n\nfor the possibility of being kept until 5:30?\n\nMS. STERNHEIM: We had proposed 6 o'clock.\n\nTHE COURT: Okay.\n\nMS. COMEY: Obviously, your Honor, we will strive for\nefficiency in our arguments.\n\nTHE COURT: Yes. Okay.\n\n[ will say that. I need to give them an opportunity\nto let Ms. Williams know if that's not possible. I don't know\nif somebody has childcare responsibilities or the like.\n\nMS. STERNHEIM: Understood.\n\nThat's why we wanted to raise it with you now.\n\nMS. COMEY: Yes, your Honor.\n\nTHE COURT: All right. Thank you.\n\nBring in the jury.\n\n(Jury present)\n\nTHE COURT: Members of the jury, thank you so much for\nyour patience. I greatly appreciate it.\n\nMr. Everdell, you may proceed.\nMR. EVERDELL: Thank you, your Honor.\nYour Honor, at this time the parties have a number of\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\n2724\n\nDOJ-OGR-00014289\n", "char_count": 1291}, {"efta_number": "DOJ-OGR-00014107", "page_number": 183, "text_content": "Case 1:20-cr-00330-PAE\n\nDocument 763\n\nLCHVMAX6\n\n1 stipulations that we would like to read for the jury.\n\n2 THE COURT: Go ahead.\n\n3 MR. EVERDELL: The first is an oral stipulation\n\n4 between the parties, and I would like to have Ms. Comey read\n5 that one out to the jury.\n\n6 THE COURT: Okay.\n\n7 MS. COMEY: Thank you, your Honor.\n\n8 The parties have hereby stipulated and agreed that\n9 Government Exhibits 52-K, 52-J, and 52-L are redacted excerpts\n10 of what has been marked for identification as Government\n1] Exhibit 52. And the government would offer those three\n12 exhibits, 52-K, J, and L under seal to protect the privacy of\n13 third parties.\n\n14 MR. EVERDELL: And without waiving our prior\n\n15 objections, no objection, your Honor.\n\n16 THE COURT: All right. 52-K, 52-J, and 52-L are\n\n17 admitted under temporary seal for me to consider limited\n\n18 redactions.\n\n19 MS. COMEY: Yes, your Honor. Thank you.\n20 (Government's Exhibits 52-J, 52-K, 52-L received in\n21 evidence)\n22 MR. EVERDELL: Your Honor, we have another oral\n23 stipulation agreed to by the parties.\n24 The parties hereby stipulate and agree that Annie\n25 Farmer's boots were seized by the FBI on June 29th, 2021.\n\nFiled 08/10/22 Pa\n\nge 184 of 197\n\nSOUTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nBRS, P.\n\n(212)\n\n805-0300\n\nDOJ-OGR-00014290\n", "char_count": 1288}, {"efta_number": "DOJ-OGR-00014107", "page_number": 184, "text_content": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 185 of 197 2726\nLCHVMAX6\n\n1 THE COURT: Okay. Thank you.\n\n2 MR. EVERDELL: We have another oral stipulation.\n\n3 The parties hereby stipulate and agree that Mike\n\n4 Wallace's date of birth is May 9th, 1918.\n\n5 THE COURT: Thank you.\n\n6 MR. EVERDELL: We have one more oral stipulation.\n\n7 The parties hereby stipulate and agree that The Lion\n\n8 King, the Broadway musical, opened in previews at the New\n\n9 Amsterdam Theater in New York City on October 15th, 1997, with\n10 the official opening on November 13th, 1997.\n11 THE COURT: Okay.\n12 MR. EVERDELL: And your Honor, we have some written\n13 stipulations now, which I would like to read to the jury.\n14 THE COURT: Okay.\n15 MR. EVERDELL: First, it is hereby stipulated and\n16 agreed by and among the United States of America, by Damian\n17 Williams, United States Attorney for the Southern District of\n18 New York, and Maurene Comey, Alison Moe, Laura Pomerantz, and\n19 Andrew Rohrbach, Assistant United States Attorneys, of counsel,\n20 and defendant Ghislaine Maxwell, by and with the consent of her\n21 attorneys, Christian Everdell, Esquire, Laura Menninger,\n22 Esquire, Jeffrey Pagliuca, Esquire, and Bobbi Sternheim,\n23 Esquire, that:\n24 The witness referred to as Kate and her counsel\n25 attended a meeting with the government prosecutors on September\n\nSOUTHERN D\n\nSTR\n(212)\n\nCT REPORTERS, P.C.\n805-0300\n\nDOJ-OGR-00014291\n\n", "char_count": 1429}, {"efta_number": "DOJ-OGR-00014107", "page_number": 185, "text_content": "=\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\na\nco)\n\na\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHVMAX6\n\nDocument 763\n\n3rd, 2021. At tha\n\ngovernment prosecu\n\napplication for a\n\nstatus.\n\nt meeting,\n\nU visa,\n\nFiled 08/10/22\n\nPage 186 of 197 2727\n\nKate's counsel provided the\n\ntors with a partially completed visa\n\nand asked to discuss Kate's visa\n\nstipulation marked\nevidence at trial.\n\nparties.\n\nas De\n\nIt is further stipula\n\nfense\n\nExhibit A-1\n\n(Continued on next page)\n\nSOU\n\nIt's dated today's date,\n\nTHERN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nLD\n\nted and agreed that this\n\nmay be received in\n\nsigned by the\n\nDOJ-OGR-00014292\n\n", "char_count": 674}, {"efta_number": "DOJ-OGR-00014107", "page_number": 186, "text_content": "Case 1:20-cr-00330-PAE Document 763 _ Filed 08/10/22 Page 187 of 197 2728\nLCHCmax7\n\n1 MS. COMEY: No objection, your Honor.\n\n2 THE COURT: A-1 is admitted.\n\n3 (Defendant's Exhibit A-1l received in evidence)\n\n4 MR. EVERDELL: Your Honor, I now have A2.\n\n5 THE COURT: And you could you skip the preface and\n\n6 say, between the parties.\n\n7 MR. EVERDELL: Sure, your Honor.\n\n8 THE COURT: Thank you.\n\n9 MR. EVERDELL: It is hereby stipulated and agreed by\n10 and among the parties that, if recalled as a witness, Dominique\n11 Hyppolite would testify as follows: The Palm Beach County\n12 school maintains school records in the ordinary course of\n13 business.\n\n14 The document marked Defense Exhibits DH1, DH2, and DH3\n15 are each a true and accurate copy of Palm Beach County school\n16 records for Virginia Robertson.\n\n17 The document marked Defendant's Exhibit J2 is a true\n18 and accurate copy of Palm Beach County school records for the\n19 witness identified as Jane.\n\n20 t is further stipulated and agreed that Defense\n\n21 Exhibits DH1, DH2, DH3, and J2, and this stipulation marked as\n22 Defense Exhibit DH4, may be received in evidence at trial.\n\n23 And it's dated today's date, signed by the parties.\n24 MS. COMEY: No objection. The government would\n\n25 request that Exhibit J2 be accepted under seal consistent with\n\nSOUTHERN D\n\nSTR\n\nCT RE\n\nPORTERS,\n\n(212)\n\n805-0\n\n300\n\nPG ew\n\nDOJ-OGR-00014293\n\n", "char_count": 1392}, {"efta_number": "DOJ-OGR-00014107", "page_number": 187, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHCmax7\n\nDocument 763\n\nthe Court's prior order.\n\nTHE\n\nak\n\nCOURT: DH1, DH2,\n\nDH3,\n\nFiled 08/10/22 Page 188 of 197 2729\n\nand DH4 are admitted. J2\n\nis admitted under seal with the opportunity to propose a narrow\n\nredaction.\n\nExhibits\n\n(Defendant's\n\nin evidence)\n\nMR. EVERDELL:\n\ncopies for the Court if\nTHE COURT: It's okay.\nMR. EVERDELL: Yes, your\n\nWe have A5 now,\n\nDHE COURT:\n\nOkay.\n\nMR. EVERDELL: It\n\nand among the parties that the HM\n\ngovernmental authority in the Unit\n\nofficial public records relating\n\nDH1,\n\nThat's correct,\n\nto the ownership of\n\nJ2 received\n\nDH2, DH3, DH4,\n\nAnd I have\n\nyour Honor.\n\nyou want me to hand those up now.\n\nT'll take them after.\n\nHonor.\n\nyour Honor.\n\nis hereby stipulated and agreed by\n\nLand Registry is the\nted Kingdom that maintains\n\nland and\n\nproperty located in the United Kingdom.\n\nExhibit MG12 are\n\nDefense\n\nproperty located at 69 Stanhope Mews\n\ndocuments relating to the\n\nEast, London SQ750T,\n\nUnited Kingdom, that were retrieved from the HM Land Registry\non March 26th, 2021.\n\nDefense Exhibit MGl are documents related to the\nproperty located at 44 Kinnerton Street, London, SW1XHES,\nUnited Kingdom, that were retrieved from the HM Land Registry\non December 13th, 2021.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014294\n\n", "char_count": 1421}, {"efta_number": "DOJ-OGR-00014107", "page_number": 188, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax7\n\nPages\n\naccurate copy of\n\ndated January 21\n\nof\n\nthe property located at 69 Stanhope Mews\n\nUnited Kingdom.\n\nPages 4\n\nSs\n\nae A\n\naccurate copy of\n\nda\n\nAnthony John Je\n\nlocated at 69 Stanhope Mews\n\nKingdom, a\n\nMarion Maxwell.\n\nted April 24th,\n\nDocument 763\n\nto 3 of\n\nde\n\n1994,\n\nto 6 0\n\nthe HM Land Registry of\nconfirming th\n\nGhislaine Noelle Marion Maxwell as of\n\nDe\n\nthe HM\n\n1995,\n\nts as of\n\ncon\n\nNovember llth, 1988 of\nEast, London, SQ750QT,\nfense Exhibit MG12 is a true and\nLand Registry official public record,\nfirming the registered ownership of\n\nApril 4th,\n\nfter ownership of\n\nfFense\n\nFast\n\nFiled 08/10/22\n\nExhibit MG12\n\nPage 189 of 197\n\nis a true and\n\nficial\n\npublic record\n\nregistered ownership\n\n1995,\n\nof\n\nLondon,\n\nait A\n\nto 2 0\n\nPages\n\naccurate copy of\n\ndated March 20th,\n\nGhislaine Noelle\n\nproperty located\n\n1XATS,\n\nPages 3\n\nLOOT ,\n\naccurate copy of\n\ndated December\n\nof\n\nof\n\nSW1XEHES,\n\nSOUTH\n\nLS\n\nth,\n\nJohn Gerard O'Nea\n\nthe property loca\n\nto 4 0\n\n1 and Nessa O'Neal,\n\nted at 44 Kinnerton Street,\n\nUnited Kingdom.\n\nC\n\nMarion Maxwell as of\n\n1B Bon\n\nUnited Kingdom,\n\nthe HM Land Registry of\n\nbet\n\nconfirming th\n\nSQ75Q0T,\n\nthe property\n\nUnited\n\nsaid property by Ghislaine Noelle\n\nficial\n\nDefense Exhibit MGl is a true and\nthe HM Land Registry official public record,\nonfirming the registered ownership of\nMarch 20th, 1997, of the\nat 44 Kinnerton Street, London, Southwest\nDefense Exhibit MGl is a true and\n\npublic record\n\nas of\n\nFore ownership of\n\nregistered ownership\n\nJune 30th, 1986,\nLondon\n\nsaid property by\n\n=\n\n(RN\n\nD\n\nSTR\n\nCT REPORT\n\n(212)\n\n805-0300\n\nBRS, P.\n\n2730\n\nDOJ-OGR-00014295\n", "char_count": 1741}, {"efta_number": "DOJ-OGR-00014107", "page_number": 189, "text_content": "=\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nI\n=\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 190 of 197 2731\nLCHCmax7\nGhislaine Noelle Marion Maxwell.\n\nIt is further stipulated and agreed that Government\nExhibit 610A is a fair and accurate copy of selected pages from\na transcript of a deposition of Ghislaine Maxwell on April 9th,\n2019.\n\nIt is further stipulated and agreed that Defense\nExhibit MG12, Defense Exhibit MG1, Government Exhibit 610A, and\nthis stipulation marked as Defense Exhibit Ab may be received\n\nin evidenc\n\ne at trial.\n\nIt's dated with today's date and signed\n\nby the parties.\n\nMS. COMEY: No objection, your Honor.\n\nTHE COURT: Great. Defense MG12, MG1l, and ASD are\nadmitted, and GX610A is admitted.\n\n(Defendant's Exhibits MG12, MG1, A5 received in\nevidence)\n\n(Government's Exhibit 610A received in evidence)\n\nMR. EVERDELL: Correct, your Honor.\n\nI believe this is the final stipulation, A6, your\nHonor.\n\nTHE COURT: Go ahead. Thank you, Mr. Everdell.\n\nMR. EVERDELL: It is hereby stipulated and agreed by\n\nand among\nGlassman,\npseudonym\n\nThe notes\n\nthe parties\n\ncounsel for\n\nJane, spoke\n\nthat on August 17th,\n\nby phone wit\n\nthe witness testifying\n\nthe call\n\nof re\n\nFlect that Glassman s\n\nSOUTHERN D\n\nSTR\n\nCT RE\n\n(212)\n\n805-0300\n\n2021,\n\nRobert\n\nusing the\n\nth a prosecutor in this case.\n\nPORTERS, P.\n\ntated that before\n\nDOJ-OGR-00014296\n", "char_count": 1427}, {"efta_number": "DOJ-OGR-00014107", "page_number": 190, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHCmax7\n\nDocument 763\n\nthe government charged th\n\nGlassman whether to cooperate with the case,\nconversations,\n\ndiscussed wit\n\nmoral\n\nly righ\n\ntes\n\nti\n\nGla\n\nth Jan\n\nt thin\n\nfying a\n\nmen\n\ncase,\n\nIt\n\ntioned that Gla\n\nis\n\nt tria\n\nunquote.\n\nssman had advised Jane to cooperate,\n\nCas\n\nFiled 08/10/22\n\nPage 191 of 197 2732\n\n, Jane had discussed with\n\nand during those\n\nand\n\ne that cooperating with the case was the\n\ng to do,\n\nand they had discussed how\n\nGlassman also\n\nl was the right thing to do.\n\nssman had told Jane it would, quote,\n\nhelp her\n\nfurther stipulated and agreed that this\n\nstipulation,\n\nmarked as\n\nevidence at trial.\n\nthe parties.\n\nAnd it\n\nDef Exhibit\n\nense A6é, may be received in\n\n\"s dated with today's date, signed by\n\nMS. COMEY: No objection.\n\nTHE COURT: A6 is admitted.\n\n(Defendant's Exhibit A6 received in evidence)\n\nMR. EVERDELL: May I have a moment, your Honor?\n\nTHE COURT You may.\n\nMR. EVERDELL: Your Honor, those are all the\nstipulations.\n\nTHE COURT: Go ahead, Ms. Sternheim.\n\nMS. STERNHEIM: Thank you, Judge. At this time, the\ndefense rests.\n\nTHE COURT: Ms. Comey.\n\nMS. COMEY: The government has no further case, your\nHonor.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00014297\n\n", "char_count": 1356}, {"efta_number": "DOJ-OGR-00014107", "page_number": 191, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\n_\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE Document 763 _ Filed 08/10/22 Page 192 of 197 2733\nLCHCmax7\n\nTHE COURT: All right. Thank you.\n\nMembers of the jury, that closes th vidence portion\nof the trial.\n\nLet me tell you what comes next.\n\nClosing arguments are summation by the parties. Both\n\nsides will have an oppor\n\nconsider.\n\nyou'll\n\nFollowing that,\n\ntunity to summarize\n\nyour deliberations.\n\nfor you their view\nof the evidence in the case and the arguments they wish you to\nT'll instruct you as to the law that\n\nfollow during your deliberations and then you'll begin\n\nMonday, I'm going to ask that we start at 9:00 a.m.\ninstead of 9:30. And I want you I believe we'll finish at\nour normal time, but there is a possibility that, just to get\nthrough what we need to do on Monday, we may go a little bit\nlater. So I'm going to ask you to arrange to be here as late\nas 6:00 p.m. If that is a problem, on your way out tonight,\n\nlet Ms.\n\nto my promise to the schedule,\n\nas late as 6:00 on Monday,\n\nWilliams know, and we won't do that.\n\nbut if\n\nthat might\n\ncan get done what we want to do in one day.\n\nSo again,\n\nclosing arguments, their\n\nto the law, and then th\n\nMonday,\n\n9:00 a.m.,\n\nsummations, then\n\nSo 9:00 a.m. on\n\nMonday is a hardship,\n\nplease\n\neverybody is able\n\nhelp us ensure that\n\nI want to stick\n\nLO Stay\n\nwe\n\nthe parties will do their\n\nI'll instruct you as\n\ndeliberations will begin.\n\nMonday.\n\nlet Ms.\n\nstaying until 6:00 on\n\nWilliams know on your way\n\nSOUTHERN D\n\nSTRICT REPORTERS,\n\n(212) 805-0300\n\nPG ew\n\nDOJ-OGR- 00014298\n\n", "char_count": 1635}, {"efta_number": "DOJ-OGR-00014107", "page_number": 192, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\n\nLCHCmax7\n\nDocument 763 ‘Filed 08/10/22 Page 193 of 197 2734\n\nout and we'll end at our normal time.\n\nI'm going to let you go for the weekend and the day\n\ngiven where we are in the trial.\n\nI want to just take a couple moments to really\nemphasize how important it is, of course, that you continue to\nfollow all of my instructions. Even though we're at this\n\ndifferent phase of the case, no communications with each other\n\nor anyone else through any means about the case. No consuming\n\nany information about the case through any means. Continue to\n\nkeep an open mind until you hear the summation -- the closing\n\narguments of the parties,\n\nmy instructions as to the law, and\n\nyou begin your deliberations as a jury. It's vitally important\n\nthat those rules continue to be followed all the way through.\n\nI'm very grateful\n\nfor your patience today and\n\nthroughout. I wish you a very good and safe weekend. Please\n\nbe cautious out there.\n\nMonday at 9:00. And I\n\nThank you.\n\nhop\n\nI want to see everybody back here\n\ne you have a wonderful weekend.\n\n(Continued on next page)\n\nSOUTHERN D\n\nSTRICT REPORTERS, P.C.\n\n(\n\n212) 805-0300\n\nDOJ-OGR-00014299\n\n", "char_count": 1276}, {"efta_number": "DOJ-OGR-00014107", "page_number": 193, "text_content": "be\n\nN\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHCmax7\n\nDocument 763 ‘Filed 08/10/22\n\n(Jury not present)\n\nTHE COURT:\n\nak\n\nMa\n\nyou're curious. I want\n\ntters to take up.\n\nOh,\n\nto give it just one more read.\n\nPage 194 of 197\n\nthe charge,\n\nhaven't had time to do that today given the issues that\n\noccupied the Lunch break.\n\nhave a copy of my dr\n\nwe'll meet at 9:00 a.m. here\n\ntomorrow.\n\nMS. MOE:\n\nGI\n\nJust on a separate housekeeping\n\njust wanted to flag,\n\naft charge and the drat\n\nThank you, your Honor.\n\nI would say by 6:00 p.m., you'll\n\nfor the charging conference\n\nmatter, your Honor,\n\ngiven the number of issues we're trying\n\nstreamline and resolve today and yesterday,\n\nchance yet to discus\n\nmake sure we iron that out so we make sure w\n\nMonday morning.\n\nevening to make sur\n\ns logistics for closing,\n\nwe haven't had a\n\nbut we want to\n\nVe\n\nI wanted to flag that we'll\n\n‘re ready to go\n\nconfer this\n\nscreens and the like\n\nWw\n\non the same pag\n\non logistics and\n\nWould the Court prefer that we reach out about a\n\nproposal about how that should be arranged?\n\nsure we're not causing\nTHE COURT:\nstaff to make sure you\n\ndispute do you need\n\nMS. MOE:\n\ncourthouse staff we should reach o\n\nto\n\nraise it with me.\n\nTI want to make\n\nany delay on Monday morning.\n[ mean, I think confer with the court\nhave what you need. Only if there is\n\ns there anyone in particular within the\n\nSOUTH\n\nE RN\n\nD\n\nSTRICT REPORTERS,\n\n(212) 805-0300\n\nLD\n\nut to about logistics?\n\nDOJ-OGR\n\n2735\n\nI bet\n\nFt verdict sheet and\n\nto\n\non\n\na\n\n-00014300\n", "char_count": 1603}, {"efta_number": "DOJ-OGR-00014107", "page_number": 194, "text_content": "be\n\nN\n\n(ee)\n\nws\n\nOo\n\nOY\n\n~]\n\n(oe)\n\nKe}\n\na\nca)\n\nhe\nbe\n\nN\n\nWw\n\nKB\nws\n\nOo\n\n_\nOY\n\na\n~]\n\na\noO\n\na\nKe)\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nCase 1:20-cr-00330-PAE\nLCHCmax7\n\nTH\n\nFA\n\nCOURT:\n\ndepends what it is.\n\nDocument 763\n\nStart with Ms.\n\nWe'll have some staff\n\nthe charging conference,\n\nbut Ms.\n\nmatter what over th\n\nMS. MOE:\n\nGI\n\nWw\n\nkend and she can direct tra\n\nwanted to work that out in advance.\n\nTHE COURT:\n\nMS. STERNHE\n\nM:\n\nreiterate and renew our mot\n\nTHE COURT:\n\na\n\nthe charging conference.\n\nAnything else\n\nMS. MOE: Not\n\nWith\n\nyou.\nMR. EVERDELL: Not from the det\nTHE COURT: [ thank everyone.\n\n9:00. You'll get the charge as soon as\n\n(Adjourned to\n\nDecember 18,\n\ntion pursuant\n\nthat reserval\n\nThank you.\n\nJudge, at this\n\nFiled 08/10/22\n\nWilliams.\n\nPage 195 of 197 2736\n\nI guess it\n\nhere tomorrow for\n\nto take up?\n\ntion,\n\nfrom the government,\n\nThank you very much, your Honor.\n\ntime,\n\nto Rule 29.\n\nWilliams will be reachable no\n\n1G ws\n\nJust\n\nwe would\n\nwe can proceed to\n\nyour Honor. Thank\n\nFense,\nT'll s\n\nI can,\n\n* ok O*\nSOUTHERN DISTRICT REPORTERS,\n(212) 805-0300\n\nyour Honor.\n\nLD\n\nveryone at\nbut by 6:00.\n\n2021 at 9:00 a.m.)\n\nDOJ-OGR-00014301\n\n", "char_count": 1135}, {"efta_number": "DOJ-OGR-00014107", "page_number": 195, "text_content": "be\n\nNO\n\nCase 1:20-cr-00330-PAE Document 763 Filed 08/10/22\n\nExamination of:\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\nhe\nbe\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nJASON RICHARDS\n\nDirect By Mr.\n\nCross By Ms.\n\nRedirect\n\nBy Mr.\n\nAMANDA YOUNG\n\nCross By Ms.\n\nRedirect\n\nDirect By Ms.\n\nBy Ms.\n\nEVA ADNI\n\nGd\n\nDirect By Mr.\n\nRSSON\n\nCross By Ms.\n\nMICHELLE\n\nHEALY\n\nCross By Ms.\n\nDirect By Ms.\n\nNDEX OF EXAMINATION\n\nPagliuca\n\nComey\n\nPagliuca\n\nMenninger\n\nComey\n\nMenninger\n\nDUBIN\n\nPagliuca\n\nMoe\n\nMenninger\n\nComey\n\nSOUTHERN DISTRICT REPORTERS,\n(212) 805-0300\n\nLD\n\nPage 196 of 197 2737\n\nPage\n\n«23593\n-2603\n\n-2604\n\n-2605\n-2619\n\n- 2626\n\n263-2\n\n-2665\n\n-2672\n\n-2682\n\nDOJ-OGR-00014302\n\n", "char_count": 687}, {"efta_number": "DOJ-OGR-00014107", "page_number": 196, "text_content": "=\n\nNO\n\nCase 1:20-cr-00330-PAE\n\nExhibi\n\nWw\n\nws\n\nOo\n\nOY\n\n~]\n\noO\n\nNe}\n\nA\nco)\n\n4\niy\n\nt No.\n\n662-RI\n\nDH1,\n\nMG12,\n\nA6\n\nN\n\nWw\n\n=\nws\n\nOo\n\na\nOY\n\nI\n~]\n\na\noO\n\na\nWO\n\n20\n\n21\n\n22\n\n23\n\n24\n\n25\n\nS27),\n\n610A\n\nDH2,\n\nMG1,\n\nExhibit No.\n\n52-K,\n\nDH3,\n\nA5\n\nDH4,\n\n52-L\n\nDocument 763\n\nJ2\n\nGOV\n\nFiled 08/10/22\n\niFENDANT EXHIBITS\n\nERNMENT EXHIB\n\nTS\n\nSOUTH\n\nPRN\n\nD\n\nSTR\n\nCT REPORT\n\nERS,\n\n(212)\n\n805-0300\n\nLD\n\nPage 197 of 197 2738\n\nReceived\n.20b2\n.2728\noe P29\n~2731\n\n~2732\n\nReceived\n22725\n\n-2731\n\nDOJ-OGR-00014303\n\n", "char_count": 485}]}