EFTA00068582.pdf

120 LBUCmaxl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. 20 CR 330 (AJN) 4 GHISLAINE MAXWELL, 5 Defendant. Jury Trial 6 New York, N.Y. 7 November 30, 2021 8:50 a.m. 8 Before: 9 HON. ALISON J. NATHAN, 10 District Judge 11 APPEARANCES 12 DAMIAN United States Attorney for the 13 Southern District of New York BY: 14 15 Assistant United States Attorneys 16 HADDON MORGAN AND FOREMAN 17 Attorneys for Defendant BY: JEFFREY S. PAGLIUCA 18 CHRISTIAN R. EVERDELL LAURA A. MENNINGER 19 -and- BOBBI C. STERNHEIM 20 -and- RENATO STABILE 21 Also Present: , FBI 22 NYPD Sunny Drescher, 23 Paralegal, U.S. Attorney's Office Ann Lundberg, 24 Paralegal, Haddon Morgan and Foreman 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068582  121 LBUCmaxl (Jury not present) THE COURT: Looks like we have everybody. Matters to take up, counsel. 4 MS. COMEY: Nothing from the government, your Honor. 5 MR. EVERDELL: Nothing, your Honor, but note we have 6 put the folders under the chairs as we agreed yesterday. 7 THE COURT: And the government has seen -- well, I 8 guess you didn't see them, but you are aware of them? 9 MS. COMEY: We have seen the outside of the folders, 10 your Honor. 11 THE COURT: Mr. Everdell, there are two folders. 12 MR. EVERDELL: There is one folder with two documents. 13 THE COURT: One folder with two documents. And then, 14 as we discussed, he'll direct us as necessary to make sure 15 everybody can follow along. 16 I think the only thing I wanted to raise is that, 17 assuming the timing works out, I would like to speak with the 18 juror who had the trip planned, with the court reporter 19 present, of course, to see if there is additional information 20 about the ability to change that plan to make sure it's not 21 weighing on my mind. Without objection to that? 22 MS. COMEY: No objection, your Honor. 23 MR. EVERDELL: No objection, your Honor. 24 THE COURT: So if they're here a little on the early 25 side, I'll do that before, otherwise I'll do it at the break. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068583  122 LBUCmaxl MS. STERNHEIM: Judge, I have an issue I would prefer to raise at sidebar very quickly. THE COURT: Okay. 4 (Continued on next page) 5 (Pages 123 to 125 SEALED) 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068584 EFTA00068585 EFTA00068586 EFTA00068587  126 LBUCmaxl (In open court) THE COURT: I'll note I received a report from the district executive office that, once again, today, everyone 4 who's appearing to watch the trial is being accommodated, 5 either in this court or in the overflow courtrooms. There are 6 empty seats available for everybody who wishes to observe the 7 public trial. 8 With that, anything else before we wait for the 9 jurors? 10 MS. COMEY: No, thank you, your Honor. 11 MR. EVERDELL: No, your Honor. 12 THE COURT: Thank you so much. 13 (Continued on next page) 14 (Pages 127 to 129 SEALED) 15 16 17 18 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068588 EFTA00068589 EFTA00068590 EFTA00068591  130 LBUCmaxl (In open court) THE COURT: I spoke to the juror with the travel plans and the information is that dates can't be changed and they 4 can't cancel and it would be of some significant hardship. The 5 juror is, I think, more concerned about the spouse's reaction. 6 At one point, they did say, "If I have to proceed, I can. I 7 understand." On the other hand, they mentioned some level of 8 distraction and concern. 9 So, I'll hear your suggestion. 10 MR. PAGLIUCA: Your Honor, I understood that the Court 11 was going to -- there were two options the Court was 12 considering. One was seeing if the juror could change plans, 13 and if that didn't work, the Court was considering breaking for 14 the juror's anticipated vacation. That's what I understood the 15 Court to say. 16 If the juror can't change the plans, our preference 17 would be, not frankly that we want to delay the trial, but my 18 preference would be to keep the juror and accommodate the 19 juror's travel plans, your Honor. 20 MS. COMEY: Your Honor, the government's preference 21 would be to keep the trial moving, keep the trial days as 22 scheduled, and excuse the juror if those days become necessary 23 for this case. 24 THE COURT: Just to be clear about what we're talking 25 about. So given the holiday, we're not going to sit the 23rd SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068592  131 LBUCmaxl or the 24th, and it's the weekend, Christmas weekend, 25th, 26th. The juror would be gone the 27th, 28th, would not make sense to return for one day of that week. So, really, it would 4 be a 10-day break in the trial. I don't think that makes 5 sense, Mr. Pagliuca. I know I mentioned that, but I'm not sure 6 I had that fully in mind at the time, and that's practically 7 what we would be talking about. 8 MR. PAGLIUCA: I appreciate that, your Honor. Again, 9 I frankly don't want to delay this trial. The intention here 10 is, first, I don't know which juror this is, and that would 11 make a difference in my analysis here, frankly. 12 THE COURT: I mean, to be candid, that's why I'm not 13 telling you, because -- I'm not telling either side because 1 14 think under the veil of ignorance is a better place for 15 everybody to be. 16 MR. PAGLIUCA: Let me be more specific, your Honor. 17 I'm not asking to know the specific juror, but what would make 18 a large difference to me is whether this person is in the 19 alternate pool versus the main pool of jurors. I would have 20 less of a problem excusing the juror if the juror was in the 21 alternate pool as opposed to the main pool. And the reason 1 22 say that is we carefully exercised peremptory challenges in 23 this case, both to the main pool and the alternate pool. Had 24 we understood that if this juror's plans couldn't be changed, 25 we would have made a different choice while the entire venire SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068593  132 LBUCmaxl was still available and we would have gone with the choice of seating the one juror, the number I don't remember off the top of my head, but the one juror who had dropped off of the 4 alternate pool as opposed to doing something else. That would 5 have been the choice we would have made at that point. 6 THE COURT: But you actually had that option with this 7 information available to you yesterday. The government 8 supported that move of having seven alternates and you declined 9 that option. So even with the information that we might face 10 this issue, you chose not to go that route. 11 MR. PAGLIUCA: But, your Honor, my view, that's 12 because we understood that the Court was not going to excuse 13 the juror. That was my clear understanding. The transcript 14 says whatever it says. 15 THE COURT: Fair enough. It was not with a 10-day 16 pause in the trial in mind, and I suppose the new information 17 is the juror telling me that there is some level of distraction 18 as a result of this concern, which was not what was indicated 19 yesterday when the discussion was that they would make every 20 effort to try to move it. Having apparently now made that 21 effort, they can't move it. 22 MR. PAGLIUCA: I understand, your Honor. I think my 23 position is clear and the Court will do as the Court sees fit. 24 THE COURT: I don't want to do a 10-day break in the 25 middle of the trial. That doesn't make sense. I think, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068594  133 LBUCmaxl really, the option is just to encourage them to take a last shot at any effort to move it, but I think we're going to end up in the same place. I'm wishing we had kept that additional 4 juror. I think I have to excuse the juror. 5 I'll have a discussion in which I just say one more 6 time, is there anything else to explore regarding cancellation 7 or moving it, and if the answer to that is no, I think I will 8 excuse the juror. I'll step down. 9 (Continued on next page) 10 (Pages 134 to 136 SEALED) 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068595 EFTA00068596 EFTA00068597 EFTA00068598  137 LBUCmaxl (In open court) THE COURT: I had an additional conversation with the juror. He was confident there was no way to move it. He said 4 he could cancel it, they would lose money, it was a burden, he 5 was distracted by it, so I had to excuse juror number 58. 6 All our other jurors are here. They're just finishing 7 up settling in. So we can proceed as soon as Ms. 8 brings them out. 9 Anything to take up? 10 MS. COMEY: No, thank you, your Honor. 11 MR. EVERDELL: No, your Honor. 12 THE COURT: I think they'll be ready momentarily. So 13 I'll sit. 14 MS. COMEY: Your Honor, would you like the witness in 15 the witness box? 16 THE COURT: That would be great. Thank you. 17 (Witness present) 18 We need about two more minutes. 19 (Continued on next page) 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068599  138 LBUCmax1 - direct (Jury present) THE COURT: Thank you, members of the jury. I hope you had a pleasant evening. Thank you so much for being here 4 ready to go on time. I greatly appreciate it. We will resume 5 with the direct examination of Mr. 6 Mr. , I remind you are under oath. 7 THE WITNESS: Thank you, your Honor. 8 THE COURT: Ms. Comey, you may proceed. 9 MS. COMEY: Thank you, your Honor. 10 , resumed. 11 DIRECT EXAMINATION CONTINUED 12 BY MS. COMEY: 13 Q. Good morning, Mr. 14 A. Good morning, Ms. Comey. 15 Q. I'd like to pick up where we left off yesterday talking 16 about Mr. Epstein's employees and his office. 17 THE COURT: Ms. Comey, could you adjust the microphone 18 a little bit higher. 19 MS. COMEY: Yes. Thank you, your Honor. Is this 20 better? 21 THE COURT: Yes, that's better. 22 MS. COMEY: Thank you, your Honor. 23 Q. Mr. , I'd like to pick up where we left off 24 yesterday talking about Mr. Epstein's office and his employees. 25 A. Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068600  139 LBUCmaxl - direct Q. Based on your interactions with and observations of Mr. Epstein's employees, where in the hierarchy did Ms. Maxwell fall? 4 A. Ms. Maxwell was number 2. It was definitely Mr. Epstein 5 was a big number 1. 6 Q. What makes you say that Ms. Maxwell was the number 2 in 7 your experience? 8 A. She was the one that pretty much handled most of the 9 finance, my expenses, spending in the office. 10 Q. What, if any, assistants did Mr. Epstein have, other than 11 Ms. Maxwell? 12 A. As far as secretaries or personal assistants, is that what 13 you mean? 14 Q. Personal assistants. 15 A. He had an array of personal assistants, almost like 16 professional shoppers, because there was a lot of items that 17 needed to be purchased for all of the properties that were 18 being acquired. So there were several people that were 19 personal assistants. 20 Q. How about Ms. Maxwell, did she have personal assistants? 21 A. Yes, I would consider Ms. Maxwell a personal assistant. 22 Q. My question was, did Ms. Maxwell have her own personal 23 assistants. 24 A. Oh, I see. Yes, she had assistants, as well. 25 Q. What were the names of some of the personal assistants you SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068601  140 LBUCmax1 - direct remember? A. Throughout the entire or we're talking 1994 to '04? Q. Yes. 4 A. The first one that comes to mind would be 5 Then there was another woman named , the last name 6 escapes me. Those are the two that are coming to mind right 7 away. 8 Q. About when did you meet 9 A. It had to have been the late '90s to my recollection. 10 Q. What did look like between when you first met 11 her and the mid 2000s? 12 A. She looked the same except for different hair lengths and 13 maybe a little different hair color. 14 MS. COMEY: Ms. Drescher, I would like to please pull 15 up for the witness, the parties, and the Court Government 16 Exhibits 327 and 310, please. 17 Q. Mr. , do you recognize these? 18 A. Yes, I do. 19 Q. What are they? 20 A. The photo on the left is Ms. with the green 21 dress. And then to the right in the photo, it's actually a 22 photo of myself at the front of the aircraft. Then there is 23 Mr. Epstein. And that's also in the photo. 24 MS. COMEY: Your Honor, the government offers these 25 two exhibits in evidence. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068602  141 LBUCmaxl - direct MR. EVERDELL: No objection. THE COURT: Government Exhibit 327 and 310 are admitted. You may publish. 4 (Government's Exhibits 327, 310 received in evidence) 5 MS. COMEY: Thank you, your Honor. 6 BY MS. COMEY: 7 Q. While Ms. Drescher puts these up on the screen for the 8 jury, Mr. , could you tell us, for Government Exhibit 9 310, the photo on the right, could you tell us what we see in 10 that photo? 11 A. In that photo, that's the one with the aircraft in it? 12 Q. Yes. 13 A. That appears to be a photo of -- it was probably the late 14 '90s, mid to late '90s, Mr. Epstein purchased that twin engine 15 Cessna 421, and he had a runway at the ranch. So that photo 16 appears to be taken at the ranch at one of the ends of the 17 runway, judging by the square, you know, the asphalt bottom 18 with the square on top there, because it was a dirt runway and 19 at the end of the runway, there was an asphalt base to turn the 20 aircraft around. 21 But in the photo, obviously, it's a picture of me with 22 the luggage and Mr. Epstein and Ms. 23 MS. COMEY: Thank you. We can take that down, 24 Ms. Drescher. 25 I would like to now pull up for the witness, the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068603  142 LBUCmaxl - direct Court, and the parties Government Exhibits 334 and 335, please. Q. Do you recognize these, Mr. A. Yes, I do. 4 Q. Who do we see starting in Government Exhibit 334, the one 5 on the left? 6 A. The one on the left is a picture of Ms. Maxwell and to the 7 right of her is a photo of Ms. 8 Q. How about Government Exhibit 335, who do we see in that 9 exhibit? 10 A. The same, Ms. Maxwell on the left and Ms. on the 11 right. 12 MS. COMEY: Your Honor, the government offers these in 13 evidence. 14 MR. EVERDELL: No objection. 15 THE COURT: Government 334 and 335 are admitted and 16 you may publish. 17 (Government's Exhibits 334, 335 received in evidence) 18 MS. COMEY: Thank you, your Honor. 19 Ms. Drescher, could we please put those up for the 20 jury. We can take those down. Thank you. 21 Q. Mr. , about when do you recall first visiting 22 Mr. Epstein's ranch in New Mexico? 23 A. I believe the ranch -- his ranch was purchased in 24 approximately 1994. I'd call it the mid '90s. 25 Q. About how often did you visit that ranch during your SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068604  143 LBUCmax1 - direct employment with Mr. Epstein? A. I visited that ranch every visit that Mr. Epstein had to the ranch. 4 Q. And about how often did Mr. Epstein go to the ranch? 5 A. It wasn't that often. Certainly not enough. It was 6 probably, maybe five, six times a year. 7 Q. What was that ranch called? 8 A. It was called Zorro Ranch. 9 MS. COMEY: Ms. Drescher, would you please pull up 10 Government Exhibit 328 for the witness, the Court, and the 11 parties. 12 Q. Do you recognize this? 13 A. Yes, I do. 14 Q. What is it? 15 A. That is a photo of the entrance driveway to Mr. Epstein's 16 main property on Zorro Ranch. 17 Q. Is this a fair and accurate depiction of a portion of 18 Mr. Epstein's property in New Mexico? 19 A. Yes, it is. 20 MS. COMEY: Your Honor, the government offers this in 21 evidence. 22 MR. EVERDELL: No objection. 23 THE COURT: Government 328 is admitted and you may 24 publish. 25 (Government's Exhibit 328 received in evidence) SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068605  114 LBUCmax1 - direct MS. COMEY: Thank you, your Honor. Ms. Drescher, could we please show this to the jurors. BY MS. COMEY: 4 Q. While that's up, Mr. , would you please describe the 5 ranch property that Mr. Epstein owned in New Mexico. 6 A. The property in general, the whole -- 7 Q. Yes, please, the whole property. 8 A. The whole property. You started entering the ranch off of 9 Highway 41 in Stanley, New Mexico. So you drove down a dirt 10 road approximately a half mile and you would enter an area 11 which the ranch called the Ranch Central, and that housed many 12 buildings. 13 Just to the left, there were two homes, and that was 14 mainly for the ranch staff that lived on the ranch for support. 15 So there were two homes to the left. To the right, there was a 16 small office for the ranch. And then you continued, you're 17 still in the Ranch Central area. And then you went still 18 further into the ranch, probably a hundred feet. 19 And then on the right side, there was a building that 20 had rooms, there was approximately five bedrooms with a western 21 motif on the outside. And that would be for whether it be, 22 the -- any of the guests that would have came on the aircraft 23 to stay, the chef, the pilots all still stayed there. And then 24 it was a motel style building. 25 And then across the street from that, there was a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068606  145 LBUCmaxl - direct firehouse with a fire engine, and that also had several garages for all the maintenance for the ranch. And then to the right of that, there was a greenhouse for growing vegetables, et 4 cetera. 5 And then across the street from the greenhouse, there 6 was a stable with a stable area that housed -- it had to have 7 been 10 to 15 horses. That was the ranch central area. 8 And then you continued through Ranch Central and 9 continued up a dirt road approximately, I don't know, it had to 10 have been two or three miles and you got to a Y in the road 11 where if you went to the left -- I'll take you to the left 12 first. Once you got to the Y in the road, you took a left and 13 actually you're going to pass by, during that drive, a runway 14 we had on the property, which, as you saw, the twin-engine 15 Cessna was parked on. So we had a runway and a hangar to house 16 the aircraft. So you pass the runway and you continued up the 17 road to -- it was called the lodge. It was actually the first 18 home site that was selected to build the main house, and that 19 was a triple-wide trailer that also had a western faux facade 20 built around it. Once you went past the triple-wide lodge, you 21 went about, you know, maybe a thousand yards and there was a 22 log cabin that was built up on the cliff, because both the 23 lodge and the log cabin were on cliffs that overlooked the 24 ravine to the north. 25 And we go back to the Y in the road that brought you SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068607  146 LBUCmaxl - direct past the runway. You continued up that road where you saw the photo with the Z on the entrance. That was the main entrance to the main house. And then the main house was built 4 eventually on that cliff overlooking the ravine. 5 (Continued on next page) 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068608  117 LBUVMAX2 - direct BY MS. COMEY: Q. In total approximately how many acres was Mr. Epstein's ranch? 4 A. It was approximately 10,000 acres. I know there was some 5 state land included in it, but everybody said it was around 6 10,000 acres. 7 Q. And all of the structures you just described, were they all 8 located on that property owned by Mr. Epstein? 9 A. Yes. 10 Q. Have you been inside the main house on the ranch property? 11 A. Yes, I have. 12 Q. For what purpose? 13 A. Several purposes. A lot of the times -- it was on occasion 14 I would meet with Mr. Epstein and discuss future aircraft 15 maintenance or purchases for the aircraft. And then other 16 times would be to pick up and drop off luggage. And that was 17 another residence that I installed a lot of the home theater 18 and audio equipment. He was an audiophile, so he liked very 19 high-quality music; so I installed a home theater, like I had 20 done at the other properties as well. 21 MS. COMEY: Ms. Drescher, can we please pull up 22 Government Exhibits 323 and 706 for the witness, the Court, and 23 the parties. 24 Q. Mr. , do you recognize these? 25 A. Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068609  148 LBUVMAX2 - direct Q. What are they? A. Those are exterior photos of the main house at Zorro Ranch. Q. Are these fair and accurate depictions of the exterior of 4 the main house on Mr. Epstein's Zorro Ranch? 5 A. Yes, they are. 6 MS. COMEY: Your Honor, the government offers these in 7 evidence. 8 MR. EVERDELL: No objection. 9 THE COURT: Government 323 and 706 are admitted and 10 you may publish. 11 (Government's Exhibits 323, 706 received in evidence) 12 MS. COMEY: Thank you, your Honor. 13 Q. While Ms. Drescher shows those to the jury, I'd like to ask 14 you, Mr. to please describe the interior of this main 15 residence. 16 A. Okay. As you come into the entrance, I'll take you to the 17 front door, since it's a quite large property. You entered in 18 the front door, and I'll take it starting to the left. If you 19 enter the main door at the front of the house, you made a left, 20 and the house was actually a square house with an open 21 courtyard in the middle that had access to the sun. So it was 22 a -- virtually a square house that circled the courtyard in the 23 middle. 24 So we make a left, and that brought you down a 25 hallway. And the first room you came to was the main living SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068610  149 LBUVMAX2 - direct room, which was tremendous in size; it had to have been 200 feet by 50 feet, and it had an extremely large picture window that overlooked the ravine or the house -- where the house was, 4 you know, to take advantage of the view. Inside that room we 5 had a tremendous stereo system that I installed. And then you 6 came out of that living room and you continued down the 7 hallway. At the corner of that hallway there was Mr. Epstein's 8 library with a desk in it where he spent most of his time, and 9 also housed an impressive audio system. 10 You came out of that room and that led you -- now 11 you're on the -- you're still walking down circling the house. 12 That brought you into what was the dining room for the house. 13 And he didn't use it as a dining room actually; we made that 14 into a movie theater room with a projector that came down. So 15 that was actually the home theater of the house. And you 16 continued through that room. That brought you into a butler's 17 pantry. And then from the butler's pantry, you went into the 18 main kitchen, which also had a dining room table. Once you 19 went through the kitchen, that brought you to another room, 20 which was kind of a morning room, just a small little family 21 room off to the kitchen. 22 As you continue around, there was a staircase that 23 would -- I'll take you downstairs first. You went downstairs. 24 And that brought you to a gym and an indoor swimming pool that 25 also led to the outside patio. Once you came -- I'll bring you SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068611  150 LBUVMAX2 - direct back up the stairs. We're on the main level. And then there was another staircase that brought you upstairs that housed the master bedroom, as well as approximately three -- three or four 4 guest bedrooms upstairs. 5 Q. When you first visited this ranch, was the main house you 6 just described completed? 7 A. No, it was not. 8 Q. About when was construction on this main house completed? 9 A. It was under construction for a while, that's why he had 10 the triple-wide trailer to stay during the construction. But I 11 would estimate probably late '90s, maybe 2000 is when the house 12 got finished. 13 Q. And so in the mid to late '90s, when you visited the ranch, 14 where did Mr. Epstein stay? 15 A. He would stay up at the lodge or the triple-wide mobile 16 home I described. 17 Q. Could you describe what the interior of that triple-wide 18 lodge looked like. 19 A. Sure. As I mentioned, it was a triple-wide trailer that 20 had a wood western facade built around it to make it a little 21 more attractive than just a mobile home. Once you went in the 22 front door, there was a large wooden deck in the front of the 23 house like you would see in a western movie. And you went in 24 the front door, you walked into the living room which had a 25 fireplace to the left. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068612  151 LBUVMAX2 - direct And then if you continued past the living room and made your left turn to the left side of the home, that was the master bedroom. And then you came back into the living room 4 you continued straight ahead from the entrance door, that 5 brought you into a kitchen that led to a large outside deck 6 that overlooked the ravine. And then you came back into the 7 kitchen, and to the right side of the house there were -- there 8 was a small -- or a family room to the right side and also 9 there was two guest bedrooms there. 10 Q. Did the inside of this structure look like a trailer? 11 A. Not the way it was decorated. It was very high-end. 12 Q. What airport did you fly to when Mr. Epstein was staying on 13 this ranch? 14 A. Typically, depending upon what aircraft he selected, if we 15 were flying the Gulfstream, which is a smaller, lighter 16 aircraft, we would use Santa Fe, New Mexico Airport. And if we 17 were flying the Boeing, which is a large airliner, we would fly 18 into Albuquerque due to weight restrictions. 19 Q. I'd like to turn now to Mr. Epstein's Paris property. 20 About when do you remember first visiting 21 Mr. Epstein's apartment in Paris? 22 A. It had to have been maybe the late '90s, Ms. Comey. I 23 couldn't really narrow it down, but it had to have been in the 24 '90s, I would -- yes. 25 Q. About how many times did you visit that apartment while SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068613  152 LBUVMAX2 - direct working for Mr. Epstein? A. Not as much as the other properties. On occasion I would go to pick up luggage and drop off luggage at that place. But 4 I would almost say every trip, but we didn't go to Paris that 5 often, so I'll even go as far as saying most every trip. 6 Q. Other than to pick up luggage, did you go to that apartment 7 for any other reason? 8 A. Yeah. I also did some audio work on the home theater that 9 he had in the Paris apartment as well. 10 MS. COMEY: Ms. Drescher, could we please pull up 11 Government Exhibit 705 for the witness, the Court, and the 12 parties. 13 Q. Mr. , do you recognize this? 14 A. Yes. 15 Q. What is it? 16 A. That is the exterior of the Paris apartment. 17 Q. Is this a fair and accurate depiction of the exterior of 18 the building in which Mr. Epstein's apartment was located? 19 A. That is correct, yes, it is. 20 MS. COMEY: Your Honor, the government offers this in 21 evidence. 22 MR. EVERDELL: No objection. 23 THE COURT: GX-705 is admitted and you may publish. 24 (Government's Exhibit 705 received in evidence) 25 MS. COMEY: Thank you, your Honor. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068614  153 LBUVMAX2 - direct Ms. Drescher, would you please show that to the jury. Q. And while that's up, Mr. would you please describe what the inside of this apartment looked like. 4 A. I believe it was on the second or third floor, we're going 5 back a little ways. But it was -- once you went in the front 6 door, it was a little on the unique side. It was a very long 7 type of apartment. Once you went in the front door, there was 8 an entrance foyer. And if you continued straight through that 9 foyer, it would take you into the kitchen. And then to the 10 left of the kitchen, I think, led down to a hallway with some 11 guest bedrooms. 12 Once you came back to the kitchen, to the right there 13 was a dining room. And then to the right of the dining room 14 there was Mr. Epstein's office where he had a home theater set 15 up in his office as well. And then once you came out back into 16 the foyer, I believe if you went to the right, it took you to 17 either more guest bedrooms, and definitely the master bedroom 18 was down the hallway. 19 Q. When Mr. Epstein stayed at this apartment, what airport did 20 you fly out of? 21 A. We flew into Paris-LeBourget. 22 Q. Turning now to Mr. Epstein's island, about when did you 23 first visit that island? 24 A. It was approximately mid to late -- late '90s. 25 Q. And what was that island called? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068615  154 LBUVMAX2 - direct A. Little St. James. Q. About how often did you visit Little St. James during your employment for Mr. Epstein? 4 A. Every time we went to the St. Thomas U.S. Virgin Islands, 5 where the island was located. 6 Q. About how often did you fly Mr. Epstein to the U.S. Virgin 7 Islands? 8 A. Had been every week, every ten days, if we weren't 9 elsewhere in the world, but it was a regular destination. 10 Q. And why did you go to the island each time Mr. Epstein went 11 to the Virgin Islands? 12 A. I also flew the helicopter. So when Mr. Epstein would 13 arrive at St. Thomas main airport, I would go get the 14 helicopter and then pick him up and the passengers and fly them 15 to Little St. James Island, as well as, you know, taking 16 luggage and also picking up luggage at the island. And also a 17 very large home theater was installed at that residence as 18 well. 19 Q. Did you install large home theaters in all of Mr. Epstein's 20 residences? 21 A. Yes, I did. 22 Q. Other than helicopter, how else could you get to Little St. 23 James? 24 A. The other option would be boat. 25 MS. COMEY: Ms. Drescher, can we please pull up SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068616  155 LBUVMAX2 - direct Government Exhibit 346 for the witness, the Court, and the parties. Q. Mr. , do you recognize that? 4 A. Yes. 5 Q. What is it? 6 A. That is an aerial view of Little St. James Island. 7 Q. And does that fairly and accurately depict Little St. James 8 Island? 9 A. Yes, it does. 10 MS. COMEY: Your Honor, the government offers this in 11 evidence. 12 MR. EVERDELL: No objection. 13 THE COURT: Government 346 is admitted. 14 You may publish. 15 (Government's Exhibit 346 received in evidence) 16 MS. COMEY: Thank you, your Honor. 17 We can take that down. Thank you, Ms. Drescher. 18 I'd like to go now to Government Exhibit 308 for the 19 witness, the Court, and the parties please. 20 Q. Mr. , do you recognize this? 21 A. Yes, I do. 22 Q. What is it? 23 A. That is an aerial view of the main property on Little St. 24 James Island. 25 Q. Is this a fair and accurate depiction of a portion of SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068617  156 LBUVMAX2 - direct Mr. Epstein's private island? A. Yes, it is. MS. COMEY: Your Honor, the government offers this in 4 evidence. 5 MR. EVERDELL: No objection. 6 THE COURT: Government 308 is admitted. 7 You may publish. 8 (Government's Exhibit 308 received in evidence) 9 MS. COMEY: Thank you, your Honor. 10 Q. And while Ms. Drescher puts that up for the jury, 11 Mr. , could you tell us what we see in this photograph 12 please? 13 A. That is the main house which appears to be -- and it's 14 located on the north side of the island. But it's a photo of 15 the main house structure on the island. 16 MS. COMEY: I'd like now, please, to go to Government 17 Exhibit 326 for the witness, the Court, and the parties. 18 Q. Mr. , do you recognize this? 19 A. Yes, I do. 20 Q. What is it? 21 A. That is also an aerial view of Little St. James Island's 22 main property home site. 23 Q. And is this a fair and accurate depiction of a portion of 24 Jeffrey Epstein's private island? 25 A. Yes, it is. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068618  157 LBUVMAX2 - direct MS. COMEY: Your Honor, the government offers this in evidence. MR. EVERDELL: No objection. 4 THE COURT: GX-326 is admitted. You may publish. 5 (Government's Exhibit 326 received in evidence) 6 MS. COMEY: Thank you, your Honor. 7 Q. And while Ms. Drescher puts this up for the jury, 8 Mr. , would you please tell us what we see in this 9 photograph. 10 A. As far as describing the home or the property? 11 Q. Yes. Could you tell us what we see in the top right-hand 12 corner first and then tell us what we're seeing on the 13 property. 14 A. Oh, gotcha. 15 The top right-hand corner was the boat dock, if you 16 were to arrive by boat. So that was the entrance for guests to 17 arrive by boat. And then if you continued down the highway 18 there, you can't see the helipad, the helipad is still south of 19 that structure. Once you were there, you could take -- you 20 would walk up to the main house up on the top of the hill. 21 Q. Thank you. 22 MS. COMEY: We can take that down. 23 And now, Ms. Drescher, can you please pull up 24 Government Exhibit 703 for the witness, the Court, and the 25 parties. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068619  158 LBUVMAX2 - direct Q. Mr. , do you recognize this? A. Yes, I do. Q. What is it? 4 A. That is a photo of Little St. James Island. 5 Q. Is this a fair and accurate depiction of an aerial view of 6 the entirety of Little St. James Island? 7 A. Yes, it is. 8 MS. COMEY: Your Honor, the government offers this in 9 evidence. 10 MR. EVERDELL: No objection. 11 THE COURT: Government's 703 is admitted. 12 You may publish. 13 (Government's Exhibit 703 received in evidence) 14 MS. COMEY: Thank you, your Honor. 15 Q. While Ms. Drescher puts this up for the jury, Mr. 16 I want to ask you, did Mr. Epstein own this entire island that 17 we see here? 18 A. To my knowledge, yes. 19 Q. And could you walk us through in a little more detail a 20 description of the island and the property on it. 21 A. Okay. I guess I'll start at the top of the photo. There 22 was a building there that was a library. It used to have a 23 gold dome on it, but that was actually a library inside that 24 building. And then we come down to the right side of the 25 photo, you could see a small pool on the right side of the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068620  159 LBUVMAX2 - direct photo which was -- which they call the flag -- or the flagpole pool, which was a tremendous-size pool which also had a cabana built. And that was another office that Mr. Epstein spent a 4 lot of his time working on the phone and computers. 5 And then we're coming down through the beach area. 6 Right dead center of the island you'll see a little blue roof, 7 that was the gym. And inside the gym had a tremendous audio 8 system for working out. There was a large gym inside there. 9 And then you come down further from -- further down -- or 10 you're heading down back to the main house structure, to the 11 left you see a wide open grass area, that was the helipad that 12 if we -- if you arrived by helicopter. 13 Coming further down from that, there are several 14 buildings to the left, you see a blue one, a white one. That 15 housed all of the construction equipment, tractors, dump trucks 16 and such, support equipment for the island. And then we're 17 going to come down further from that to the right. We'll come 18 all the way down to the main house structure which also has a 19 large swimming pool. 20 The house was quite unique. It was pretty much a home 21 that was exploded out, that each building was a room of a 22 house; that guest bedrooms were their own bunaglows. So the 23 kitchen was its own building, the living room was its own 24 building, the master bedroom was its own building. So in order 25 to walk from one to another, you actually walked outside. So SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068621  160 LBUVMAX2 - direct it was kind of what I considered like an exploded house. Q. When Mr. Epstein was staying on this island, what airport did you fly into and out of? 4 A. We flew into the main airport in St. Thomas, U.S. Virgin 5 Islands. I believe it's called Charlotte Amalie. 6 MS. COMEY: We can take that down. 7 Thank you, Ms. Drescher. 8 Q. Mr. , what, if any, of Ms. Maxwell's residences did 9 you visit during your employment? 10 A. I think I've been to all of her residence. 11 Q. Could you walk us through each of them chronologically, 12 starting with the first, please. 13 A. Yes. The first time I met Ms. Maxwell, she was in a 14 smaller apartment. We're going back 30 years, so I don't 15 really remember the streets. 16 But then the second apartment I remember a little 17 more, a little more obviously better, which