Trial Day 3 - 745.pdf

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
------------------------------x 
UNITED STATES OF AMERICA, 
 
           v.                            20 CR 330 (AJN) 
 
GHISLAINE MAXWELL, 
 
               Defendant.                Jury Trial              
------------------------------x 
                                         New York, N.Y. 
                                         December 1, 2021 
                                         8:55 a.m. 
 
Before: 
HON. ALISON J. NATHAN,  
 
                                        District Judge 
 
APPEARANCES 
 
DAMIAN WILLIAMS 
     United States Attorney for the 
     Southern District of New York 
BY:  MAURENE COMEY 
     ALISON MOE 
     LARA POMERANTZ 
     ANDREW ROHRBACH  
     Assistant United States Attorneys 
 
HADDON MORGAN AND FOREMAN  
     Attorneys for Defendant 
BY:  JEFFREY S. PAGLIUCA  
     CHRISTIAN R. EVERDELL  
     LAURA A. MENNINGER  
        -and- 
BOBBI C. STERNHEIM  
        -and- 
RENATO STABILE 
 
Also Present:  Amanda Young, FBI 
               Paul Byrne, NYPD 
               Sunny Drescher,  
                Paralegal, U.S. Attorney's Office 
               Ann Lundberg, 
                Paralegal, Haddon Morgan and Foreman 
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(Trial resumed; jury not present) 
THE COURT:  All right.  Matters to take up, counsel,
includes the Rule 16/608, as I see it, issue.  And then I want
to see where you are in terms of working out anticipated
personal identifying information of witnesses who I've given
permission to testify under pseudonyms to protect their
privacy.
So let's begin.
Ms. Menninger, did you want to begin with the Rule 16
issue?
MS. MENNINGER:  I think Mr. Everdell was going to
handle that piece.
THE COURT:  Okay.
Ms. Comey, are you taking this? 
MR. ROHRBACH:  I'm taking this one, your Honor.
THE COURT:  You all swapped off.
So I think the defense is clearly right that if we are
talking by impeachment by contradiction, that is to say,
impeachment, direct contradiction of something testified to on
the stand, it's not required to be disclosed as case-in-chief
material under Rule 16; and depending on what it is, it's
likely not 608 because it's impeachment by contradiction, not
impeachment to show -- extrinsic evidence to show a character
for dishonesty and the like.
So the question is whether it's impeachment or not.
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And I still don't fully understand the photograph of the street
that the witness read the line from saying, That's the address
where we lived, how that's impeachment.  That remains an open
question in my mind.
But otherwise, Mr. Rohrbach, do you disagree with 
anything I've just said as to the state of the law? 
MR. ROHRBACH:  No, I think that that's a correct
statement of the law, your Honor.
The issue with the photograph is it wasn't established 
that that satisfied any of the theories of impeachment; and so 
if the defense is offering it for some other purpose, that 
purpose would be part of the defense's case-in-chief and, 
therefore, subject to Rule 16 or an attack on the witness's 
character for truthfulness, which would be barred by 608. 
THE COURT:  Right.  
But the, I'll charitably call it, theory offered 
yesterday that anything that's not part of the case-in-chief 
somehow then falls under 608 as extrinsic, you've walked away 
from that. 
MR. ROHRBACH:  Yes -- the theory really is that it has
to satisfy some proper basis of impeachment for extrinsic
evidence.  So it's true that there are more than two paths,
yes, your Honor.
THE COURT:  All right.  So just to get to the
photograph, as I see it, the witness's testimony -- and tell
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me -- I don't know if this is Mr. Everdell or Ms. Menninger.
MR. EVERDELL:  It's me, your Honor.
THE COURT:  Okay.
The witness testified, I believe, that at the time 
that she met Epstein and Ms. Maxwell, that she was living with 
her family in a pool house and she described that as homeless; 
correct? 
MR. EVERDELL:  And she said that she lived in one
place, I believe, continuously for her childhood.  The
testimony, what you just said, is accurate.
THE COURT:  Right.  So then you've got the FBI 302 in
which she said that she lived at a certain address at the time
that she met them; correct?
MR. EVERDELL:  That's right.
THE COURT:  I think there's a question of whether that
statement comes in as a prior inconsistent statement.  I don't
know that that was moved.  But she said, in any event, she
looked at it and it was a typo; so she addressed the apparent
discrepancy, as I heard it.  I'm not sure if you wanted to move
the statement in as a prior inconsistent statement and let the
jury resolve that dispute.
But we moved on then to a current photograph of a 
street that had writing on it, an address and a date, and she 
said that's the street I lived in -- that's the street I lived 
on, which it just -- I think it suffered from a lot of 
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problems, but certainly wasn't directly impeaching of her 
testimony. 
MR. EVERDELL:  Your Honor, I'm sorry.  I just -- see
if we could back up.  
Have we moved beyond the Rule 16 issue at this point 
and we're just talking about -- 
THE COURT:  Well, if it's impeaching, then there's not
a Rule 16 issue.  As I sit here, I don't know -- I don't see
that it's impeaching; so that if it's not impeaching, I'm not
sure what you're doing with it and it may be a Rule 16 issue.
MR. EVERDELL:  If I can address that, your Honor,
because I think we disagree with what the state of the law is.
I think there's some disagreement on the courts about whether
or not if the defense is going to introduce something or talk
about something on cross-examination, whether that is
considered a Rule 16 document.
So what I understand the case law to be, your Honor,
is that they are trying to deal with the issue of where the
defense is trying to introduce affirmative proof in its own
case through the government's own witnesses.
THE COURT:  For sure.  Which is, let's face it,
usually what happens.  There's often not a defense case.  Both
cross-examination and impeachment testimony, as well as
affirmative evidence, comes in through cross-examination.
So I think the cases that say there's not a clear 
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temporal time split, that is to say, you don't have to put on 
your first witness, is not the question; it's a functional 
question, are you putting on evidence in your case-in-chief as 
opposed to impeachment testimony. 
MR. EVERDELL:  I think that's right, your Honor.  
Let's give an example, because I think it's helpful to 
use examples.  I'll use one from this very case.   
It's my understanding that the government wants to 
introduce certain FedEx records through a FedEx document 
custodian.  The defense also would like to introduce other 
FedEx records, coincidentally, through the same document 
custodian.  So if that happens, you'd have a witness called by 
the government, the defense would want to introduce affirmative 
proof in its case through that same witness.  That would be 
defense case-in-chief material which, by the way, we disclosed 
in our Rule 16 letter to the government.  That's an example, I 
think, where the courts are talking about where you disclose 
things -- where you have a witness where you are trying to put 
on affirmative proof in the defense case through the 
government's witness.  That is an example where we don't 
dispute. 
I'll give another example.  This is a hypothetical
one.  Larry Visoski just testified.  He was shown a number of
pictures of Little St. James Island where there were
structures, houses on the island.  And he testified to those,
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and those were introduced.
If we hypothetically had photos of that same island 
before those houses were built, we don't, but if we did and we 
wanted to introduce those through Larry Visoski, again, that 
would be affirmative defense in the defense case-in-chief 
introduced through the government's witness.  That would be 
Rule 16 which we'd have to disclose ahead of time. 
THE COURT:  Right.
MR. EVERDELL:  Now, what we are talking about here is
what Witness 1, what Jane, remembers about the childhood, about
these events; it's about her recollection of everything, and
that is critical to the case.  So misremembering details,
misremembering where she lived, not being able to recognize a
house, that all goes to her credibility as a witness, her
believability, any contradiction.  
This is central to the case.  Her memory of every 
single detail of her childhood is central to the case, and that 
is not case-in-chief material.  That is, if she testifies to 
something and we think we have something that contradicts what 
she just said, like a photograph of her -- of a place where she 
lived as a child, but she didn't seem to remember, that's 
impeachment material.  And we don't know if we're going to use 
that until she says on the stand what she says on the stand.  
We have it ready to go in case she says that, and she did in 
this case, and so that's why we were able to use it or try to 
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use it, to show that she doesn't have an accurate recollection.  
That is pure impeachment material. 
THE COURT:  Up to the point where you said it
contradicted what she said on the stand, you and I were in
vigorous agreement.
MR. EVERDELL:  Okay.
THE COURT:  Okay.
MR. EVERDELL:  All right.
Well, what I would say is that we can't -- no, this is 
not -- it's not as if we were going to introduce the photograph 
of her house in our case-in-chief.  We are doing this -- we had 
it ready to be able to use it in case she said something that 
we believe was contradictory and contradicted by the 
photograph.  So that's why we did not disclose it ahead of 
time, because we believed it to be impeachment material.   
By the way, Judge, I'll just note for the record that 
when we sent our Rule 16 discovery several weeks ago to the 
government, we included a cover letter, which I'm happy to 
share with the Court -- 
THE COURT:  I can imagine it reserved all your rights.
And you can keep talking, but we remain in agreement.
MR. EVERDELL:  Okay.  And it cited all the cases that
we cited, and it said we do not consider impeachment material
or refreshing material case-in-chief material.
THE COURT:  It is true.  I think, Mr. Rohrbach agrees.
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The only question in any specific instance is is it impeaching,
and is it a prior inconsistent statement.  We have to deal with
the rules around a prior inconsistent statement.  It wasn't
like you had deposition testimony.  You had an FBI agent's
write-up of notes which the witness was confronted with and
said it was a mistake.  Again, that wasn't moved in, but we can
deal with that as it comes.
There could be -- not here, but there could be 608
issues if you're trying to use extrinsic evidence.  If what we
have is impeaching by contradiction, impeachment of what the
witness testified to on the stand, then it's not going to be a
608 issue.
MR. EVERDELL:  If we're impeaching the witness, yes,
that's right.  And I just want to address the issue of
impeaching with extrinsic evidence, which I know the government
has raised.  That rule is -- and the cases they cite --
THE COURT:  I know you cited Rule 613.  I hadn't
understood their argument to be about 613.
MR. EVERDELL:  They raised in their papers the notion
that you can't impeach -- or you can't use extrinsic evidence
to impeach.  But the rule there and the cases they've cited
stand for the unremarkable proposition that you can't
impeach -- or you can't use extrinsic evidence on a collateral
matter.
THE COURT:  Correct.
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MR. EVERDELL:  Her memory about anything to do with
this time period is not a collateral matter; she is a central
witness to this case.
THE COURT:  Well, again, I don't adopt that broad
statement.  But to the extent you are attempting to impeach --
so you have something that contradicts what she testified to on
the stand, then it's not a Rule 16 issue, I doubt it's a 613 --
a 608 issue.  We may have to deal with 613 questions and what
it is that we're looking at.
MR. EVERDELL:  Again, it's also not a 608 issue, I'd
say, your Honor, because that rule deals with conduct.
THE COURT:  I said it's not a 608 issue.
MR. EVERDELL:  Yes.  Okay.  I agree with you.
MR. ROHRBACH:  I'm a little confused, your Honor.  
I think we're agreeing that, as your Honor said, if 
it's offered for impeachment with a proper basis for 
impeachment and it's not about a collateral matter, then they 
didn't have to disclose it in Rule 16.  If it's to advance the 
defense case, whether in the government's case or in the 
defense case, then it should have been disclosed in Rule 16.   
There are things that the defense might expect to 
offer for impeachment, but that might be impeachment about a 
collateral matter or might be impeachment, but is not, in fact, 
based on a contradiction or some other proper theory of 
impeachment, in which case it is not an admissible exhibit.   
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The government also doesn't agree with the defense's 
broad statement that anything that goes to this witness's 
memory is a noncollateral matter.  It's hard for us to know now 
exactly what they plan to do.  The government thinks we should 
take that as it comes.  But I think there's sort of broad 
agreement about the general principles here, your Honor. 
MR. EVERDELL:  If there's broad agreement, your Honor,
then there shouldn't be objections.  If we have an issue with
the witness's memory that we believe we have a document or some
other information that contradicts what she's saying, then we
are allowed to cross on it.
THE COURT:  Okay.  We'll take it as it comes, but we
agree on the principles.  I think the only question is -- I
sustained the objection to admission of the photograph, because
it's not clear to me that it's impeaching.  As I said, if it's
not impeaching, then it might be a Rule 16 issue; I wasn't
entirely sure what you were trying to do with it.
You're welcome to -- if there's some basis to show a 
photograph, to impeach something she suggested in her 
testimony, then you can do that. 
MR. EVERDELL:  Yes.
THE COURT:  Okay.
MR. EVERDELL:  Understood.
MR. ROHRBACH:  The government agrees, your Honor.  The
issue with that particular photograph, setting aside the fact
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that the witness couldn't recognize it, and there are other
questions about admissibility than just whether it's relevant
or impeaching, is that it wasn't a direct contradiction of
anything the witness said on the stand; so it wasn't a proper
basis for impeachment.  And if it advanced the defense case in
some other way, it would have been a Rule 16 --
THE COURT:  What is the government's understanding of
when the witness lived at the address that's referenced in the
302?
MR. ROHRBACH:  If I may ask Ms. Moe, who's taking the
rest to answer that question.
THE COURT:  Sure.
MS. MOE:  Yes, your Honor.  
I don't recall the particular date, but I think the 
witness was beginning to clarify on cross-examination yesterday 
that at some point while she was a teenager living in Palm 
Beach, she moved to the second address.  I don't recall the 
specific date -- 
THE COURT:  And you say the second address, what do
you mean?
MS. MOE:  Yes, your Honor.
THE COURT:  I guess what do you mean by the first
address, do you mean the pool house?
MS. MOE:  Yes, your Honor.  I believe the witness
would explain that at the time that all of this --
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THE COURT:  Could you pull up the microphone.
MS. MOE:  Yes, your Honor.  I apologize.
THE COURT:  Even though we're three days in, I still
can't hear you without the mic.
MS. MOE:  I'm sorry.
THE COURT:  That's okay.
MS. MOE:  I believe the witness would explain that
when all of this began when she was 14, she was living in a
pool house because of her family's financial circumstances.
But at some point during the years that followed, her family
moved to a second house.
THE COURT:  And that's the address listed in the 302,
as you understand it?
MS. MOE:  I don't recall offhand whether that's the
particular address.  I'd want to review the 3500.  But I
believe the witness was clarifying that she lived at a second
house.
THE COURT:  Okay.  All right.
MR. EVERDELL:  Your Honor, I'm sorry.  
I believe -- and I'm checking this right now, but I 
believe the address she put on her 1994 Interlochen application 
was the address we were showing her the photograph of.  And 
she's saying she's in a pool house or homeless.  So I think 
this is impeaching.  I think this goes directly -- 
THE COURT:  Again, she said she lived -- they move in
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the application.  All she said about the photograph was, That's
the address that I lived in.  And so we just don't have a --
she looked at your photograph, she looked at the address
written on it; she said that's the address where I lived.
That's not yet in contradiction to her statement, because
there's a timeline issue.  But you can try, again, to see if
there's a basis for impeachment.
MR. EVERDELL:  All right.  I'll leave it to
Ms. Menninger, who's going to be doing the cross.
THE COURT:  Okay.
Any questions about that, Ms. Menninger? 
MS. MENNINGER:  No, your Honor.  I think I can ask her
questions today that explain when she lived where --
THE COURT:  Great.
MS. MENNINGER:  -- what was on her applications.  What
she said in her 302, which was already discussed on the record,
is that she lived in the same place from the time she met
Epstein until she moved to New York.  That was her statement.
She continued on --
THE COURT:  You mean that's the statement recorded in
the 302.  
MS. MENNINGER:  That is one of the statements recorded
in the 302 verbatim.
THE COURT:  Right.  Sorry, verbatim.  She said it was
a typo.  It's a type-up of agents' notes, is it not?
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MS. MENNINGER:  It's a type-up of the agent's notes.
We also have the agent's handwritten notes.
The next sentence -- then I'll explain what I think we 
may get to.  The next sentence, she says, That home was a 
three-bedroom home in a gated community called Bear Lake, 
something like that.  Those were the two statements that were 
typed up in the agent's 302. 
THE COURT:  Okay.
MS. MENNINGER:  And in the handwritten notes.
She's had a chance to explain it; in her mind, it's a 
typo.  We have those agents on call to be witnesses, and they 
can talk about whether it was a typo or not a typo.  I mean, I 
think that's the state of play in terms of contradicting a 
witness with a prior inconsistent statement. 
THE COURT:  Okay.  Anything else on that?
MR. ROHRBACH:  Nothing from the government.
MR. EVERDELL:  No, your Honor.  Thank you.
THE COURT:  Do we have issues to take up around
specific identifying information?
MS. MOE:  Yes, your Honor.
Just to provide the Court with an update on the status 
of our conferral with defense counsel, defense counsel provided 
the government with a list of certain topics this morning, 
which we appreciated; and we had a productive conversation this 
morning about a number of those topics, and I think I've 
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narrowed the scope of any disagreement.   
There are two remaining topics.  And I think we've 
agreed that before those topics are raised at a break or before 
the jury comes out, we're going to confer with the witness's 
counsel just to confirm what issues might be identifying as to 
those two particular issues.  I'm hopeful that we'll be able to 
resolve any disagreement there, but we want to just work that 
out before that comes out before the jury.  And I think there 
are one or two issues that we've agreed that won't be raised 
without a sidebar in advance to discuss them. 
THE COURT:  Okay.  Is there no way to do that now
while we're waiting for our jurors or --
MS. MOE:  Your Honor, I think defense counsel's
preference was to do that at a sidebar.
THE COURT:  It's here.
MS. MOE:  Yes, your Honor.
THE COURT:  I just meant I'm happy to do it at the
sidebar, to the extent we're referencing the specific
identifying information.  I just meant as a time saver can we
do it now.
MS. MENNINGER:  I think there are two of the three
that we can do now; but the third one depends on what the
witness says, your Honor.
THE COURT:  Okay.
Let me just get a check on our juror numbers. 
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MS. MOE:  Yes, your Honor.  
Just to be clear, I think two of those topics were 
ones that we wanted to just confer with the witness's attorney 
about, because there may not be any disagreement; we just 
wanted to confer with him to ensure we have that right.   
I think there was one remaining topic that defense 
counsel preferred to raise as it arises during the course of 
cross-examination.  That's what I meant by at sidebar.   
Apologies. 
THE COURT:  Okay.  So is there anything we can discuss
now at the sidebar or no?
MS. MENNINGER:  There's two of the three we can
discuss at sidebar.  I'm happy -- if the witness's counsel
wants to join us at the sidebar and weigh in on what counsel
thinks is identifying or not as we discuss it.
THE COURT:  My preference would be for you to confer
first and then let me know.
MS. MOE:  Yes, your Honor, that's what we would
propose.
THE COURT:  Okay.
MS. MOE:  Thank you.
THE COURT:  All right.
Anything else we can take up now? 
MS. MENNINGER:  Yes, your Honor.  
I conferred with the government.  We have prepared, 
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similar to the government and similar to what Mr. Everdell did 
yesterday, 18 binders that have potentially admissible sealed 
exhibits in them we would like to place under the jurors' 
chairs, consistent with the practice on prior witnesses, to 
only have them directed to a particular tab when and if the 
Court admits a particular document that has identifying 
information contained in it, if that's okay with your Honor. 
THE COURT:  Ms. Moe, is that fine with you?
MS. MOE:  Your Honor, may I have just one moment?
(Counsel conferred) 
MS. MOE:  No, your Honor.  Thank you.
THE COURT:  Fine.  Okay.  So you can place the
binders.  Anything else we can take up now, Ms. Menninger?
MS. MENNINGER:  No, your Honor.  I'm just going to
approach the witness stand at some point and re-place the
binder on the witness stand.
THE COURT:  You may do that.
Ms. Moe, anything we can take up now? 
MS. MOE:  No, your Honor.
THE COURT:  All right.  I will step down.
I appreciate counsel conferring on the anonymity 
issues and working through as much as you could.  I greatly 
appreciate that.  I will see you in a few minutes. 
(Recess) 
THE COURT:  All right.  We have our jury.
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Anything to take up? 
MS. MOE:  Yes, your Honor.
I just wanted to report to the Court, we had a chance 
to confer about those two issues.  We've narrowed the scope of 
disagreement to just one issue after conferring with the 
witness's counsel, which we'd like to raise at sidebar.  I 
don't know how soon that will come up, so I defer to defense 
counsel whether to do that now or whether it would be more 
efficient to bring the jury out and deal with that at a break. 
There's a second issue to flag, but let me just pause
there on that to see.
THE COURT:  Sure.
Is it anytime soon, Ms. Menninger? 
MS. MENNINGER:  I don't think so, but I don't have it
all memorized.
THE COURT:  Understand.  Let's hope we get to the
break and then we'll take it.
What else? 
MS. MOE:  Yes, your Honor.
Defense counsel provided the government with a number 
of exhibits, and we appreciated the chance to review those in 
order to raise issues in advance.  We just wanted to flag that 
for two of those we anticipate there being a Rule 408 
objection.  Again, I don't know how quickly that will arise, so 
I just wanted to alert that to the Court.  We can take that up 
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as it arises, but wanted to bring that to the Court's 
attention. 
In addition, defense counsel has notified the
government that they've provided binders of defense materials
for the jurors.  It appears that -- we have not had a chance to
review those materials, but based on a sampling that defense
counsel has provided to the government, it appears a large
number of them are things like printouts from the internet and
otherwise.  So we have concerns about jurors flipping through a
binder that would appear to contain a wide array of materials
that would not be admissible.  And because we haven't examined
that binder, we have concerns about that.
I don't want to delay bringing the jury out, and so I 
would just ask for an opportunity to be heard about that before 
the jurors bring out any binders and begin flipping through 
them. 
MS. MENNINGER:  I'm going to be asking them to look at
the binders at the outset at the beginning exhibits.  I think
we've all come to believe --
THE COURT:  We're going to keep doing what we've been
doing, which is before the jury turns to it, the defense will
tell us what it is.  If you have an objection before they turn
to it, you'll raise it and we'll deal with it.
MS. MOE:  Yes, your Honor.  Thank you.
THE COURT:  Is there any general set of objections in
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that regard that we can --
MS. MOE:  Yes, your Honor.
I think materials like printouts from the internet, 
things like tabloid articles, Wikipedia pages, we don't think 
are appropriate as exhibits before the jury, and so we would 
object to exhibits of that nature.   
In addition, the samples that we've been provided 
include -- 
THE COURT:  Doesn't it depend what it's being used --
you have an internet objection, is that the -- what's the
grounds for a blanket objection to internet material?
MS. MOE:  Yes, your Honor.
I agree that we'll have to take these as they come.  
Thinking ahead, we can't conceive of a basis for offering 
things like Wikipedia articles with this witness or tabloid 
articles with this witness, but we recognize the Court will 
have to address that as it comes because we're not quite sure 
what the defense argument would be.  We mostly just wanted to 
give the Court a preview of those issues that we anticipate 
arising. 
THE COURT:  Okay.
MS. MENNINGER:  Your Honor, I feel like I'm trying to
give them stuff in advance so they can be prepared and we can
move this proceeding more quickly, but it will only come up
when and if it comes up.
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THE COURT:  All right.  Then we'll take it -- I'm
going to try to minimize sidebars, so we have to keep moving.
My request always is if there are things that you 
think are likely to require a discussion to address 
admissibility, that you do raise them in advance.  Confer.  If 
you disagree, raise them.   
I think at this point we'll bring out the jury.  I'll 
ask you to keep trying to do that as we go, so we use our time 
efficiently.  But it makes no sense to have the jury sitting 
idly now. 
MS. MOE:  Thank you, your Honor.
THE COURT:  We'll bring in the jury.
Can we bring in the witness.
(Witness present) 
(Jury present) 
THE COURT:  Good morning, ladies and gentlemen of the
jury.  Nice to see you.  Thank you so much for your punctuality
and attention and diligence.  I greatly appreciate it.  I hope
you had a good evening.
We will continue with Ms. Menninger's
cross-examination of the witness who's testifying under the
pseudonym "Jane."
I remind Jane that you are under oath.   
I do remind the sketch artists that pursuant to my 
order, please don't sketch exact likeness of the witness who is 
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LC1VMAX1                 Jane - cross
testifying under a pseudonym.   
With that, Ms. Menninger, you may continue. 
MS. MENNINGER:  Thank you, your Honor.
 JANE, 
     called as a witness by the Government, 
     having been previously duly sworn, testified as follows: 
CROSS-EXAMINATION (continued) 
BY MS. MENNINGER:  
Q.
Good morning, Jane.
A.
Good morning.
Q.
I'd like to pick up again with your Interlochen
applications, all right?  You don't need to open the binder
until we let you know.  Thank you.
You are aware that Interlochen awards financial aid; 
correct? 
A.
Yes.
Q.
You are aware that Interlochen awards scholarships;
correct?
A.
Correct.
Q.
You went there for three years in the summers?
A.
Yes.
Q.
Ages 13 to 17 -- 16?
A.
16, yes.
Q.
No, 17; I think you turned 17 in your final summer.
THE COURT:  Is that a question?
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LC1VMAX1                 Jane - cross
MS. MENNINGER:  Yes.
THE COURT:  Did you turn 17 in your final summer?
THE WITNESS:  Sorry, I'm doing the math.  14, 15 --
no, 16.
Q.
Your brothers went there as well?
A.
Yes.
MS. MENNINGER:  If we could turn to J-3, which has
already been admitted.  And there is a little green flag for
you to get to the J exhibits more quickly.
And your Honor, because J-3 has been admitted, I would 
ask at this time that the jurors be permitted to access the 
smaller binder under their chairs which has J-3 in it. 
THE COURT:  Just one moment.
Without objection? 
MS. MOE:  No objection, your Honor.
THE COURT:  Okay.  Jurors, you may pick up the smaller
binder please and turn to J-3.  Thank you.
BY MS. MENNINGER:  
Q.
Have you found J-3?
A.
Yes.
Q.
I think as we discussed yesterday, that's your name on this
application; correct?
A.
Yes, ma'am.
Q.
And at the top line above your name, the question was
asked:  Are you applying for scholarship/financial aid;
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LC1VMAX1                 Jane - cross
correct?
A.
Correct.
Q.
And you checked off no; correct?
A.
Correct.
Q.
I want to ask you to turn to the second page of that
exhibit.  And on the second page, you described what kind of
classes you wanted to apply for; correct?
A.
Correct.
Q.
You wrote that:  When asked about something difficult,
nothing has been difficult for me; correct?
A.
I guess I did.
Q.
You were involved in the school of the arts as we
discussed, right?
A.
Yes.
Q.
Costuming, acting, improvisation, right?
A.
Yes.
Q.
Plays, performances, movies, right?
A.
Correct.
Q.
This was at the age of 13, right?
A.
Yes.
Q.
And then just below that, it has the names of some
individuals who offered letters of recommendation for you,
right?
A.
Right.
Q.
When you were 13; correct?
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LC1VMAX1                 Jane - cross
A.
Correct.
Q.
And then your signature is on that page, right?
A.
Yes.
Q.
And then the next page in this exhibit are some photographs
of yourself, right --
A.
Yes.
Q.
-- that you submitted?
A.
Yes.
Q.
These were all taken before you had turned 14, right?
A.
Yes.
Q.
All of them on the page?
A.
Yes.
Q.
All right.  If we could turn to page -- well, actually,
yes, the next page, 4.  That also has your address at the time;
correct?
A.
Yes.
Q.
And one more page, page 6.  That is one of the letters of
recommendation for you; correct?
THE COURT:  Ms. Menninger, could I have a binder?  I
don't think I have it.  That's the government exhibits.
MS. MENNINGER:  Your Honor --
THE COURT:  If you don't, that's okay.
MS. MENNINGER:  No, no.  I believe for this one we
gave you one yesterday, but I could be wrong about that.  If I
could just check with Ms. Lundberg.
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LC1VMAX1                 Jane - cross
THE COURT:  I thought you did, too.  I have just the
government exhibits.
MS. MENNINGER:  Can she put it on the screen, your
Honor?
THE COURT:  That would be fine.  That is, I think,
what we were doing in part yesterday.
MS. MENNINGER:  My apologies.
J-3, and we're on page 6. 
THE COURT:  Go ahead, Ms. Menninger.
BY MS. MENNINGER:  
Q.
On page 6, we have a letter of recommendation for you.  Do
you see that?
A.
Yes.
Q.
Glowing letter of recommendation, right?
A.
Yes, it looks like it.
Q.
And the person that is referred to who performed or wrote
that letter of recommendation gave her qualifications, right?
A.
Yes.
Q.
Her credentials, right?
A.
Yes.
Q.
She was then on the board of the Palm Beach School of the
Arts, right?
A.
I didn't know that till I just saw it.
Q.
Well, it's in your application, right?  You solicited this
letter of recommendation from her; correct?
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LC1VMAX1                 Jane - cross
A.
Yes.
Q.
And she was presently on the -- formerly, I'm sorry, a
director of the Professional Children's School; correct?
A.
Correct.
Q.
And that's the school that you ultimately went to in New
York for senior year, right?
A.
Yeah.
Q.
And she was glowing in her support of your application to
go to Interlochen when you were 13 years old; correct?
A.
Correct.
Q.
I want to direct your attention to the last page in that
exhibit, page 11.  If I could have you read the third full
paragraph; but, of course, omit your family name from that
reading.  If you could read it out loud.
A.
The third paragraph?
Q.
Yes, that begins with "Each."
A.
Each child has their own individual personality and talent,
but all three reflect the qualities of a strong, loving family
background.  The arts have always been a common interest with
music as a binding love.  The family organized and underwrote
an annual charity performance for our school.  After attending
their Feastival of Lights, our school community has always felt
we had witnessed the rebirth of the von Trapp family.
Q.
The von Trapp family, is that right?
A.
Yes.
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LC1VMAX1                 Jane - cross
Q.
And this was a reference to you and your two brothers,
right?
A.
Yes.
Q.
I also believe, just in case it wasn't audible, it said
that you and your two brothers came from a strong and loving
family background; is that right?
A.
That's what it says.
Q.
I want to turn to -- and we could show for the Court --
what's been marked for identification as J-4.  But you're
certainly welcome, Jane, to turn to that in paper form.
THE COURT:  Not the jurors.
MS. MENNINGER:  Not the jurors.
THE COURT:  Please wait till I direct you.  Please
wait till I direct you.  You can close your binders.
Thank you. 
MS. MENNINGER:  It's going to come out again, I hope
soon.
BY MS. MENNINGER:  
Q.
Do you recognize this document?
A.
I do not recognize the document per se.
Q.
J-4?
A.
But I recognize my signature.
Q.
Okay.  Do you believe that this is your application?
A.
Yes.
Q.
And to the same Interlochen Arts Camp?
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LC1VMAX1                 Jane - cross
A.
Yes.
Q.
And do you see the date on the upper right-hand corner?
A.
Yes.
Q.
And that would have been an application for the next year,
for the next summer, is that fair?
A.
Yes.
Q.
All right.
MS. MENNINGER:  Your Honor, at this time I'm moving
for the admission of J-4, which I previously discussed with the
government.
MS. MOE:  No objection, your Honor.  We would just ask
that it be under seal and that any identifying information not
be read into the record.
THE COURT:  Okay.  J-4 is admitted.  It's admitted
under seal consistent with my ruling that this witness may
testify under pseudonym.  And if any reference -- if any
reading of the document occurs, everyone is admonished not to
use the identifying information.
(Defendant's Exhibit J-4 received in evidence) 
BY MS. MENNINGER:  
Q.
So if you need to turn on the second page, I think it has
your signature, just for reference sake.  Do you see that?
A.
Yes.
Q.
Do you believe this is your application?
A.
Yes.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX1                 Jane - cross
Q.
That was submitted in October of 1994?
A.
Yes.
Q.
And that would be for the summer of 1995?
A.
Yes.
Q.
Up again on the top line above your name there is a
question:  Are you applying for financial aid?
MS. MENNINGER:  Oh, the jurors can look at J-4 now, if
that's okay.
THE COURT:  Without objection?
MS. MOE:  No objection, your Honor.
THE COURT:  You may open your binder to J-4, please.
Thank you. 
Q.
So we see your name in the top portion of the application,
right?
A.
Yes.
Q.
And then above that, are you applying for financial aid,
and you checked no; correct?
A.
Correct.
Q.
If you want to turn to page 2 of that exhibit, up on the
top line there are some references and one is your father's
name; is that right?
A.
Yes.
Q.
And then next to that was your teacher from Palm Beach
School of the Arts, right?
A.
Yes.
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LC1VMAX1                 Jane - cross
Q.
And then below that, again, it gave a little summary of
where you were in your career in October of '94; correct?  It
talked about you had done commercials, right?
A.
A couple.
Q.
Many performances singing, right?
A.
Yes.
Q.
Plays, skits, etc., right?
A.
Yes.
Q.
You had been in the New York Broadway production of Joseph
and the Amazing Technicolor Dreamcoat; correct?
A.
I was not in the New York production.
Q.
It was a local production?
A.
It was -- it was the touring company in Florida.
Q.
Okay.
MS. MOE:  Your Honor, may I have just a moment to
confer with defense counsel?
THE COURT:  You may.
(Counsel conferred) 
MS. MOE:  Thank you, your Honor.
Q.
And again, you said:  Nothing has been very difficult for
me.  Correct?
A.
I guess I did.
Q.
On the next page you had submitted a letter asking to take
extra classes the next summer, right?
A.
Yeah.
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LC1VMAX1                 Jane - cross
Q.
And your address on this application for the summer of '95
is the same address as the one that was on your application for
the summer of '94; correct?
A.
Correct.
MS. MENNINGER:  All right.  And then if we could --
not the jurors, if the jurors could wait a minute, could we
have the witness identify what's been marked as J-5, which is
the next exhibit?
THE COURT:  Jurors, close your binders please.  And
keep them on your laps, but close them.  Thank you.
Q.
Do you see the exhibit at J-5?
A.
Yes.
Q.
And that has your signature as well, correct?
A.
Correct.
Q.
And there's a date on the upper left-hand corner, do you
see that date?
A.
Yes.
Q.
And do you believe this to be your application for the
summer of 1996?
A.
Yes.
Q.
All right.
MS. MENNINGER:  At this time I would move for the
admission of J-6.
MS. MOE:  No objection, your Honor.  We'd ask that
this exhibit be received under seal for the same reasons.
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LC1VMAX1                 Jane - cross
THE COURT:  Okay.  J-6 is admitted.  It's admitted
under seal, consistent with my ruling --
MS. MENNINGER:  I'm sorry, J-5 for 1996.
THE COURT:  Oh, I apologize, J-5.  J-5 is admitted
under seal consistent with my ruling that this witness may
testify under a pseudonym, and without objection from the
government.  
(Defendant's Exhibit J-5 received in evidence) 
THE COURT:  I'll direct, Ms. Moe, the jury to look at
the binder, J-5.
MS. MOE:  Yes, your Honor.
THE COURT:  All right.
Jurors, you may look at J-5 please. 
BY MS. MENNINGER:  
Q.
So on J-5 we have your signature there again; correct?
A.
Correct.
Q.
And you were applying for the high school level, right?
A.
Yes.
Q.
And you had a new address for this application for the
summer of 1996; correct?
A.
Yes.
Q.
That address is the one we talked about yesterday that was
in the Bear Lake Estates gated community, right?
A.
Yes.
Q.
I want to show you, at the bottom of that page, it's the
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX1                 Jane - cross
same teacher who had supported you from the prior year's
application; correct?
A.
Correct.
Q.
And then if we could turn the page to the next page, on
page 2 of J-5, in the second box down from the top, there's a
label "Financial Information."  Do you see that box?
A.
Yes.
Q.
And in that box it asks:  Are you applying for financial
aid?  And you said no.  Correct?
A.
Correct.
Q.
And then the next line says:  Does the student applying
expect to be the recipient of any funds, scholarship, grant,
award, or prize from any country, state, organization, or
individual specifically for attendance at the Interlochen Arts
Camp.  And you checked no.  Correct?
A.
Correct.
Q.
And then on that same page there is a little newspaper
clip; correct?
A.
Correct.
Q.
And I won't say the names of any performances, but it's
talking about some performances that you and your brothers had
performed in the area, right?
A.
Yes.
MS. MENNINGER:  And if I may have one second, your
Honor?
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX1                 Jane - cross
THE COURT:  You may.
(Counsel conferred) 
Q.
And that you and your brothers had performed the last week
for a School of the Arts performance locally; correct?
A.
Correct.
Q.
And then you were going to be performing in another city in
Florida in the upcoming days; is that right?
A.
That's right.
Q.
And then it said in April that you would be traveling to
Italy for a vocal competition; correct?
A.
Correct, with my school.
Q.
And so this was in -- this was dated in 1996, right?
A.
Yes, ma'am.
Q.
All right.  And then if we could go to the last -- I'm
sorry, page 5 of that exhibit we touched on briefly yesterday.
On page 5 of that exhibit, it gives the camp fee structure for
Interlochen for you for that summer, right?
A.
It looks like it, yeah.
Q.
And it's $4,025 for the summer; correct?
A.
Correct.
Q.
And you signed under that as well as your mother, right?
A.
Yes.
Q.
And on none of these three applications is there any
mention of Jeffrey Epstein; correct?
A.
Correct.
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443
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX1                 Jane - cross
Q.
And there's no mention of Ghislaine Maxwell; correct?
A.
Correct.
MS. MENNINGER:  All right.  At this point, if we could
ask the jurors to close the binders, your Honor.
THE COURT:  Please do.  Thank you.
Q.
I want to talk about the first time that you say you met
Mr. Epstein and Ms. Maxwell, okay?
A.
Okay.
Q.
And you claim that was in 1994 when you were 14, right?
A.
Yes.
Q.
You testified yesterday on direct examination that you were
sitting with friends at a picnic table, and a tall, thin woman
approached you with a dog.  And you chitchatted with her, and
then a man came and joined her, right?
A.
Right.
Q.
You recalled a lot of details about that incident in 1994,
right?
A.
Yes.
Q.
You remember that the man had a newspaper under his arm
which he put down on the table, right?
A.
Right.
Q.
You remember that you were on a break from classes, right?
A.
Right.
Q.
You were eating an ice cream cone and the man said, I think
I know your mom.  That's what you testified to yesterday;
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444
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX1                 Jane - cross
correct?
A.
Yes.
Q.
All right.  You gave some statements about that meeting to
several people over the course of the last 20 years, right?
A.
Yes.
Q.
You spoke to your brother, your older brother Brian within
a few days of that meeting, right?
A.
I'm sorry, can you -- a few days of the meeting back in
1994?
Q.
Right.
A.
I don't recall.
Q.
Well, isn't it true that you told your brother Brian that
you had been approached by Epstein?
A.
I don't recall.
Q.
Isn't it true that you told your brother Brian that Epstein
said he knew your dad and admired him?
A.
I don't recall.
Q.
Isn't it true you told Brian nothing about Ghislaine
Maxwell being there at all; correct?
A.
I don't recall.
Q.
Do you remember talking to your younger brother about it
over the last 20 years?
A.
Over the last 20 years?
Q.
Yes.
A.
Yes.
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445
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX1                 Jane - cross
Q.
And when you spoke to your younger brother about this
initial meeting, you also told him that you only met Epstein;
correct?
A.
I don't recall.
Q.
You didn't tell him anything about meeting a woman;
correct?
A.
I don't recall.
Q.
And you also gave an interview to a news source about this
initial meeting; correct?
A.
Correct.
Q.
And when you spoke to that news source, you told the news
person, journalist, that you were approached by Epstein;
correct?
A.
Correct.
Q.
You said nothing about Ghislaine being there?
A.
I don't remember what I said.
Q.
All right.  Could I have you -- and only you and not the
jurors -- take a look at J-13.
MS. MENNINGER:  And for the Court and the witness we
could put it on the screen.
If I could direct the witness's attention to page 2 of 
that document. 
Q.
Are you at page 2?
A.
Yes.
Q.
And on the fourth paragraph, you told the reporter that
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446
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX1                 Jane - cross
Epstein approached you; correct?
A.
Correct.
Q.
You didn't say anything to the reporter about Ghislaine
being there; correct?
A.
Correct.
Q.
You spoke to the government for the first time, as we
discussed yesterday, in September of 2019; correct?
A.
I don't recall the exact date.
Q.
Well, you were there in California with your lawyers and
Ms. Moe and some others; correct?
A.
Correct.
Q.
And what happened when you spoke to them then is you were
asked about the first time that you met Ghislaine, right?
A.
Right.
Q.
And what you told the government on that day with your
attorneys there is that Ghislaine walked by with her dog;
correct?
A.
I don't recall my exact vernacular.
(Continued on next page) 
 
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447
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
BY MS. MENNINGER:  (Continued)
Q.
And you told the government that only Epstein came up to
meet you, correct?
MS. MOE:  Objection, your Honor.
MS. MENNINGER:  3509-002, page 1.
THE COURT:  Can I have it on the screen?
MS. MENNINGER:  Yes, your Honor.  3509-002.
Q.
What you told the government on September 19 of 2019 is
that Ghislaine walked by with her dog and Jeffrey Epstein came
up to meet you, correct?
A.
I wouldn't have said that.
Q.
So, the (inaudible) again.
(Reporter inquired) 
MS. MOE:  Objection, your Honor.
THE COURT:  You cut out.  I think I heard the
question, but can you repeat the question?
Q.
So the FBI got it wrong again?
MS. MOE:  Objection, your Honor.
THE COURT:  Overruled.  You may answer.
A.
Maybe they typed it up wrong.
Q.
What you told the government is that -- well, what you
testified to yesterday is that both Ghislaine and Jeffrey told
you that they give scholarships, correct?
A.
I don't remember which -- I know Jeffrey said it.
Ghislaine was standing there.
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448
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
Q.
And that's right.  Ghislaine didn't walk by?
A.
No, she was right there.
Q.
And Jeffrey said, can I give scholarships?
A.
I cannot remember his exact verbiage this many years later.
Q.
And Jeffrey said, can I have your mom's phone number?
A.
Yes.
Q.
Not Ghislaine asking for your mom's phone number?
A.
No.
Q.
You testified yesterday that you were sitting on a park
bench with your friends, right?
A.
Yes.
Q.
And when you filed your civil lawsuit in January of 2020
you said you were sitting alone on a bench between classes,
correct?
A.
I don't recall what was written.
Q.
I want to talk about the second meeting that you had with
Mr. Epstein.  You went back home after camp that summer?
A.
Yes.
Q.
And you started school for the school year, right?
A.
Yes.
Q.
You testified yesterday that a few days after you got back
to school, someone from Epstein's office called your mom,
right?
A.
Yes.
Q.
That someone from Epstein's office was not Ghislaine
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449
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
Maxwell, correct?
A.
I don't know.
Q.
Well, did the person invite you to Maxwell's house?
A.
No.
Q.
Invited you to Epstein's house, correct?
A.
Correct.
Q.
With your mother, right?
A.
Yes.
Q.
And when you got to Epstein's house with your mother, it
was 15 or 20 minutes away from your house, right?
A.
Yes.
Q.
It was in -- your house was in West Palm Beach, right?
A.
No, not at this time.  It was in Palm Beach.
Q.
You didn't cross any state lines, did you?
A.
No.
Q.
When you got to Epstein's house for tea, you and your
mother sat by the pool?
A.
Yes.
Q.
You were the only people there?
A.
Yes.
Q.
Ghislaine was not there?
A.
I don't recall.
Q.
Well, you spoke to the government in October of 2021, so
two months ago.  Do you recall speaking with them two months
ago?
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450
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
A.
Yes.  So I was sitting -- it was only the three of us
having tea, yes.  I don't recall if Ghislaine was in the house.
Q.
Well, what you said to the government in October of 2021 at
3509-28 in the handwritten notes is, it was just Epstein, mom
and you present, correct?
MS. MOE:  Again, your Honor, I think we've been over
reading documents that are not in evidence.
THE COURT:  That statement is not inconsistent, so
I'll sustain the objection with respect to that statement.
Q.
At the first tea, the only people there were you and your
mom and Epstein, correct?
A.
Yes.
Q.
You never reported to the government that Ms. Maxwell was
present for the tea, correct?
A.
That's right.
Q.
During the conversation, Epstein told you he gives
scholarships and mentors people, right?
A.
Yes.
Q.
He said he does that; not we do that, correct?
A.
Correct.
Q.
And he did not refer to Ms. Maxwell at all during your
initial meeting with him, correct?
A.
Correct.
Q.
Wasn't a part of the conversation?
A.
No.
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451
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
Q.
After this tea with your mother, you went back to Epstein's
house, correct?
A.
Correct.
Q.
Yesterday you testified that for the first few months when
you spent time with Epstein in Palm Beach, you were there by
yourself.  Do you remember that testimony?
A.
I'm sorry, can you repeat that?
Q.
Yesterday you testified that for the first few months when
you spent time with Jeffrey Epstein in Palm Beach, you were
there by yourself?
A.
By myself as in without my mother.
Q.
Right.  You said --
A.
Yes.
Q.
You were --
A.
Yes, yes, without my mother.
Q.
And then you clarified that your mother did not go back to
his house with you for meetings because she was "not invited."
That was your testimony yesterday, correct?
A.
Correct.
Q.
That is not what you told the government when you met with
them in September of 2019, is it?
A.
I don't know.
Q.
What you told the government in September of 2019,
including Ms. Moe, is "In the beginning, I would be with my
mother and brother"?
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452
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
MS. MOE:  I object to just reading documents.
THE COURT:  Let me see it.  Let me see it before you
read, I'll see it, okay?  And then you can make your objection,
Ms. Moe, and I'll rule.
MS. MOE:  Thank you, your Honor.
THE COURT:  Let me have the passage first.
MS. MENNINGER:  It's going to be in 3509-001 on the
second page, in the fourth paragraph beginning in the middle of
the paragraph.
THE COURT:  Ms. Moe?
MS. MOE:  Your Honor, if the question is whether she
made that statement, we have no objection.
THE COURT:  Go ahead.
MS. MENNINGER:  Thank you.
Q.
What you said to Ms. Moe and the agents was, "In the
beginning, I would be with my mother and brothers at Epstein's
house," correct?
A.
I don't recall that.
Q.
You told the government nothing about your mother wasn't
invited back to Epstein's house, correct?
A.
I don't recall.
Q.
And you talked thereafter about being driven repeatedly to
Epstein's house by a chauffeur who was a sweet Latin American
man, correct?
A.
Correct.
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453
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
Q.
And you said that that sweet Latin American man picked you
up every week or two while you were 14, 15 and 16 years old?
A.
Correct.
Q.
So approximately a hundred times he picked you up over
three years every week or two.  That's your testimony, correct?
A.
I'm not good at math, but I wouldn't recall how many times.
Q.
Well, you testified under oath yesterday --
A.
Okay.
Q.
-- that it was every week or two for three years, right?
A.
Yes.
Q.
All right.  You were asked yesterday by the government how
these meetings at Epstein's house were typically arranged.  Do
you remember that question?
A.
Yes.
Q.
And you said yesterday it was Ghislaine calling the house
or Jeffrey's office calling the house like an assistant or
something.  Do you remember that testimony?
A.
Yes.
Q.
That's not what you told the government in November of 2019
when you met with them then.  And if we could turn to 3509-003
at page 1, fourth paragraph?
MS. MOE:  I'm sorry, I didn't hear the number.
Q.
3509-003, first page, fourth paragraph.
MS. MOE:  Thank you.
Q.
What you told the government on that occasion is you were
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454
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
not sure if Maxwell ever called you to make appointments,
correct?
A.
I don't recall.  I don't know.
Q.
And then on the next page in the same interview in the
first paragraph, same document, next page, you said, "When in
Florida, Epstein or his office would call your house," right?
A.
I guess so.
Q.
You didn't say Maxwell would call your house, right?
A.
I guess -- I don't know.  I guess so.
Q.
And so two years later, now you remember that Ghislaine
called your home to make appointments, right?
A.
Right.
Q.
That memory has come back to you in the last two years?
A.
Well, memory is not linear.
Q.
Do you remember that Mr. Epstein came to your house for
dinner?
A.
Yes.
Q.
In Bear Lakes Estate?
A.
Yes.
Q.
Right?  And he came to your house with your mother and your
brothers there, correct?
A.
Yes.
Q.
Ghislaine was not there?
A.
No.
Q.
You recall that that did not happen right at the beginning
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455
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
of your meeting with Mr. Epstein, right?
A.
Right.
Q.
And it was a year or two after meeting Epstein that he came
to your house for dinner, correct?
A.
I don't know the timeline, but it was at the new house.  
Q.
Well, in February of 2020, you told the government -- this
is at 3509-008, page 12.
THE COURT:  What paragraph?
Q.
The fourth full paragraph beginning with the word "this."
At the end of that paragraph -- I'm sorry -- the middle of that
paragraph is that you said to the government, "They visited you
one to two times at your house in Florida.  This was about a
year or two after meeting him," correct?
A.
Correct, I guess.
Q.
So then you remembered it was a year or two, but you don't
remember it today.  Is that right?
A.
Well, I'm trying to be very accurate, so I don't know.  I
just know it's at the new house.
Q.
And the dinner that you had at your house was prior to any
abuse?
A.
That's not true.
Q.
Well, in the same interview in February of 2020, at page
11 --
MS. MOE:  Your Honor, I'd object to counsel testifying
about --
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456
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
THE COURT:  We're going to keep doing -- point to the
passage.  You'll read it, Ms. Moe.  You'll let me know if
there's an objection, okay?
MS. MOE:  Yes, your Honor.
THE COURT:  So where are we reading?
Q.
On page 11 of that same document in the last full
paragraph, second sentence.
THE COURT:  Okay.  No objection.  You may proceed,
Ms. Menninger.
Q.
What you told the government on that occasion is that at
some point Maxwell and Epstein came to your house prior to the
abuse, correct?
A.
Correct.
Q.
You mentioned on direct examination that you felt Ghislaine
had kind of become your big sister, right?
A.
Right.
Q.
And you have two older sisters as we discussed yesterday,
correct?
A.
Correct.
Q.
One is approximately ten years older than you, right?
A.
Right.
Q.
One is approximately 15 years older than you, correct?
A.
Yes.
Q.
During the time you were in high school, you traveled to
see your sisters?
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457
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
A.
Yes.
Q.
You traveled to Los Angeles to visit and stay with one of
them there, correct?
A.
I don't recall what year, but, yes, at some point.
Q.
You remember staying with her in Los Angeles, correct?
A.
Yes.
Q.
Before you lived in Los Angeles?
A.
Yes.
Q.
So it was while you were still in high school, right?
A.
Yes.
Q.
And you traveled to Boston to visit the other sister,
correct?
A.
No, that's the same sister.
Q.
Same sister, a different time?
A.
Yes.
Q.
In high school, right?
A.
Middle school -- no, middle school and then, okay, once in
high school.
Q.
And your own sisters took you shopping on occasion,
correct?
A.
Correct.
Q.
They took you to the movies, correct?
A.
Correct.
Q.
Over the years, they've talked to you about your
boyfriends, correct?
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458
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
A.
No.
Q.
You have not talked to your sisters about your boyfriends?
A.
I never had any boyfriends.
Q.
You've never had a boyfriend?
A.
Not in high school, I didn't.
Q.
Sorry.  My question was had you ever over the years spoken
to your sisters about boyfriends?
A.
Over the years, yes.
Q.
Because yesterday you suggested that you hadn't had normal
relationships, right?
A.
Right.
Q.
But you have had boyfriends for multiple years at a time,
correct?
A.
Yes.
Q.
You talked a little bit about Ghislaine and Epstein taking
you to see the movies; you said that's something that you guys
did together, right?
A.
Yes.
Q.
You went to a movie theater in the area of Epstein's house
in Florida, correct?
A.
Correct.
Q.
Which is a nice area, right?
A.
Right.
Q.
They were normal movie theaters?
A.
Yes.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax2                 Jane - Cross
Q.
Sometimes other girls went with you, right?
A.
Yes.
Q.
And Epstein would direct who was supposed to sit where in
the movie theater, correct?
A.
Correct.
Q.
And he did not sit next to you in the movie theater,
correct?
A.
I don't remember.
Q.
Well, let's turn -- well, not you, but we'll look at
February 27 of 2020 when you spoke with the government,
3509-008 on page 3.  
MS. MOE:  Your Honor, could we have just a very brief
sidebar about this issue?
THE COURT:  Can you tell me what paragraph I'm
reading?  And then yes.
MS. MENNINGER:  It's going to be on page 4 at the end
of the paragraph that began on the page 3, the last sentence.
(Continued on next page) 
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LC1Qmax2                 Jane - Cross
(At the sidebar) 
MS. MOE:  Thank you, your Honor.  And I apologize for
asking for a sidebar, but I'm hoping this will streamline
things.  The issue is at a number of times the witness has
testified that she doesn't recall, and instead of showing the
witness the document and asking if that refreshes her
recollection, which is the only thing that would be proper at
that juncture, I believe counsel is now just reading reports
into the record, which is not proper.
THE COURT:  Well, the question was yesterday you
testified --
(Pause) 
THE COURT:  So, yes, she said she didn't remember if
Epstein directed where they sat.
MS. MENNINGER:  Your Honor, under 613, I'm not
obligated to show the witness a prior statement before I ask
her about it.  I have to give her an opportunity --
THE COURT:  She said she didn't remember.  What's the
inconsistency?
MS. MENNINGER:  Well, your Honor, her not remembering
I don't have to refresh her recollection.  Her memory is at
issue in this case.  If she can't remember what she said a
month ago or two months ago or a year ago, that's relevant to
the jury's determination.  Then we can put on evidence through
other witnesses that that is in fact what she said to the
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax2                 Jane - Cross
government on that date.
THE COURT:  Your theory is everything that she -- when
you ask her, "What did you say on this date to the government,"
she says, "I don't remember."
MS. MENNINGER:  Her story has changed like a hundred
thousand times, and that is exactly what the problem is here,
your Honor.
THE COURT:  Well, here's the problem:  There is a way
you can get in her story has changed, but what you're doing and
what -- I don't know what the limits to this would be.  You're
asking her very specific questions about multiple instances of
reporting, and when she said "I don't remember what I said in
that moment," you're then introducing the statements of what
she said.
MS. MENNINGER:  I can say, isn't it true that you said
this?  That's the other way to phrase it.
THE COURT:  You could say "do you recall saying this
to the government"?  If she says no, then you move on.
MS. MENNINGER:  Right.  That's all I've been doing.
THE COURT:  Is that right?
MS. MOE:  Yes, your Honor.  I think we're talking
about two different scenarios.  The first is, for example, if
Ms. Menninger asked the witness, "Did this meeting happen on a
particular date" or you know "were you living in the blue
house" for example.  If the witness says, "I don't remember,"
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LC1Qmax2                 Jane - Cross
then we're talking about refreshing her recollection with a
document.  If the witness says something that Ms. Menninger
believes to be inconsistent with a prior statement, the
question then is instead, not a document, but do you recall --
like isn't it true that you told the government X?  And if the
witness says, "I don't remember that," then that's the record.
If the witness says, "Yes, I said that," then that's the
impeachment.
The documents themselves are impeachment by collateral 
material.  The proper way to do this is to ask the witness 
whether she said something or not.  If she denies it, then the 
way to do that is through the witnesses to that meeting, and 
not by asking the witness to read a document that she didn't 
prepare into the record, which is what's happening. 
THE COURT:  Well, what I understand you to be saying
is you want first her to show it to her and see if it refreshes
her recollection.
MS. MOE:  Yes, your Honor, if she says she doesn't
recall.  If she denies the fact and the point is to impeach her
with a fact of a prior inconsistent statement --
THE COURT:  Well, I think the window of disagreement
is not just an inconsistent statement but that she doesn't
recall -- no, I think you're right.  So if she doesn't recall
what she said in a meeting, you can refresh her recollection as
to what she said.  If she says, "I didn't say that" or "I don't
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax2                 Jane - Cross
recall," you can say, "Didn't you say the following to the FBI
agent," and then --
MS. MENNINGER:  So I believe that I do not have to
refresh for impeachment, but I can ask her --
THE COURT:  You're claiming that because she doesn't
recall what she said, it's an inconsistent statement.  There's
not an inconsistency there.
MS. MENNINGER:  So, I can ask her, "Did you say this?"
She can say, "I don't recall."  And then I can say, "Isn't it
true you said it on this date?"  And she can say, "No, I
didn't" or "I still don't recall."
THE COURT:  Every trial I've been to with these
materials I've presided over -- and there's been a lot in ten
years -- this precise thing happens.  You testified X.  Didn't
you tell the agent some variation of x or Y.
I don't remember way said to the agent.   
You show them the 302.  Does that refresh your 
recollection, or didn't you -- and didn't you say if it doesn't 
refresh your recollection and then you get to do precisely what 
you're doing. 
MS. MENNINGER:  Your Honor, may I get the statute book
because it says right in 613.
THE COURT:  Sure.
MS. MENNINGER:  Yesterday I tried to show the witness
an exhibit and I was directing her to when the exhibit was made
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LC1Qmax2                 Jane - Cross
and what the date of the interview was, and nobody liked that.
So today I tried --
THE COURT:  I don't think I sustained an objection to
that.
MS. MENNINGER:  Well, I said here's the date and then
there was an objection at the time.  But in Rule 613(a), it
says:  When showing or disposing the statement during
examination.  When examining a witness about the witness' prior
statement, a party need not show it or disclose its contents to
the witness.  But the party must on request show it or disclose
its contents to an adversary party's attorney.
And so because I don't believe I have to show it to 
her.  If I want to prove it later with extrinsic evidence, she 
has to be given an opportunity to explain or deny the statement 
and the adversary party is given an opportunity to examine the 
witness about it.  That's the way I read that rule. 
THE COURT:  So the extrinsic evidence of a witness'
prior inconsistent statement.  My point is if she says she
doesn't remember, it's not an inconsistent statement.  You have
to get to a point of inconsistency.
MS. MENNINGER:  Here is the inconsistency.
THE COURT:  When you're doing it based on what she
testified to yesterday, if there's a difference, yes.
MS. MENNINGER:  That's what I've been trying to do.
THE COURT:  Here you're saying on this date you said
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax2                 Jane - Cross
Epstein told you where to sit.  She says, "I don't remember."
It's not an inconsistent statement.  That's the difference.
Then you can refresh her on what she said.  But if what you're
doing is -- right?  What's inconsistent about you saying, "You
said X to the agent," and she says, "I don't remember."  Is
that an inconsistency?  
MS. MENNINGER:  The statement that she gave yesterday
versus what her statement to the agent that's what I'm trying.
THE COURT:  I let you do that.  I let you do that.
Just now the example that drew the objection you said Epstein
didn't -- you told the agent you didn't sit next to Epstein and
she said "I don't remember."
MS. MENNINGER:  Okay.  So I will show her for that
type of example --
THE COURT:  But I agree with you if you have a prior
statement that is inconsistent with testimony, that's when
we're there.
MS. MOE:  Yes, your Honor and in that scenario, it's a
question:  Did you say that to the agent on this date?  If not,
showing the witness the document and asking her to read it into
the record.  The question is, did you make that statement?
MS. MENNINGER:  I just asked.
THE COURT:  I agree.  I think you did it right up
until this moment when we didn't have and inconsistent
statement?  We're in vigorous disagreement.
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LC1Qmax2                 Jane - Cross
MS. STERNHEIM:  Vigorously.
(In open court) 
(Continued on next page) 
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LC1Qmax2                 Jane - Cross
THE COURT:  Ms. Menninger, you can take off your mask.
I want to pause.  Counsel, one of the exhibits 
referenced was not in one of the jurors' binders, so I want to 
just correct that.   
Ms. Williams, can you let counsel know what exhibit it 
was? 
MS. MENNINGER:  My apologies, your Honor.  We'll get
that fixed.
THE COURT:  Thank you.  And thank you to the juror for
alerting us.  
MS. MENNINGER:  If there is anyone else that has a
problem.
Thank you, your Honor.   
THE COURT:  I apologize for that.  I'm grateful to the
jurors.  If anything like that happens, feel free to kind of
raise your hand in the moment and we'll have Ms. Williams as
she always does, make things right.
(Pause) 
THE COURT:  I think we're not in the binders at the
moment, so while Mr. Everdell is working on that, you'll
proceed.
MS. MENNINGER:  Thank you, your Honor.
BY MS. MENNINGER:  
Q.
I believe we were talking about you going to the movies
with Epstein and Ghislaine.  Do you remember that?
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LC1Qmax2                 Jane - Cross
A.
Yes.
Q.
And isn't it true that you told the government that you did
not sit next to Epstein in the movie theaters?
A.
I don't recall.
Q.
Okay.  If I could have you look at 3509-008, page 4, in the
binder sorry.  Just you.
A.
Sorry, 35 what?
Q.
It's in the first set.
A.
Okay.
Q.
She'll show it to you, I apologize.
THE COURT:  It's on the screen.
Q.
004 -- I'm sorry, page 4 of 008, and the top paragraph and
the last line of that top paragraph.
A.
Okay.
Q.
You told the agents that Epstein would decide where
everyone sat?
A.
Yes.
Q.
Correct?
MS. MOE:  Objection, your Honor.  Same issue.  The
question is whether that refreshes her recollection.
THE COURT:  Go ahead.
Q.
Does it refresh your recollection what you told the
government?
A.
Yes.
Q.
And what you told the government is that Epstein would
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax2                 Jane - Cross
decide where everyone sat, correct?
A.
Correct.
Q.
And you told them that you did not sit next to Epstein,
right?
A.
Right.
Q.
But when you were in the movie theater, nothing sexual was
happening; you weren't sitting next to him, right?
A.
Right.
Q.
Yesterday you spoke about the first time that you saw
Ghislaine without her clothes on, correct?
A.
Yes.
Q.
You said that happened shortly after the first incident in
the pool house, correct?
A.
Correct.
Q.
And you described that you were just hanging out and all of
a sudden Epstein demanded that you follow him upstairs, right?
A.
I'm sorry, can you clarify which --
Q.
The first time that you saw Ghislaine without her clothes
on is what you claimed.  Do you remember that?
A.
The first time I saw her without a top on was by the pool.
Q.
Yesterday Ms. Moe asked you about the first time you saw
Ghislaine without her clothes on.  Do you recall that?
A.
I -- I don't recall which question you were referring to or
I don't recall, sorry.
Q.
You don't recall the first time you saw Ghislaine without
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax2                 Jane - Cross
her clothes on?
A.
Yes, I do recall, but to be specific, topless or completely
naked?
Q.
The question from Ms. Moe was the first time you saw
Ghislaine with her clothes off, and you didn't have any
question about what she meant.
MS. MOE:  Objection to form.
THE COURT:  Sustained.
Q.
Yesterday you were asked:
"Q.
Did there ever come a time when you saw Ghislaine Maxwell
without her clothes on?"
Do you recall that question? 
A.
Yes.
Q.
And you said yes?
A.
Yes.
Q.
You didn't say her top or not her top?
MS. MOE:  Objection to form.
THE COURT:  Overruled.
Q.
Right?
A.
Right.
Q.
And you described a whole scenario where you claim you and
Epstein and Ghislaine went upstairs and there was fondling in a
room.  Do you recall relating that to this jury yesterday?
A.
Yes.
Q.
When you spoke with the government in December of 2019, you
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax2                 Jane - Cross
told them that you do not have a specific memory of the first
time with Ghislaine?
MS. MOE:  Objection to form.
THE COURT:  Sustained.
Q.
Yesterday did you give a specific memory of the first time
that you recall being in a massage scenario with Ghislaine?
A.
Yes.
Q.
All right.  And when you spoke with the government in
December of 2019, you told them you do not have a specific
memory of the first time with Ghislaine.
MS. MOE:  Objection to form.
THE COURT:  That's not a question.
Q.
Isn't it true that you told the government in December of
2019 that you do not have a specific memory of the first time
with Ghislaine?
MS. MOE:  Objection to form.
THE COURT:  Overruled.
A.
I don't recall.
Q.
You did not tell the government in December of 2019 about a
scenario of you following Ghislaine and Jeffrey upstairs and
the three of you were alone, correct?
A.
I don't recall.
Q.
In fact, there was a period of time that you claim that it
was just you and Jeffrey alone, and you had not been present
with Ghislaine?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax2                 Jane - Cross
MS. MOE:  Objection to form.
THE COURT:  Sustained.  I don't understand the time
frame of that question.
Q.
Yesterday you testified that it was shortly after the pool
house that you had this incident with Epstein and Ghislaine,
right?
A.
Right.
Q.
When you spoke with the government before, you said that
some period of time, months went by before you ever had an
incident with Ghislaine, correct?
MS. MOE:  Objection to form.
THE COURT:  I will sustain it.  You've drawn on
different meetings with the government.  You have to specify
which one you're talking about so that the witness can answer
whether she recalls or not.
Q.
Previously you told the government you do not have a
specific memory of your first time with Ghislaine.
MS. MOE:  Objection to form.
MS. MENNINGER:  This is just foundational to the next
question.
THE COURT:  But give a -- give what you are asking
about, give the date that you're asking about.
Q.
In December of 2019, you told the government you do not
have a specific memory of your first time with Ghislaine.
Moving on from that, because you do not have a 
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
specific -- 
MS. MOE:  Objection to form.
MS. MENNINGER:  That was just admitted.  I'm just
laying the foundation for the next question.  That was the last
thing.
MS. MOE:  Your Honor, I'm not sure what the question
is.
THE COURT:  You don't have a question yet.  Go ahead.
BY MS. MENNINGER:  
Q.
Because you have no specific memory of your first time with
Ghislaine in December of 2019, you have come up with that
memory in the last two years, the one you gave yesterday,
correct?
MS. MOE:  Objection to form.
THE COURT:  Overruled.
A.
I come up with -- I don't believe I've come up with a
memory, no.
Q.
Well, you gave a memory to the jury yesterday that you
didn't have in December of 2019, right?
A.
I don't recall.
Q.
You then later met with the government in February of 2020,
right?
A.
Right.
Q.
And what you told the government in February of 2020 is
that the first time you were involved with Ghislaine, there
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax2                 Jane - Cross
were two other girls there as well, correct?
A.
I don't recall.
Q.
At 3509-008, page 4, first full paragraph, beginning in the
middle of the paragraph.
MS. MOE:  And, your Honor, is the question whether
that refreshes the witness' recollection?
THE COURT:  That will be the question.  Go ahead.
Q.
Does it refresh your recollection to read the sentence
beginning with the first time?  Yes or no.
A.
Yes.
Q.
It refreshes your recollection, it's true that you told the
government that the first time with Maxwell, there were two
other girls there as well, correct?
A.
Correct, but the wording that was typed up on this isn't
correct, so I don't know how to --
Q.
Another typo by the government?
MS. MOE:  Objection, your Honor.
THE COURT:  Overruled.
Q.
It's another typo?
A.
Yes.
Q.
So, yesterday you gave a story that is different from
December 2019 when you had no specific memory and is different
from February 2020 when there were two other girls there as
well, correct?
MS. MOE:  Objection.  Compound.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax2                 Jane - Cross
THE COURT:  Sustained.
Q.
Yesterday you testified that there were times when
Ghislaine was in the room with you and Epstein, correct?
A.
Correct.
Q.
And you remember those times, right?
A.
Not all, but yes.
Q.
When you spoke with the government at the February 2020
meeting, they asked you if there were times where it was just
you, Epstein and Ghislaine in the room, and you said you were
not sure, correct?
A.
I don't recall.
Q.
You said you were not sure that ever happened, correct?
A.
I don't recall.
Q.
You were not sure where it happened, correct?
A.
I don't recall.
Q.
You only remembered being solely with Epstein and going
back to the group setting, correct?
A.
I don't recall.
Q.
It is true that you do not recall Ghislaine ever touching
you?
A.
That's not true.
Q.
When you spoke to the government in December of 2019 with
your lawyers there, and you told the government at that time
you are not sure whether Maxwell ever touched you during these
encounters, correct?
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
A.
I don't recall.
Q.
You told the government that you're not sure that Maxwell
ever kissed you, correct?
A.
I don't recall.
Q.
You told the government that Ghislaine never used sex toys
or vibrators on you, correct?
A.
That's correct.
Q.
You told the government that you don't recall Ghislaine
ever giving you a talk about how to massage Epstein, correct?
A.
I don't recall.
Q.
You told the government that Ghislaine never saw you
perform oral sex on Epstein, correct?
A.
That's correct.
Q.
You told the government that Ghislaine never saw you
perform hand jobs on Epstein, to use your words, correct?
A.
I don't recall.
Q.
You told the government that Ghislaine never saw you
involved in any masturbation with Epstein, correct?
A.
I don't -- know or I don't recall.
Q.
You told the government that Ghislaine never saw you
engaged in sexual intercourse with Epstein, correct?
A.
Correct.
Q.
You told the government you have no memory of Ghislaine
being present when you claim Epstein engaged in any sexual
contact with you, correct?
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477
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
A.
I'm sorry, can you repeat that?
Q.
You told the government you have no memory of Ghislaine
being present when you claim Epstein engaged in any sexual
contact with you, correct?
A.
I don't recall.
Q.
You told the government that Ghislaine never discussed any
sexual abuse with you, right?
A.
Whether she discussed abuse with me?
Q.
Right.
A.
Right.  
Q.
It was very compartmentalized.  It was never discussed.
A.
Yes.
Q.
No one gave you any feedback afterwards.  It was never
mentioned, right?
A.
Right.
Q.
No one asked you if Epstein had fun, right?
A.
I don't recall.
MS. MENNINGER:  Can I have one moment, your Honor?
THE COURT:  You may.
(Pause) 
Q.
So if we could go back to your conversations with the
government in February of 2020, and if I could direct your
attention to 3509-008 at page 5, in the second paragraph, I'm
going to ask you if this refreshes your recollection?
MS. MOE:  Your Honor, about what?
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478
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
THE COURT:  Yes.
MS. MENNINGER:  Something that she earlier said she
doesn't recall.
THE COURT:  Well, you will have to ask it again.
MS. MENNINGER:  I will.
THE COURT:  You will ask the question again.
Q.
Before she does it, okay.
You said you don't recall whether or not you ever told 
the government that you and Ghislaine and Jeffrey were alone 
together in the room.  You were not sure that ever happened.  
Do you recall that testimony? 
A.
I don't recall that, no.
Q.
If I could have you look at 3509-008, page five, the last
paragraph, the first sentence in that paragraph, if you could
read that to yourself, tell me whether that refreshes your
recollection?
A.
It doesn't, but I read it, yeah.
Q.
So, what you told the government on February 27, 2020 --
MS. MOE:  Objection, your Honor.
THE COURT:  Overruled.
Q.
 -- is that when asked if there were times when it was only
you, Epstein and Ghislaine in the room, you said you were not
sure, correct?
A.
That's what it says.
Q.
You were not sure that ever happened in February of 2020,
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479
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax2                 Jane - Cross
right?
MS. MOE:  Your Honor, objection.  Is the question
whether she made the statement, whether she remembers it,
whether she's reading it from a document it's very unclear.
THE COURT:  You will rephrase, please.
Q.
As you sit here today, you're not sure whether you were
ever in the room alone with Ghislaine and Epstein, correct?
A.
No.
Q.
I asked you if you recall telling the government that
Ghislaine never touched you?
A.
I don't recall that.
Q.
If I could have you take a look at 3509-005.  That's going
to be difficult.
On page 3 of 3509-005, in the second full paragraph in 
the middle of the paragraph there's a sentence that begins with 
your name, and I would like you to read that and tell me if 
that refreshes your recollection that you said that to the 
government in December of 2019? 
A.
Which paragraph?
Q.
The second full paragraph in the middle of the paragraph
beginning with your name.
A.
Yes.
(Continued on next page) 
 
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480
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
BY MS. MENNINGER:  
Q.
Does that refresh your recollection that you told the
government you do not have a recollection and are not sure if
Ghislaine touched you during these encounters; correct?
A.
I don't recall.
Q.
Isn't it true that's what you told the government on that
date?
A.
I don't remember, but it's written here.
Q.
I want to turn back to your statement that you don't recall
whether you ever told the government that Ghislaine did not see
you performing oral sex on Epstein.  Is that what you told the
government?
A.
I don't remember.
Q.
If I could have you look at 3509-008 at page 10.  And I ask
you to look at the first full paragraph and the last sentence
of that paragraph.  Does that refresh your recollection of
whether Ghislaine was ever present for instances of oral sex
between you and Epstein?
A.
Correct.
Q.
It's true that you don't know whether Ghislaine was ever
present for you having oral sex in any way with Epstein;
correct?
A.
I don't remember.
Q.
That's what you told the government, didn't you?
A.
I don't remember.
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481
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
MS. MENNINGER:  Your Honor, is now an appropriate time
for a break?  I was about to start another area.
THE COURT:  All right.  We can take our morning break.
Members of the jury, we'll take about a ten-minute 
break.  Thank you. 
(Jury not present) 
THE COURT:  Matters to take up, counsel?
Just a moment.  You may step out, Jane.  Thank you. 
Everyone may be seated.
MS. MOE:  Thank you, your Honor.
Just two --
THE COURT:  Just a moment.  Go ahead.
MS. MOE:  Thank you, your Honor.
Two issues to raise. 
The first is the issue that we raised earlier this
morning about the remaining anonymity issue.  Happy to raise
that at this time, if it's appropriate.  I don't know if it's
coming up soon in cross-examination.
THE COURT:  Okay.
MS. MOE:  But we would prefer to raise that at sidebar
because it relates to anonymity.  
The second issue is the Rule 408 issue I flagged this 
morning relating to documents we received a few minutes before 
the beginning of the court day.  Happy to front that issue now 
while we have a break if the Court would like to hear that 
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482
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
issue. 
THE COURT:  Okay.  Go ahead.
MS. MOE:  So with respect to the Rule 408 issue,
defense counsel has provided the government this morning just
before the Court day with a few documents they've marked as
exhibits.
THE COURT:  One moment.  Go ahead.
MS. MOE:  Those two documents are correspondence
between Jane's attorney and the victim compensation fund, as
well as correspondence from Jane's attorney and Ms. Menninger's
law firm.
To the extent defense counsel intends to offer these 
as exhibits, there's a Rule 408 issue here. 
MS. MENNINGER:  I don't, your Honor.
THE COURT:  Okay.
MS. MOE:  I just want to ensure any questions about
this are framed as Jane's knowledge about the litigation and
not asking for her to testify about documents that aren't in
evidence, that she may not have seen, that are prepared by
attorneys.  In order to avoid confusion, we want to make sure
that any questions about civil litigation are about what she
knows or doesn't know.  I want to avoid a scenario in which a
lay witness is shown legal documents and asked to read them
into the record or testify to them beyond the scope of her
knowledge.
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483
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
THE COURT:  So that's not a 408 issue, it's a scope of
knowledge issue.
MS. MOE:  Yes, your Honor.
It's a 408 issue to the extent the questions are about 
negotiations related to settlements which would only be 
admissible in order to show bias under the second prong of the 
rule.  And that's where the scope of knowledge issue comes into 
play, because facts along those lines would only be relevant 
under Rule 408 if this witness were aware of them.  So we just 
wanted to make sure any examination was cabined along those 
lines. 
THE COURT:  Ms. Menninger?
MS. MENNINGER:  Your Honor, in those two documents,
the attorney in a civil matter for this witness demanded sums
of money.  And there was one in the civil case.  He was acting
in his capacity, and she was a party in that case, and he was
her lawyer.  So his statements are adoptive admissions by the
party from that case that she was demanding the money that's
claimed in that letter.  That's the first one.
THE COURT:  And so what do you expect to do?  You
expect to ask what?
MS. MENNINGER:  You were demanding $25 million to
settle your civil law claim while Ms. Maxwell was pending in
this criminal case, I might add.  That's the first one.
THE COURT:  Okay.  So the question is, Were you
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484
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
demanding $25 million in civil litigation while this criminal
case was pending?
MS. MENNINGER:  Yes, your Honor.
THE COURT:  Okay.
MS. MOE:  Yes, your Honor.
As long as it's framed in terms of her knowledge; we 
have no objection to what she knows about or was involved in.   
What we want to avoid is a scenario where following a 
question like that, a legal document exchanged between 
attorneys was then shown to the witness to refresh her 
recollection, and this witness was asked to read into the 
record comments her attorney made, which would not be 
admissible under Rule 408 if she doesn't know about them 
because they can't speak to her bias if she is not aware of 
those communications. 
THE COURT:  So just to spin out the question, Were you
demanding $25 million during -- in a civil lawsuit while this
criminal investigation was pending?  
I suppose one response would be I don't know, one 
response is yes, and one response is no.   
So if the response is yes, you move on? 
MS. MENNINGER:  Yes.
THE COURT:  If the response is I don't know, what do
you do?
MS. MENNINGER:  Refresh her recollection with her own
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485
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
attorney's letter to my law firm in which he's demanding that
and the date of the letter.  If she wants to say she doesn't
know what her civil attorney is doing acting on her behalf, I
guess she could say that.
THE COURT:  Okay.  So if it doesn't refresh her
recollection, we move on.  And then if the answer is no, what
then?
MS. MENNINGER:  Well, your Honor, that leads to a
potential scenario with her attorney being a witness.  But I
think we would cross that bridge on another day.
MS. MOE:  Yes, your Honor.
The question remains about her knowledge.  And again, 
if we're refreshing this witness's recollection with a document 
she hasn't seen, I just want to make sure that the question is 
very precisely framed.  Because there have been a number of 
times already this morning where the witness has been asked to 
just read the document and has given answers like, I don't 
know, but I guess that's what this says, which is beyond the 
scope of refreshing a recollection.  So I just want to ensure 
we're not asking this witness to read into the record hearsay 
statements of her attorney which she doesn't have knowledge. 
THE COURT:  If she says, I don't know, you can try to
refresh her recollection.  The question is, Does this refresh
your recollection?  If the answer is no, we move on.  And then
you do --
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486
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
MS. MENNINGER:  We cross bridges that -- 
THE COURT:  Right.  
And if the answer is -- so she says no.  And you show 
it to her and ask if that refreshes her recollection.  And if 
the answer is no, we move on.   
MS. MENNINGER:  The second one, your Honor, is in the
victims' compensation program.  As your Honor may have seen,
she was offered an award.  And after that award was offered,
her lawyer -- the same lawyer in that proceeding -- wrote
basically a motion for reconsideration and said that the award
was not appropriate; that it should at least be an eight-figure
award.  So that delayed the whole -- you know, her decision to
join in the -- or to accept the award.  And I believe that is,
again, an adoptive admission or a statement because he was
acting in her capacity as her lawyer in a civil case while this
criminal case was pending.
THE COURT:  So what's the question you'll ask.
MS. MENNINGER:  They are the same, your Honor.  It's
essentially, Didn't you get offered an award of $5 million and
felt that that was not sufficient?  And your attorney, on your
behalf, went back to the claims program and asked for an
eight-figure settlement instead.
MS. MOE:  Yes, your Honor.
Again, the substance of that testimony would only be 
relevant under Rule 408.  If this witness knows about it and, 
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487
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
thus, it's offered about her particular bias -- 
THE COURT:  Well, you heard the question.
MS. MOE:  Yes, your Honor.
THE COURT:  Do you object to the question?
MS. MOE:  We do object to the question.  If the
question is, Did you seek an increased amount in the settlement
award, I have no objection to that.  If the question is, Isn't
it true your attorney made the following statement, that
question is objectionable.
THE COURT:  Under 408.
MS. MOE:  Yes, your Honor.
MS. MENNINGER:  Your Honor, it goes to bias, her
motive to testify in this case, and her bias against my client.
THE COURT:  Let's start with a more basic issue which
no one has briefed, but Manko v. United States, are you
familiar?
MS. MOE:  I'm not, your Honor.
THE COURT:  87 F.3d 50 (2d Cir. 1996).
I'll quote:  "the policy that underlies Rule 408 does 
not apply to criminal prosecutions.  The policy favoring the 
encouragement of civil settlements sufficient to bar their 
admission in civil actions is insufficient, in our view, to 
outweigh the need for accurate determinations in criminal cases 
where the stakes are higher."   
Is that good law? 
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488
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
MS. MOE:  Your Honor, I'm not -- I take the Court at
its word.  I'm not familiar --
THE COURT:  I mean, that's what it says.  I'll admit
there may be some complications, but I'd like to know the
government's position on that.
MS. MOE:  Yes, your Honor.  We'd be happy to take a
quick look into it.
THE COURT:  It will probably take more than a quick
look.  It's complicated.  That case is in the context of the
defense seeking to introduce civil litigation settlement.  Is
defense aware of this case?  Anybody have knowledge?  No.
Who reads Second Circuit cases? 
In the context of the defense seeking to introduce,
the rule was subsequently amended, there's been no intervening
Second Circuit interpretation.  The rule is amended because the
government wanted some ability to introduce in some context
civil settlement matters.  So the rule has been changed now, by
its terms, at least, not in the case of motive and bias, it
does appear to apply in criminal settings.  But I don't think
that the amendment, which was not -- I don't think that
amendment is sufficiently overruling of the Second Circuit
decision for me not to be bound by that Second Circuit
decision.  But you'll, I'm sure, take a look at that issue.
MS. MOE:  Yes, your Honor.
And just to widen the aperture of the issue, what
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489
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
we're talking about is impeachment.  And so a statement or an
issue of bias that's being offered for impeachment, whether
we're talking about a Rule 408 issue or otherwise, is only
relevant and permissible if this witness knows about it.
THE COURT:  I agree there are personal knowledge
questions in issue.  I did ask you specifically if it was a 408
issue, and you said yes.  You're on your feet, of course, now,
and have to respond to me quoting a Second Circuit decision at
you.  And, of course, district courts are required to follow
Second Circuit precedent even if its intention was subsequent
changes in the law, unless and until the case is reconsidered
by the Second Circuit sitting en banc or its equivalent or is
rejected by a later Supreme Court decision.
So I do think there may be a question of the change in 
the rule and what the scope of that was and whether it 
overturns the Second Circuit decision such that I'm not bound 
by it.  I doubt it.  Separate and apart from that is the 
question of whether she has personal knowledge of what her 
attorneys did, right. 
MS. MOE:  Yes, your Honor.
THE COURT:  It's not a 408 issue, it's a foundation
question, personal knowledge question.  
Ms. Menninger made an argument that in the civil 
litigation context, she could be assumed to have adopted the 
position of her attorneys.  I think we do get to that bridge, 
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490
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
if we need to cross it, so let's see if there's a memory -- if 
there's an awareness or not.  And if she doesn't know and the 
answer is no, I think we'll move on until I hear from you as to 
how it might come in. 
MS. MOE:  Thank you, your Honor.
And we'll look into the Rule 408 issue.  If we have 
that wrong, we'll certainly withdraw that objection.  And I 
appreciate the Court flagging that. 
THE COURT:  I assume that's why you hadn't raised 408
in your motion to quash.  In any event, one of the parties
raised 408, so we looked at it and that was as far as we got.
Anything else?
MS. MOE:  Yes, your Honor.  
There was just that brief anonymity. 
THE COURT:  Oh, yes.  Let's do that at sidebar.
MS. MOE:  Thank you, your Honor.
(Pages 491 to 495 SEALED) 
(Continued on next page) 
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
(In open court) 
THE COURT:  Five minutes.
(Recess) 
THE COURT:  Matters to take up?
MS. MOE:  Not from the government, your Honor.
MS. MENNINGER:  No.  Thank you, your Honor.
THE COURT:  We can bring the witness.
And Ms. Williams can bring in the jury. 
Mr. Everdell, did you get the binders squared away for
the jurors?
MR. EVERDELL:  Your Honor, I did look, and the one
juror referenced the letter of recommendation.  And those, I
think, would have been with the Interlochen applications.  And
I looked at all of those in both binders, and they look to be
complete.  I just think that he or she may have missed the
page.
THE COURT:  Okay.  All right.
So maybe we'll take -- really make sure we're taking 
time to direct them -- 
(Jury present) 
THE COURT:  All right.  We will resume, Ms. Menninger,
with your cross-examination of witness Jane.
And Jane, I remind you, you are under oath.   
Go ahead, Ms. Menninger. 
MS. MENNINGER:  Thank you, your Honor.
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497
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
BY MS. MENNINGER:  
Q.
Yesterday you testified about the first time you were
abused, you claim, by Epstein.  Do you recall that testimony?
A.
Yes.
Q.
You said that it occurred in a pool house in Florida;
correct?
A.
Correct.
Q.
His Palm Beach home; correct?
A.
Correct.
Q.
The Palm Beach home that you went to, you say, for all
three years; correct?  Fourteen through 16.
A.
Correct.
Q.
And the very first time that you were abused would be a
very important part of your story, you would agree; correct?
A.
Correct.
Q.
But when you talked to the government in December of 2019,
isn't it true that you told them that the first time you were
abused was in New York?
A.
That is not correct.
Q.
Isn't it true that you said you were in New York and you
were abused when you went up there to take headshots?
A.
I don't recall.
Q.
If I could direct your attention to 3509-005 on the second
page.  It's going to be the second paragraph up from the
bottom.
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498
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
A.
Yes.  And with all due respect, I didn't write any of this
and I've never read this document because this is incorrect.
Q.
So you're denying that you made the statement your first
experience of abuse was when you were 14 years old in New York,
you met Epstein to take headshots, and that is when he
masturbated?
A.
Yeah, this is incorrect.
Q.
When you first talked to the government in December of 2019
about traveling to New York, you told them that on your first
trip nothing inappropriate happened; correct?
A.
I don't recall.
Q.
You told the government that your first trip was to just go
and have fun; correct?
A.
I don't recall.
Q.
If I could direct your attention to your statement from
September of 2019, which is 001, at the second page.
MS. MOE:  And I'd object to characterizing it as her
statement.
THE COURT:  Sustained.
MS. MENNINGER:  I'm sorry, what?  I didn't hear it.
MS. MOE:  I'd object to characterizing this as her
statement.  I think the witness has been very clear these are
not her statements.
MS. MENNINGER:  I didn't hear it.  I apologize, your
Honor.
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499
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
THE COURT:  I sustain.
Q.
You spoke with the government in September of 2019;
correct?
A.
Correct.
MS. MENNINGER:  I apologize.  I may be on the wrong
page.  I'll find that in a minute.  And I apologize.
Q.
If I can direct your attention to a discussion you had with
the government in February of 2020, where you told them that
the first trip to New York was just to go and have fun.  Is
that true?
A.
I don't recall.
Q.
Okay.  If I could have you take a look at 008 on page 8.
And it's going to be in the fourth full paragraph.
Does that refresh your recollection about what you 
told the government in February 2020 about your first trip to 
New York? 
A.
Like I said, with all due respect, I didn't write any of
this.  I've never read this before.  And I was never recorded.
This was just somebody jotting down notes, and so a lot of this
is out of sequence and incorrect.
Q.
Does that refresh your recollection about what you told the
government about your first trip to New York?
A.
No.
MS. MOE:  Asked and answered, your Honor.
THE COURT:  The answer is no.
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500
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
You may proceed. 
Q.
Isn't it true you told the government on that occasion that
your first trip to New York was just to go and have fun?
MS. MOE:  Asked and answered, your Honor.
THE COURT:  Sustained.
A.
No.
THE COURT:  I sustained.  If I sustain, pause.  And
then if I overrule, you can answer.
Go ahead, Ms. Menninger. 
BY MS. MENNINGER:  
Q.
And it was later when you were talking to the government in
April of 2020 that you said you only specifically recalled one
incident in New York where Ghislaine was present; correct?
A.
I don't recall.
Q.
If I could have you take a look at 3509-004.  Okay.  I'm
sorry, 3509-003.  Excuse me.  And it's on the second page in
the second full paragraph.  If you could look at that second
sentence in the second paragraph regarding how many incidents
in New York.
MS. MOE:  And, your Honor, is the question whether
that refreshes her recollection or --
MS. MENNINGER:  Right.  I'm having her take a look at
it.
Q.
And does that refresh your recollection?
A.
What page is this?
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501
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
Q.
On page 2.  3509-03, page 2.
A.
What is the question?
Q.
Do you recall -- does this refresh your recollection about
how many incidents in New York you recall with Ghislaine
present?
A.
I don't think I have the correct page.
THE COURT:  You're directing to the second full
paragraph, second sentence?
MS. MENNINGER:  Yes, your Honor, the second full
paragraph on page 2.  The paragraph begins with "Maxwell."  The
second sentence of that paragraph.
MS. MOE:  I also object as mischaracterizing.
THE COURT:  Sustained.
Q.
Did you tell the government that you recall one incident in
New York where Maxwell was present?
MS. MOE:  Same objection, your Honor.
THE COURT:  Sustained.
A.
Well, this one says --
THE COURT:  Just a second.  Go ahead.
Q.
Did you tell the government you recalled at least one
incident in New York where Maxwell was present?
A.
Yes.
Q.
And that's what you relayed to them on that day; correct?
MS. MOE:  Your Honor, again, I'd object to
mischaracterizing these documents.  It's very confusing for the
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502
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
witness.
THE COURT:  You've asked already do you recall having
made that statement and the answer, I think, is yes?
THE WITNESS:  Yeah, for at least --
THE COURT:  Okay.
Q.
You recall at least one incident in New York?
THE COURT:  Are you asking that as a question of her
memory now or are you asking her if she remembers relaying that
to the FBI?
Q.
Yes, do you remember that now?
A.
Yes.
Q.
Okay.
MS. MOE:  Your Honor, which was that about, her memory
or whether it happened?
THE COURT:  It was rephrased as about her memory now.
Next question, Ms. Menninger. 
Q.
That was a conversation you had in November of 2019 with
the government; correct?
A.
Correct.
Q.
And then by April of 2020, you reported to the government
that you were abused 90 percent of the time you traveled with
Epstein and Maxwell; correct?
MS. MOE:  Objection, your Honor.
THE COURT:  Overruled.
A.
Correct.
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503
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
Q.
So you went from nothing inappropriate happened to being
abused 90 percent of the time; correct?
MS. MOE:  Objection, your Honor.  Mischaracterizes --
THE COURT:  Sustained.
Q.
Has your story changed about how many times you remember
abuse over the course of your discussions with the government?
A.
No, and I didn't understand exactly the question.
Q.
In September of 2019, when you first met with the
government, you told them that you flew with Ghislaine and
Epstein to New York to see The Lion King; correct?
A.
Correct.
Q.
You told them that you flew to New York for the first time
with them to see The Lion King; correct?
A.
I said that, but I was incorrect in my timeline.
Q.
You said that happened when you were 14, right?
A.
Yes.
Q.
And that's the trip where you said nothing inappropriate
happened; correct?
A.
I don't recall.
Q.
And you were, as we've seen, a student of theater and the
arts at the time; correct?
A.
Correct.
MS. MOE:  Objection to form.
THE COURT:  Overruled.  You may answer.
A.
Correct.
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504
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
Q.
A student of the arts would be pretty excited about their
first trip to see a Broadway show; correct?
A.
Correct.
Q.
Especially The Lion King when it came out; correct?
A.
Correct.
Q.
And it would also be memorable to a young person to have
their first trip on a private jet; correct?
A.
Correct.  But, once again, my timeline was wrong.
Q.
Well, you told them that in September of 2019, right, when
you first met with them?
A.
I did say that, yes.
Q.
You repeated that same story in December of 2019; correct?
A.
I don't recall.
Q.
You repeated that story in February of 2020; correct?
A.
I don't recall.
Q.
All right.  I'll have you take a look at 3509-005 at 6 to
7.  I apologize.  001 at page 2.
THE COURT:  What paragraph?
MS. MENNINGER:  I'm having a little trouble with my
glasses.  Just a moment, your Honor.  I apologize.
THE COURT:  Okay.
MS. MENNINGER:  Third paragraph, your Honor.  Sorry.
THE COURT:  Third full paragraph?
MS. MENNINGER:  Yes, your Honor.
THE COURT:  Okay.
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505
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
MS. MOE:  Your Honor, I apologize.  I'm confused.  
I think the question was about a number of different 
meetings, but we're now looking at the same notes.  I think 
there's a confusing suggestion that we're talking about -- 
THE COURT:  Okay.
BY MS. MENNINGER:  
Q.
The first time that you met with the government, you told
them that you were flown to New York by Epstein and Maxwell to
see The Lion King, right?
MS. MOE:  Objection.  Asked and answered.
THE COURT:  Just a moment.
Do you need a break? 
THE DEPUTY CLERK:  Yes.
THE COURT:  Go ahead.
(Jury not present) 
THE COURT:  You can be seated.
Let me find out what's happening. 
(Recess) 
THE COURT:  Just to be clear, it looked like a witness
was having a coughing issue or sickness or something.  That a
juror, apologize.
(Pause) 
THE COURT:  Happy to report she's fine.  She felt like
something was stuck in her throat.  She's getting some water
and a cough drop and we'll resume.  The juror, to be clear.
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506
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
MS. MENNINGER:  I've been provided a light by
Ms. Sternheim to see.
THE COURT:  Oh, great.  These courtrooms are dark.
(Jury present) 
THE COURT:  All right.  Everyone please be seated.
Okay.  Everybody is okay.  I know it's always alarming
to know you have to travel in a group always, but do let us
know if you need anything.  Thank you, everyone.
Ms. Menninger, you may continue with your cross.
MS. MENNINGER:  Thank you, your Honor.
BY MS. MENNINGER:  
Q.
So I think we were talking about in September of 2019 you
agreed that you had told the government about flying to New
York with Maxwell and Epstein to see The Lion King; correct?
A.
I did not say that.  Incorrect.
Q.
Okay.  If I can show you 3509-001, page 2, third paragraph.
A.
Yes, I see that.  And it's incorrect.  This is not a
transcript of mine.  Nobody ever recorded me saying any of my
statements.  And I'm reading it right now and a lot of these
are not correct.
Q.
So you did not tell the government in September of 2019
that when you were 14 years old, you flew with Epstein and
Maxwell to New York City to see The Lion King?
A.
I flew with them to New York City and I had mistaken that
we were going to see The Lion King, but that was a different
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507
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
trip.
Q.
But you did say it, but you learned later you were wrong;
correct?
A.
Yes.
Q.
All right.  So let's turn to when you learned that you were
wrong.  Your attorney -- you repeated it a few times though, I
guess that's my point?
MS. MOE:  Objection, your Honor.
Q.
That was the only time you told the government that you
flew to New York to see The Lion King with Epstein and Maxwell?
MS. MOE:  Objection, your Honor, to form.  It's an
argument, not a question.
THE COURT:  Overruled.
A.
No, it's not the only time.
Q.
You told it to them a couple times before you found out you
were wrong, right?
A.
No.
Q.
Okay.  Well, let's go to your conversation in February of
2020, 008, page 8.  And at that time you told the government
your first trip to New York was to just go and have fun.  It
may have been the trip that you went to see The Lion King,
right?
MS. MOE:  Objection, your Honor.  It's not
inconsistent and, again, this is misleading.
THE COURT:  You can --
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508
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
MS. MENNINGER:  Refresh?
THE COURT:  Yes, you can ask if it refreshes.
Q.
Does reading the second sentence of the fourth paragraph
refresh your recollection about what you told the government in
February of 2020?
A.
No.
Q.
You don't remember saying it then?
A.
No.
Q.
Isn't it true what you said to the government in February
2020 is that your first trip to New York was to just go and
have fun, this may have been the trip to see The Lion King?
MS. MOE:  Objection.  Asked and answered.
THE COURT:  Sustained.
Q.
After this meeting in February 2020, your email -- your
lawyer was Mr. Glassman at the time; correct?
A.
Correct.
Q.
Mr. Glassman got an email from a prosecutor,
Mr. Rossmiller; correct?
MS. MOE:  Objection to foundation, your Honor.
MS. MENNINGER:  I'm not asking the contents.
THE COURT:  Do you know?
THE WITNESS:  I don't know.
THE COURT:  Okay.
Q.
At some point did your attorney, Mr. Glassman, come to you
with a question?
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509
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
MS. MOE:  Objection.  Privileged.
THE COURT:  Sustained.
MS. MENNINGER:  Your Honor, it was communicated to the
government, so the privilege had been waived.
MS. MOE:  Your Honor --
THE COURT:  He didn't ask -- I sustained.
MS. MOE:  Thank you, your Honor.
THE COURT:  The question as phrased, sustained.
Q.
Do you know whether your attorney ever communicated to the
government an answer regarding The Lion King and Broadway?
MS. MOE:  No objection, your Honor.
THE COURT:  Good.
MS. MENNINGER:  I know Ms. Moe would like to come do
this for me, but --
MS. MOE:  I do object to that, your Honor.
THE COURT:  All right.  Everybody calm down.  The
question is not objected to nor objectionable.  You may state
it again, Ms. Menninger.
BY MS. MENNINGER:  
Q.
Do you know whether your attorney communicated to the
government -- communicated with the government about your
experience with The Lion King and going to New York?
A.
No, I don't know.
Q.
Could looking at 3509-10 refresh your recollection?
MS. MOE:  Your Honor, I object.
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510
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
The witness testified that she doesn't know, not that 
she doesn't remember. 
THE COURT:  Overruled.
You can ask if this refreshes.  This is precisely what 
we talked through.  You can ask if it refreshes her 
recollection. 
A.
What is the question?  Sorry.
Q.
Does this refresh your recollection about your attorney
communicating with the government about The Lion King and
Broadway?
A.
Yes, but it doesn't reference the timeline, if that was the
original question.  I'm sorry.  I'm confused.
Q.
Is it true that your lawyer communicated to the government
your recollection that, in fact, you had seen The Lion King
Broadway show and not the movie?
A.
Oh, yes, I -- we did see the show.
Q.
And you recalled seeing the Broadway show; correct?
A.
Correct.
Q.
And you recalled sitting in the mezzanine seats; correct?
A.
Correct.
Q.
And you recalled that Epstein bragged about getting those
seats because he knew the director; correct?
A.
Correct.
Q.
And your attorney communicated all of that to the
government; correct?
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511
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
A.
That's correct.
Q.
And that was in response to a question from the government
to you through your attorney; correct?
A.
Correct.
Q.
That's because the government communicated to you through
your attorney that The Lion King didn't come out until 1997;
correct?
A.
Correct.
Q.
So although you had told the government twice previously
that you flew to New York with Maxwell and Epstein when you
were 14, you learned that the Broadway show didn't come out
until you were 17; correct?
A.
That's right.  But that wasn't the first time that we'd
flown.
Q.
The government suggested to you that perhaps you meant to
say The Lion King movie through your attorney to you; correct?
MS. MOE:  Objection, your Honor.
THE COURT:  Sustained.
Q.
Did Mr. Glassman share with you the email that he got from
the government?
MS. MOE:  Objection.
THE COURT:  Sustained.
Q.
You knew at the time you communicated the information to
Mr. Glassman that he intended to share it with the government;
correct?
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512
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
MS. MOE:  Objection, your Honor.
THE COURT:  Sustained.
MS. MENNINGER:  Your Honor, that's how we establish a
waiver of the privilege.
MS. MOE:  Objection, your Honor.
THE COURT:  Sustained.
Q.
When you first talked to the government about traveling to
New Mexico, you told them that you were ignored on that trip;
correct?
A.
I don't recall.
Q.
You recall telling the government that the first time you
went on a private plane to New Mexico, you were not doing much
and just sitting around; correct?
A.
I don't recall.
Q.
Okay.  Look at 3509-008 at page 6, and the second full
paragraph, in the middle of the paragraph.  Do you recall
telling the government that the first time you went to New
Mexico on Epstein's plane you were somewhat ignored?
A.
No, I don't recall.
Q.
Do you recall that you were told to go hiking?
A.
I don't recall.
Q.
Do you recall saying you were not impressed?
THE COURT:  I need you to clarify.  You're again
switching between asking if it's a memory now or whether she
remembers having said that to the government.
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513
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
Q.
As you sit here today, do you remember not being impressed
when you went to New Mexico for the first time on the private
plane?
A.
I don't recall saying that.
Q.
No.  Do you recall as you sit here today that you were not
impressed when you first went to New Mexico on a private plane?
A.
No.
Q.
You do not recall any abuse happening when you first went
to New Mexico; correct?
A.
That's not correct, no.
Q.
That's what you told the government in February of 2020;
correct?
A.
No, that's not correct.  Like I said, this is not a
transcript of mine.  This is the first time I'm reading it and
it's not correct.
Q.
All right.  I'm going to direct your attention to 3509-008,
page 7, the last full paragraph.  Does that refresh your
recollection about what you told the government about your
first trip to New Mexico?
A.
No, it doesn't.
Q.
And isn't it true you told the government in February of
2020 that on your first trip to New Mexico, you recalled going
hiking, remembered not doing too much, just sitting around
mostly, and did not recall specific abuse that may have
occurred?
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514
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
A.
I don't recall this.
Q.
Then I would like to direct your attention to the last
sentence on that same page, where you were asked again if you
recalled any specific abuse that occurred in New Mexico, and
then turning to the next page, you stated you were not sure.
THE COURT:  Do you have a question?
Q.
Does that refresh your recollection now that you've seen
that on the page?
A.
No, it does not.
Q.
Isn't it true that's what you said to the government?
A.
I don't recall saying this.
Q.
And you also told the government that your memory of the
details of that location were not good; correct?
A.
I don't recall saying that.
Q.
Okay.  If you could look at the top of the second page --
I'm sorry, of page 8.  Does that refresh your recollection?
A.
No.
Q.
Isn't it true you told the government regarding New Mexico
the place was dark and you do not recall many of the details of
this location?  If there was abuse that occurred there, it
wouldn't have been a group thing, but she cannot recall -- you
cannot recall anything specific?
MS. MOE:  Objection, your Honor.
THE COURT:  What's the question?
MS. MENNINGER:  Well, I asked her if it refreshed her
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515
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
recollection, she said it did not.  Now I'm asking her if she
made the statement, and we haven't heard her answer yet.
THE COURT:  So the question is did you make the
statement?
MS. MENNINGER:  Yes.
THE COURT:  Okay.  You may answer that.
A.
No, I don't recall making these statements.
Q.
Then you were asked the same question by the government in
the same interview a third time; correct?
A.
I don't know.
Q.
I'm going to ask you to take a look at page 11, the top
paragraph, the first sentence.  Does that refresh your
recollection about you being asked a third time in the same
interview about abuse occurring in New Mexico?
A.
No, it does not.
Q.
Isn't it true what you told the government a third time was
that you were asked about the New Mexico trips you took and if
you recalled any specific abuse that occurred there, to which
you answered you did not remember; correct?
MS. MOE:  Objection.
THE COURT:  Sustained.
Q.
It didn't refresh your recollection --
THE COURT:  You said isn't it true that you told the
government a third time that you were asked about the New
Mexico trips.  I think you lost the thread.
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516
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
MS. MENNINGER:  Okay.
Q.
Isn't it true you told the government you do not remember
any specific abuse that occurred in New Mexico on the trips
that you took there?
A.
I don't recall.
Q.
And yesterday you testified about an incident in New Mexico
that you now specifically remember two years later.
A.
That's right.
Q.
Today you remember it; in 2020 you did not.
A.
I don't recall saying any of what's written here.
Q.
I'm going to ask you about the homes that you testified you
visited for Epstein in the mid 1990s, okay, between the ages of
14 and 16.
You recall in Palm Beach that you went to a pool
house; correct?
A.
That's correct.
Q.
And you only went to one house for Epstein in Palm Beach
ever; correct?
A.
Yes.
Q.
You remember the whole house in Florida was light-colored
and beachy; correct?
A.
I think so; correct.
Q.
You remember a winding staircase with pictures on the wall;
correct?
A.
Correct.
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517
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
Q.
You recall a massage room that was attached to the
bathroom; correct?
A.
That's my memory, yes.
Q.
And that's the description that you gave the government;
correct?
A.
Yes.
Q.
In New York, you described an eight-story mansion on the
Upper East Side; correct?
A.
Yes.
Q.
You started staying there when you were 14; correct?
A.
Correct.
Q.
That's the only home in New York that you visited of
Epstein's; correct?
A.
No.
Q.
You stayed in some apartments where he did not live;
correct?
A.
Correct.
Q.
And you stayed in this eight-story mansion beginning at the
age of 14; correct?
A.
Correct.
Q.
And you stayed on the eighth floor of this mansion, right?
A.
I believe so.
Q.
And Ghislaine didn't live in that mansion, right?
A.
I don't know.
Q.
You didn't see her living there; correct?
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518
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
A.
I don't know.
Q.
And you started staying there at the age of 14, right?
A.
Yes.
Q.
You recall a massage table being black in that home;
correct?
A.
Correct.
Q.
And then you remember going to New Mexico where there was a
giant ranch; correct?
A.
Correct.
Q.
An impressive, huge house, right?
A.
Like all of them.
Q.
What's that?
A.
I said like all of the homes, yes.
Q.
Right.  And there were other guests around in New Mexico;
correct?
A.
No.
Q.
Do you remember telling the government that Jeffrey's
brother Mark Epstein went with you on a trip to New Mexico?
A.
I don't recall saying that.
Q.
Do you remember telling the government that Chef Adam Perry
Ling went on a trip to New Mexico with you?
A.
I don't recall.
Q.
And you don't remember a massage room in the New Mexico
home; correct?
A.
I don't recall.
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519
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
Q.
In your time with Epstein, you never saw any other underage
girls around him; correct?
A.
I wouldn't know that, if they were.
Q.
Well, you told the government in 2019 that you thought you
were the only one; correct?
A.
Correct.
Q.
And you only learned otherwise, you said, when you saw the
news about Mr. Epstein's arrest in 2007 or 8; correct?
A.
Correct.
Q.
So none of the other participants in these orgies, I think
you called them, were underage; correct?
A.
I wouldn't know that.
Q.
That you thought you were the only one, right?
A.
Yes.
Q.
And you were never asked to go recruit other girls for
Epstein; correct?
A.
Correct.
Q.
You were not asked to have sexual contact with any of
Epstein's friends?
A.
No.
Q.
Epstein did introduce you to a number of people associated
with the arts, right?
A.
Not really, no.
Q.
He introduced you to the dean of Interlochen at a cocktail
party, right?
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520
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
A.
I don't remember.  Maybe.
Q.
Well, in December of 2019, you told the government that he
had introduced you to the dean of Interlochen at a cocktail
party.
THE COURT:  Having a hard time hearing you,
Ms. Menninger.
MS. MENNINGER:  I'm sorry.
Q.
In 2019 December, you told the government that you had been
introduced to the dean of Interlochen by Epstein at a cocktail
party.
A.
I don't recall.
Q.
If I could have you look at 3509-005, page 5, the second
full paragraph.  Does that refresh your recollection?
A.
I remember the dean of admissions for Julliard.  I don't
remember saying the first sentence.
Q.
Isn't it true you told the government that on one occasion
the dean of Interlochen was there for a cocktail party, you met
him through Epstein?
A.
I don't remember.
Q.
You don't remember if you did meet the dean of Interlochen
through Epstein?
A.
No.
Q.
And you do remember meeting the dean of admissions for
Julliard; correct?
A.
Yes.
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521
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX3                 Jane - cross
Q.
Through Epstein, right?
A.
Yes.
Q.
And you applied to Julliard; correct?
A.
No, I did not.
Q.
You were referred to the Professional Children's School by
the dean of Julliard -- or, excuse me, the dean of admissions
for Julliard; correct?
A.
I don't remember who referred.
Q.
Mr. Epstein introduced you to Donald Trump; correct?
A.
Correct.
Q.
He took you to Mar-a-Lago, right?
A.
Right.
Q.
When you were 14, you claim?
A.
Yes.
Q.
He took you in a dark green car?
A.
Yes.
Q.
And you met Donald Trump there; correct?
A.
Correct.
Q.
That was before the pool house incident; correct?
A.
I don't remember that.
(Continued on next page) 
 
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522
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
Q.
If I could direct your attention to your conversation to
the statement 3509-001?
MS. MOE:  I object to characterizing it as a
statement, your Honor.
THE COURT:  Sustained.
Q.
Page 3 of 001, in the second full paragraph, does that
refresh your recollection that you described a period in the
beginning before the pool house incident?
A.
I don't recall saying that.
Q.
Do you recall telling the government that Epstein took you
-- that Epstein told you that he had famous friends that he
would call and put on speaker phone?
A.
That's correct.
Q.
And you told them that he took you in a dark green car to.
Mar-a-Lago to meet Donald Trump, right? 
A.
Right.
Q.
And that was in the beginning before the pool house
incident?
MS. MOE:  Objection.  Asked and answered and also
misleading.
THE COURT:  Overruled.  I'll allow it.
A.
I don't remember saying that and I don't remember the
timeline of that.
Q.
Yesterday you talked about group sexualized massages,
right?
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523
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
A.
Yes.
Q.
I think you called them orgies, right?
A.
Yes.
Q.
You talked about how those would happen almost every visit
with him, which would have been every two weeks, correct?
MS. MOE:  Objection to mischaracterizing the
testimony.
THE COURT:  Overruled.  Overruled.
A.
Not correct.  No.
Q.
Your testimony yesterday --
THE COURT:  Where am I looking?
MS. MENNINGER:  Your Honor, the transcript from
yesterday's testimony began on page 314 and the specific
statement about frequency is at the top of 315.
MS. MOE:  Your Honor, may I have just a moment?
THE COURT:  Yes.  I need one too.
Can I get the page again, please. 
MS. MENNINGER:  Sure.  Your Honor, it began -- the
description of the topic was on 314, and then the specific
question about frequency occurred at the top of 315.
THE COURT:  Okay.
MS. MOE:  I'm sorry, your Honor.  What's the question?
THE COURT:  What's the question?
BY MS. MENNINGER:  
Q.
I asked, you testified yesterday that these group massages
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524
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
would happen almost every visit with him which would have been
every two weeks.  That was your testimony yesterday?
A.
Yes, I guess, I -- yes, I said that.
Q.
In these group massages, there were other participants,
correct?
A.
Correct.
Q.
You distinctly remembered the names of some of these other
women participants, correct?
A.
Correct.
Q.
You told those names to the government, correct?
A.
Correct.
Q.
You recalled a woman named Sophie who participated in these
group sexualized massages, correct?
A.
Correct.
Q.
She was an actual massage therapist, right?
A.
That's what she said, yeah.
Q.
She had blond hair?
A.
Mmm-hmm.  Yes.
Q.
Tall and thin, right?
A.
Yes.
Q.
Nice legs?
A.
Yes.
Q.
Was pretty?
A.
Yes.
Q.
Had a tan?
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Case 1:20-cr-00330-PAE     Document 745     Filed 08/10/22     Page 113 of 264

525
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
A.
Yes.
Q.
Right?
A.
Yes.
Q.
Lived in Florida?
A.
Yes.
Q.
Married a racecar driver?
A.
Yes.
Q.
She joined in the sexual massages, correct?
A.
Correct.
Q.
You said she knew the routine, right?
A.
Right.
Q.
She would make out with other girls during these
encounters?
A.
Yes.
Q.
And you remember being on flights with Sophie?
A.
Yes.
Q.
Sophie would be someone who could corroborate your
recollection about these group massages, correct?
MS. MOE:  Objection.
THE COURT:  Overruled.
A.
Yes.
Q.
You told the government about a woman named Eva who joined
in, correct?
A.
Correct.
Q.
You said she joined in with Sophie, right?
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526
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
A.
What's the exact question joined in with Sophie?
Q.
Those were your words.
A.
Yes.
Q.
You said she joined in with Sophie?
A.
Joined into the group scenario, yes.
Q.
She knew the routine?
A.
Yes.
Q.
So she could also confirm your story, right?
A.
Yes.
Q.
You talked about a third woman named Emmy, who was a
participant in the abuse, correct?
A.
Correct.
Q.
You said that Emmy was British?
A.
Yes.
Q.
And she was nice and cool, right?
A.
Yes.
Q.
And she was involved in the sexual contact, right?
A.
Yes.
Q.
And she was in these group sexualized massages with you,
correct?
A.
Yes.
Q.
There was a fourth woman you remembered named Michelle?
A.
Yes.
Q.
Michelle was short?
A.
Yes.
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Case 1:20-cr-00330-PAE     Document 745     Filed 08/10/22     Page 115 of 264

527
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
Q.
You hung out with her and Emmy?
A.
Yes.
Q.
And you sometimes went out with them, right?
A.
Yes.
Q.
And you claimed that Michelle was also involved in the
sexual contact, correct?
A.
Yes.
Q.
And the group massages?
A.
Yes.
Q.
And then another person you remembered was named Kelly,
right?
A.
Yes.
Q.
And you remembered her last name, right?  
A.
Yes.
Q.
And you thought she was a model who was older than you,
right?
A.
Yes.
Q.
And you told the government she could back up what you were
talking about, right?
A.
Yes.
Q.
You also told the agents and the prosecutors you were
meeting with, you thought you could recognize these people if
you saw pictures, right?
A.
A few of them, yes.
Q.
And you said that at your very first meeting in September
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528
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
of 2019, right?
A.
Yes.
Q.
And between September of 2019 and today, you've never been
shown pictures of Sophie, right?
MS. MOE:  Objection.
MS. MENNINGER:  Lack of evidence your Honor?
THE COURT:  What are the grounds?  One word grounds
for the objection.
MS. MOE:  Your Honor, may we approach?
THE COURT:  Okay.
(Continued on next page) 
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529
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
(At the sidebar) 
THE COURT:  What are the grounds?
MS. MOE:  Your Honor, in connection with our motions
in limine, the Court granted a motion in limine from the
government about efforts to put at issue particular
investigative techniques of whether we're showing photographs
or steps that the government is taking.  That's the objection,
your Honor.
THE COURT:  Overruled.
MS. MENNINGER:  Your Honor, can I make a record about
the number of objections because it's -- 
THE COURT:  Well, the record is clear about the number
of objections.
(Continued on next page) 
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530
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
(In open court) 
THE COURT:  Do you need the question repeated?  Repeat
the question.
Q.
Between September of 2019 and today, have you ever been
shown photographs of Sophie by the government?
A.
No.
Q.
Of Emmy?
A.
No.
Q.
Michelle?
A.
No.
Q.
Eva?
A.
No.
Q.
Kelly?
A.
No.
Q.
Any of the other model-types that you said you saw in these
group massages?
A.
No.
Q.
You remembered being on flights with a number of
individuals, correct?
A.
Correct.
Q.
You remember Prince Andrew being on a flight, right?  
A.
Yes.
Q.
You remember Mark Epstein, Jeffrey's brother, being on a
flight?
A.
Yes.
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531
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
Q.
You recall Adam Perry Lang being on a flight with you?
A.
Yes.
Q.
You remember Epstein's mom being on a flight with you?
A.
Yes.
Q.
You told the government you remembered all these people
being on flights with you?
A.
Yeah.
Q.
Were you aware of whether the flight logs reflect any
flights by you with those individuals?
A.
I have no idea, no.
Q.
You also had some recollections about flying on the private
plane with Epstein, right?  You recall being on the plane?
A.
Yes.
Q.
And you said that you were asked your weight when you were
boarding the plane, correct?
A.
Yes.
Q.
And you also remember this Latin American driver for
Mr. Epstein driving you up to the airport, correct?
A.
Correct.
Q.
So he could back up that story too, correct?
A.
Correct.
Q.
And you remember someone from Epstein's office named Lesley
who called to set up travel arrangements for you, right?
A.
Yes.
Q.
And you recall Lesley calling your home phone in Florida,
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532
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
right?
A.
That's what I remember, yeah.
Q.
When you were 14, 15 and 16, right?
A.
I don't know if it was her every time.  I just remember a
Lesley.
Q.
When you were in Florida?
A.
Yes.
Q.
Between the ages of 14 to 16.  And you remember Emmy
calling your house when you were age 14, 15 and 16 to make
arrangements, right?
A.
No, Emmy wasn't around then.
Q.
Well, you told the government that you do recall Emmy
calling your home phone in Florida, right?
A.
No, I never said that.
Q.
Let's look at 3509-001 at page 2, in the second full
paragraph.
A.
Yeah, but that's not correct.
Q.
So it says that you recall Emmy calling your house phone,
correct?
MS. MOE:  Objection.
THE COURT:  Just a moment.  Just a moment.  Sustained.
Q.
Did you tell the -- you're saying that it says it, but it's
not correct.  Can you just tell us what's not correct?
MS. MOE:  Objection, your Honor.
THE COURT:  Overruled.  You may answer.
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533
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
A.
This timeline is not correct.  I did not know Emmy or
Michelle while living in Florida.  I knew them in New York.
Q.
You did not live in a house in New York, correct?
A.
No.
Q.
You lived in an apartment, right?
A.
Yes.
Q.
So you didn't have a house phone in New York?
A.
I think we did have a house phone, actually.  Actually, we
did for sure.
Q.
There was staff present at Mr. Epstein's eight-story
mansion, right?
A.
Yes.
Q.
And the staff included a chef, right?
A.
Yes.
Q.
And a house manager?
A.
Yes.
Q.
And a driver?
A.
Yes.
Q.
And so all of those people saw you staying in this mansion
by yourself as a 14 year old, right?
A.
Yes.
Q.
You said that Epstein gave you money almost every time that
you saw him, right?
A.
Correct.
Q.
Hundreds of dollars at a time?
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534
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
A.
Yes.
Q.
$2- or $300 at a time?
A.
Yes.
Q.
And that happened regardless of whether or not you were in
what you claim was a sexually abusive relationship at that
time, right?
A.
Yes.
Q.
And your brothers never mentioned anything weird about you
having hundreds of dollars of cash, correct?
A.
I never mentioned it to them.
Q.
And your mother as well didn't know you had hundreds of
dollars?
A.
No.  I gave it to my mother.
Q.
You gave the hundreds of dollars to your mother?
A.
Yes.
Q.
Every time?
A.
I showed it to her every time.
Q.
And Epstein only gave you gifts.  He didn't give any gifts
to your brothers?
A.
He may have.  I don't recall.
Q.
Nothing major?
A.
I think he gave him a computer once.
Q.
Anything else?
A.
Not that I remember.
Q.
You don't have any photographs of yourself with Epstein,
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535
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
correct?
A.
Correct.
Q.
Or Ghislaine?
A.
Correct.
Q.
You don't have any photographs of you wearing the clothes
that you claim they bought you?
A.
No.
Q.
The plaid pants and the Ralph Lauren sweater, right?
A.
That's right.
Q.
You claimed that there was a photo of you that Epstein kept
on his desk, and you were wearing a bathing suit, right?
A.
Yes.
Q.
You don't know whether that photograph was ever found,
correct?
A.
Correct.
Q.
Do you have any records of when you went to the Lion King,
like a program?
A.
No, I don't have really anything from that time of my life.
Q.
You said that Epstein paid for your acting lessons, right?
A.
Yes.
Q.
At a particular studio?
A.
Yes.
Q.
And you said that he paid a particular voice coach for you?
A.
Yes.
Q.
Have you got records of any of those payments?
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536
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
A.
No.
Q.
You've met with the government quite a few times in person,
correct?
A.
Correct.
Q.
You've had a number of trial preparation sessions?
A.
Not -- not -- what's a number?
Q.
What's that?
A.
What do you mean by preparations?
Q.
Trial prep sessions?
A.
Yes.
Q.
Where they were talking about your testifying here?
A.
Yes.
Q.
And there was a mock cross-exam that you engaged in with
the government, right?
A.
Yes.
Q.
Where you practiced answering questions like we are now?
A.
Not practicing, no.
Q.
Did you rehearse your direct testimony?
A.
No, I did not.
Q.
You continued to travel on Mr. Epstein's dime after you
escaped in 1999, correct?
A.
That is not true.
Q.
Well, you took flights on his private jet after 1999,
right?
A.
Only one.
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537
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
Q.
Do you remember taking commercial flights that he paid for?
A.
No.
Q.
I will have you look at Exhibit J-37 and see if this
refreshes your recollection.  And the J numbers are behind the
green flag.
MS. MENNINGER:  Your Honor, I think it's going to make
more sense for me to come back to this.
THE COURT:  Okay.
Q.
You do recall sending a photograph of yourself to Epstein
after you moved to LA, right?
A.
Yes.
Q.
That was Government Exhibit 245, right?  
Where you wrote "Thanks for rocking my world"? 
A.
Yes.  Embarrassing.
Q.
And you wrote that when you were 19?
A.
19, yes.
Q.
You testified yesterday that your mom made you send that to
him, right?
A.
Yes.
Q.
So your mom could clearly corroborate that, right?
A.
Yes.
Q.
And there were no dates on those photographs, right?
A.
Correct.
Q.
So it's your recollection about the age you were in those
photographs, right?
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538
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
A.
Right.
Q.
There's nothing on the photographs themselves?
A.
Right.
Q.
And you testified yesterday that Epstein just kept calling
you and calling you in the 2000s until you stopped answering
his phone calls, right?
A.
Yes.
Q.
So there would be phone records of all those calls, right?
A.
Yes.
Q.
It took you quite some time to report this to law
enforcement, right?  We talked about that at the beginning
yesterday?
A.
Yes.
Q.
In the meantime, you got a job on a soap opera, right?
A.
Right.
Q.
You received an income from that job?
A.
Yes.
Q.
You had an agent?
A.
Yes.
Q.
You had a number of family members that lived nearby in the
2000s, right?
A.
Yes.
Q.
And once you had established yourself as an actress with
income, you didn't call up the police to let them know what you
claimed had happened to you, right?
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539
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
A.
Right.
Q.
In the late 2000s, 2007, 2008, you saw on the news that
Epstein had been arrested, right?
A.
Right.
Q.
And charged, right?
A.
Yeah.
Q.
And so you knew the authorities were investigating
Mr. Epstein in 2007, 2008, right?
A.
Right.
Q.
You didn't pick up the phone then and call the people that
you knew were investigating him then, correct?
A.
Correct.
Q.
You knew how do that, right?
A.
Right.
Q.
You knew how to get a lawyer?
A.
Right.
Q.
You chose not do that?
A.
Yes.
Q.
And you started to see some press that mentioned yourself?
A.
Yes.
Q.
And so you did hire a lawyer, right?
A.
Yes.
Q.
And a lot of the press that you saw mentioned about
yourself was false, correct?
A.
I don't remember what the exact press was.
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540
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
Q.
Were there allegations that you were a Yugoslavian sex
slave that you saw on the internet?
MS. MOE:  Objection to relevance, your Honor.
MS. MENNINGER:  I'm asking if she saw the press?
THE COURT:  I'll allow it.
A.
I don't remember reading that.
Q.
You wanted to stop the press about you, right?
A.
Yes.
Q.
So you hired an attorney?
A.
Yes.
Q.
And that was around 2015?
A.
Yes, I think so.
Q.
You hired a litigator, a tough litigator, right?
A.
Yes.
Q.
You paid her a lot of money?
A.
Yes.
Q.
Quarter of a million dollars?
A.
No.
Q.
Do you recall speaking with the government in December of
2019?
A.
Yes.
Q.
I'm sorry, got that date wrong.  September 2 of 2021, so a
few months ago?
A.
Yes.
Q.
At that time, you said you gave this litigator a quarter of
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541
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
a million dollars?
A.
No, that is incorrect.
Q.
Why?
A.
First of all, I don't have that much money to give away,
and it was $25,000.  So maybe it's a typo?
Q.
I'm going to have you look at 3509-023.
A.
Yeah, I see it.
Q.
In the last full paragraph in the middle of the paragraph.
A.
Yes.
Q.
Does that refresh your recollection that you told the
government you did not know you would need a $250,000 retainer?
A.
That's not correct because I never said that.  I would not
be able to afford to pay anybody that much money for anything.
Q.
Well, you paid her some amount of money?
A.
Yes.
Q.
$25,000?
A.
$25,000.
Q.
And you did that to help her stop the media about you?
A.
Stop people from harassing me and bullying me into trying
to give some sort of interview or statement.
Q.
Well, you were being approached by lawyers?
A.
Yes.
Q.
Lawyers for Virginia Roberts, for example?
A.
Yes.
Q.
You spoke to them?
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542
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
A.
Yes.
Q.
You were being approached by the media, right?
A.
Yes.
Q.
The media was wanting you to give statements, right?
A.
Right.
Q.
And you could have directed your lawyer to call the
government and report this crime you're claiming now, right?
A.
I don't know.
Q.
You didn't hire her for that purpose, right?
A.
No.
Q.
You could have, right?
A.
I guess I could have, yeah.
Q.
In 2019, before Epstein was arrested, you were contacted by
Agent Amanda Young, right?
A.
Right.
Q.
She gave you a call?
A.
Yes.
Q.
She asked to speak with you, right?
A.
Yes.
Q.
And you said you were just not interested in getting
involved, right?
A.
That's right.
Q.
And then thereafter, you hired a different attorney, right?
A.
Yes.
Q.
You hired Mr. Glassman?
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543
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
A.
Yes.
Q.
Mr. Glassman is a personal injury lawyer, right?
A.
Yes.
Q.
Mr. Glassman, touts the very large verdicts that he has
received on his web page, correct?
MS. MOE:  Objection.
THE COURT:  Grounds.
MS. MOE:  Hearsay.
THE COURT:  Sustained.
Q.
Are you aware of Mr. Glassman's advertising?
A.
No. 
Q.
Did you ever look at his website?
A.
No.  He's a friend of a friend.
Q.
You hired him on September 3 of 2019, correct?
A.
I don't know the exact date, but --
Q.
Okay.  Let's take a look at J-14.  Do you recognize that
document?
A.
Yes.
Q.
And what is that document?
A.
Attorney-client contingent fee contract.
Q.
That's between you and Mr. Glassman, right?
A.
Yes.
Q.
If you could look at the last page, does that refresh your
recollection about when you hired Mr. Glassman?
A.
Yes.
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544
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
Q.
When did you hire Mr. Glassman?
A.
September 3, 2019.
Q.
That was two weeks before you met with the government for
the first time, right?
A.
I don't know those dates.
Q.
I want to look back at 3509-001, at the date.  Does looking
at the left-hand corner of 001 refresh your recollection about
the date that you first met with the government?
A.
It doesn't, but if that's what it says, then --
Q.
September 19, 2019 seems about right, correct?
A.
Correct.
Q.
You hired Mr. Glassman before this meeting with the
government, right?
A.
Right.
Q.
Mr. Glassman was at the first meeting with the government,
right?
A.
Yes.
Q.
As well as Mr. Werksman, the second lawyer, right?
A.
Right.
Q.
And those were both personal injury lawyers that you had
selected?
A.
Yes.
Q.
You didn't hire a lawyer that specializes in victims'
rights, correct?
A.
I hired a lawyer based on advice from my husband's friend,
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
their friends.
Q.
He's not a specialist in criminal law, for example?
A.
I guess not.
Q.
And you had Mr. Glassman and Mr. Werksman in the first
meeting with the government, right?
A.
Right.
MS. MENNINGER:  May I have one moment, your Honor?
THE COURT:  You may.
(Pause) 
MS. MENNINGER:  Your Honor, would this be a good
stopping point?
THE COURT:  We were having a little issue with the
jurors' lunch, so not quite yet.
MS. MENNINGER:  Okay.  I'm just trying to find
something I can do on a short notice -- a short section.
THE COURT:  You can just start another section and
we'll break, that's fine.
MS. MENNINGER:  I appreciate that.
BY MS. MENNINGER:  
Q.
In the period of time between '99 and 2019, there has been
a lot of things that have happened, right?
A.
Right.
Q.
You have read the press, including stories about yourself,
correct?
A.
Correct.
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546
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
Q.
You've read the press about Epstein?
A.
Correct.
Q.
You've talked about the press about Epstein with other
people?
A.
What's that question?
Q.
You've talked about the press about Epstein with other
people?
MS. MOE:  Objection to form.
Q.
Well, you had discussions --
MS. MENNINGER:  I'll rephrase, your Honor.  Maybe that
will help.
Q.
You've spoken with your ex-boyfriend you were calling Matt
about Epstein, right?
A.
Yes.
Q.
And you and he watched news reports together, correct?
A.
Yes.
Q.
And you pieced some things together, correct?
A.
I pieced things?  What's the question?  Sorry.
Q.
You and Matt pieced things together based on your review of
press about Epstein, correct?
MS. MOE:  Objection to form.
THE COURT:  Overruled.
A.
I don't understand what pieced together means.
Q.
You talked to Virginia Roberts' lawyer, Brad Edwards,
right?
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547
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
A.
Yes.
Q.
You talked to Stan Pottinger?
A.
Yes.
Q.
You know they represent other Epstein accusers, right?
A.
Yes.
Q.
Your lawyer has spoken to other lawyers?
MS. MOE:  Objection.
THE COURT:  I suppose you can ask if she knows that.
Q.
Do you know whether your lawyer has spoken to other lawyers
who represent Epstein accusers?
A.
I wouldn't know that.
Q.
You've talked to your family members, right?
A.
Some of them.
Q.
You've talked to your ex-boyfriend, Matt, right?
A.
Yes.
Q.
And during that period of time, all of the pieces of
information and conversations that you've had are part of what
you now know about the Epstein case, correct?
MS. MOE:  Objection.
THE COURT:  Just a moment.
One word.  Grounds. 
MS. MOE:  Form.  Vague and confusing.
THE COURT:  Overruled.  You can state the question
again. 
Q.
All of the conversations that you've had and the press that
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
you've read and the people that you've talked to, all of those
pieces of information go into what you know about the Epstein
case as you sit here today, correct?
A.
I wouldn't say it like that, no.
Q.
You don't remember all of the things that you've talked
about, right?
A.
No, I don't remember all the things I talked about.
Q.
You don't remember all the things that you read, correct?
A.
No.
Q.
You don't know all of the websites that you've seen, right?
A.
No, I try to avoid those.
Q.
But you've read them enough to hire a lawyer to stop some,
right?
A.
No, that's based more on people calling me, harassing me,
calling my husband, harassing him, calling my work, calling my
friends.  And I wanted these people to stop calling me and go
away.  It's not based on tabloids.  I've been in enough online
tabloids.  Being an actor, you read all kinds of stuff about
yourself.
Q.
You're aware of the media out there about yourself, right?
A.
Some of it, yeah.
Q.
During your teenage years, you traveled quite frequently,
correct?
A.
I guess it's all relative, but yeah, I guess.
Q.
You traveled back and forth to a country in northern
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549
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
Europe?
A.
Yes.
Q.
You did that over the holidays?
A.
Yes.
Q.
With your family?
A.
Yes.
Q.
You were 15 when you went on one of those trips?
A.
I don't remember, but --
Q.
I will have you take a look at J-6.  I assume you have not
seen this document before?
A.
No.
Q.
Do you recognize your name on it?
A.
Yes.
Q.
And do you see certain dates and --
MS. MOE:  I'm sorry, your Honor, I don't believe I
have J-6.
MS. MENNINGER:  I thought you did.  I'm really sorry.
MS. MOE:  I'm sorry, I do.  Apologies.
Q.
You recognize your name and date of birth on this document?
A.
Yes.
Q.
And does -- I realize that some of these dates are old, but
does looking at this, particularly page 2 towards the bottom,
refresh your recollection about trips that you may have taken
outside of the country?
A.
Do I remember these flights?  Is that the question?
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550
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
Q.
Yes, do you remember taking these trips?
A.
I don't remember these in particular.  These are old.  I
don't know.
Q.
Let me direct your attention to the second from the bottom
one.
A.
Okay.
Q.
Do you recognize those airport codes or the dates of travel
indicated there?
A.
I don't know what those airport codes are.  If somebody
could translate them for me.
Q.
Let me ask you this:  In April of 1996, did you take a trip
abroad?
A.
I don't remember.
Q.
How old were you in April of 1996?
A.
15.
Q.
And do you remember going abroad when you were 15?
A.
I don't remember.
Q.
Did you ever attend a vocal competition in Italy?
A.
Oh, yes.
Q.
And that was in April of 1996?
A.
I guess it was.
Q.
Was it?  I'm asking you.
A.
I don't remember.  I was 15.
Q.
Okay.  And then there was another trip that you took, maybe
you'll recall, in June of 1997.  How old were you in June of
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551
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
1997?
A.
16.
Q.
Do you remember a trip that you took in June of 1997?
A.
I think I may remember what trip this was for, something
having to do with a sibling.
Q.
None of these trips involved Ghislaine Maxwell, right?
A.
No.
Q.
You didn't travel abroad with her?
A.
No.
Q.
And Epstein as well, you didn't travel abroad with him?
A.
No.
Q.
So, you may have taken a trip related to a sibling in June
of 1997 --
A.
Yes.
Q.
-- when you were 16?
A.
Yes.
Q.
And then in January of 1998, how old were you?
A.
167.
Q.
And you took a trip perhaps abroad then.  Do you recall
that?
A.
January 199 -- maybe a family thing?  I don't remember.
I'm sorry.
Q.
And then the last one I'll ask about is April of 1998.  Do
you remember taking a trip then?
A.
No, I don't remember what the trip was.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax4                 Jane - Cross
Q.
And how old were you in April of 1998?
A.
17.
Q.
You continued to travel throughout the 2000s abroad.  Is
that right?
A.
That's right.
Q.
When you were in your -- in the mid-1990s, you participated
in a beauty pageant, correct?
A.
Embarrassingly enough, so, yes.
Q.
A Miss Teen pageant?
A.
Yes.
Q.
The big one, right?
A.
Mmm, fairly big.
Q.
And it was associated with Mr. Trump, right?
A.
Yes.
Q.
And that was in a state that you were in in that time
frame, right?
A.
Yes.
Q.
You were given $2,000 by Epstein for a dress?
A.
I don't recall that.
Q.
Do you recall being devastated that Epstein only gave you
$2,000 for a dress?
A.
No, I don't recall that.
Q.
Or crying because he only gave you $2,000 for a dress?
A.
No, that's ridiculous.  I wouldn't do that.
Q.
You performed on a reality show, correct?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax4                 Jane - Cross
A.
Yes.
Q.
In the 2000s?
A.
Yes.
Q.
With your ex-boyfriend, Matt?
A.
Yes.
Q.
And you had cameras in your home, right?
A.
Yes.
Q.
You had some conflict with your mother during that?
A.
Yes.
Q.
And you had other friends who were also on the show?
A.
Yes.
Q.
And the cameras followed you around, right?
A.
Yes.
Q.
In that show, you talked about roughing it for you would be
going to the Four Seasons, something like that?
A.
Well, reality shows aren't really reality, so most of it is
produced by producers.
Q.
And you were paid for that reality show, right?
A.
Yes.
Q.
In the last few decades, you have supported your family,
right?
A.
Not all of them, but a few of them, yes.
Q.
You have had some of your brothers that have had to live
with you?
A.
Yes.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax4                 Jane - Cross
Q.
Your sister?
A.
No.
Q.
Has never needed financial support from you?
A.
No.
Q.
You had your mother living with you, right?
A.
Yes.
Q.
And she had some financial difficulties, right?
A.
Yes.
Q.
And you needed to help her with her finances, right?
A.
Yes.
Q.
I think at one point you claim that you were putting a roof
over your family's head, right?
A.
I don't know if I used that -- those words, but they lived
in my house, yes.
Q.
You told that to Matt?
A.
Oh, well...
Q.
Right?
A.
I don't recall if those are the words I told him, but yes,
they were living in my house.
Q.
And once you hired Mr. Glassman in September of 2019, he
talked to you about your decision to cooperate in the criminal
case, correct?
MS. MOE:  Objection.
THE COURT:  Sustained.
MS. MENNINGER:  Your Honor, he shared this with the
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax4                 Jane - Cross
government.  May we have a sidebar?
THE COURT:  No.  If you want to try to get around
privilege, you'll raise it in advance, as I've made clear.
Sustained. 
BY MS. MENNINGER:  
Q.
When you decided finally to file a civil lawsuit, that was
in January of 2020, right?
A.
I don't recall the exact date.
Q.
And you filed that under a pseudonym?
A.
Yes.
Q.
Jane, right?
A.
Yes.
Q.
And you did that with the help of Mr. Glassman?
A.
Yes.
Q.
And you sued Ghislaine, right?
A.
Yes.
Q.
You sued Epstein's estate, correct?
A.
Yes.
Q.
You also made a claim in the Virgin Islands against
Epstein's estate, correct?
A.
I don't know.
Q.
At some point you made a demand for Ghislaine to pay you
money, correct?
A.
I don't know what a demand means.
Q.
Well, your lawyer sent a letter demanding that she pay you
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax4                 Jane - Cross
money?
MS. MOE:  Objection to foundation.
THE COURT:  Sustained.
Q.
Do you know whether your lawyer sent Ghislaine a letter
demanding money?
A.
I don't know that.
Q.
You knew at the time you had that civil complaint going,
that Ghislaine was charged in this case, correct?
A.
Correct.
Q.
You also participated in the Epstein Victims' Compensation
Program, right?
A.
Yes.
Q.
And with your lawyer's assistance, you filled out the claim
form for that, right?
MS. MOE:  Objection.
THE COURT:  Sustained.
Q.
Did you fill out the claim form?
A.
Did I personally?  No.
Q.
Did you sign the claim form?
A.
Yes.
Q.
Did you notarize your signature for the claim form?
A.
I don't remember.
Q.
Did you attest that everything in the claim form that you
submitted was true and accurate?
A.
Yes.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax4                 Jane - Cross
Q.
In that claim form that you attested was accurate, you were
asked whether or not you were participating in the prosecution
of any case related to Epstein, right?
A.
I don't remember what's in the form.
Q.
If I could have you look at Exhibit J-18 on page 6.  And if
you need to look at the last page to see your signature, just
let us know.
A.
Okay.
Q.
Do you see question 11?
A.
Yes.
Q.
And it asks you:  Have you filed litigation against Epstein
or the Estate of Epstein, right?
A.
Yes.
Q.
Or any related entities or individuals, right?
A.
Right.
Q.
You said yes?
A.
Yes.
Q.
And you listed your civil case, correct?
A.
Correct.
Q.
But you also said "refer to the attachment"?
A.
Well, I didn't write this, but --
Q.
You signed it?
A.
I signed it, yeah.
Q.
And then the next question, question 12, you were asked
whether or not you'd ever been trafficked to and sexually
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax4                 Jane - Cross
abused by any individuals other than Epstein, correct?
MS. MOE:  Your Honor, we're now reading a document
that is not in evidence.
THE COURT:  Sustained.
Q.
Do you recall answering or telling the claims program that
you were making a claim against Ms. Maxwell?
A.
Yes.
Q.
And you were ultimately made an offer by the claims
program, right?
A.
Yes.
Q.
And you were told what that offer was?
A.
Yes.
Q.
What was that initial offer?
A.
$5 million.
Q.
Do you know whether your attorney went back and asked for
more money?
A.
I don't know that.
Q.
This year you were wired the money, right, $5 million?
A.
Well, not the entirety, no.
Q.
I would like to ask you to take a look at Exhibit J-40.  Do
you recognize this document?
A.
Yes.
Q.
And do you recognize the date of the document?
A.
Yes.
Q.
Do you recognize your name on the document?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax4                 Jane - Cross
A.
Yes.
Q.
And on the last page, do you recognize your signature?
A.
Yes.
MS. MENNINGER:  Your Honor, at this time I would move
for the admission of this under seal because it has identifying
information as Exhibit J-40.
MS. MOE:  Your Honor, may we take up this issue during
the lunch break?  We object.
THE COURT:  Okay.  We'll break for lunch, members of
the jury.  We almost have all your lunches in hand.  I'm hoping
by the time you get back, everything will be set.  So we'll
break about 45 minutes for lunch.  Enjoy your lunch.  Thank
you.
(Jurors not present) 
THE COURT:  Everyone may be seated.  Can I have J-40
back up so we can discuss?
Grounds. 
MS. MOE:  Thank you, your Honor.  
We have a 401 and 403 objection to this document.  
This is a multipage document containing legal terms relating to 
a civil settlement.   
To the extent the defense intends to impeach this 
witness about the fact that she settled a claim and received a 
sum of money, that's already in the record.   
This document contains additional and, frankly, 
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
complicated legal terms about a settlement agreement between 
this witness and an estate that's not a party to this case.  We 
think this document is confusing to the jury and don't 
understand any potential impeachment relevance of the 
particular terms of the settlement. 
MS. MENNINGER:  Your Honor, it's a representative --
it's a documentary representative of the amount of money that
she received in the settlement.  I don't know what's confusing
about that.  I am not going to spend a lot of time arguing some
legal clauses or anything like that, but I think our jury is
sophisticated enough to know what a settlement agreement looks
like and the amount of money that she received.  She's
contesting that that's the amount of money she received, but I
don't think that precluding us from putting in a document
because it has legal language in it is an appropriate --
THE COURT:  That's the 403 argument, that it's legal
language?
MS. MOE:  Yes, your Honor.
THE COURT:  The government puts in cooperation
agreements all the time.  Those are not the models of clarity.
MS. MOE:  Of course, your Honor, and that's certainly
true --
THE COURT:  This is comparable legal language, isn't
it?
MS. MOE:  No, your Honor.  I think the difference
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax4                 Jane - Cross
here, and it's an important one is, as a proponent of the
evidence, the defense has the burden of establishing its
relevance.  At this point what they've articulated is that they
want the exact figure that was disbursed, which this witness
has already testified to and --
THE COURT:  It's just a document of that agreement.
I'm going to overrule this objection.
Anything else?   
MS. MOE:  Your Honor, in our view, this sort of opens
the door to a lot of legal issues related to the settlement
funds that are not proper before the jury.  It's cumulative of
the testimony about this particular figure and would be
confusing about its particular terms.
THE COURT:  Yes, that's what I just overruled.
MS. MOE:  Understood, your Honor.
THE COURT:  Anything else to take up?  We'll break for
lunch for 45 minutes.  Thank you.
And, Ms. Menninger, if you have an argument that 
you're going to pierce attorney-client privilege -- 
MS. MENNINGER:  Yes, your Honor.  Can we take that up
right after lunch in a sidebar?  I believe I have grounds.
THE COURT:  You have to speak into the microphone.  It
should have been briefed.  I think that would be clear, but,
yes, I'll meet with you in 40 minutes.  You'll confer in
advance.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax4                 Jane - Cross
MS. MENNINGER:  Yes.
THE COURT:  As to what the contention is, what the
proffer is, and then I'll hear from you.  40 minutes.
(Luncheon recess) 
(Continued on next page) 
 
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
A F T E R N O O N   S E S S I O N 
1:50 P.M. 
THE COURT:  All right.  Matters to take up?
MS. MENNINGER:  Yes, your Honor.
May I approach? 
THE COURT:  Microphone.
MS. MENNINGER:  I have one exhibit that relates to the
testimony I'd like to --
THE COURT:  Okay.
MS. MENNINGER:  Your Honor --
THE COURT:  Would you come to the --
MS. MENNINGER:  Oh, yes.
THE COURT:  Take your mask off, if you'd like.
MS. MENNINGER:  As with some of the evidence, your
Honor, I understand that, when questioned, the witness might
deny knowledge about this communication to the government by
her attorney, but I would like to ask her if she has knowledge
of this communication.
THE COURT:  What exact question would you ask?
MS. MENNINGER:  Your Honor, I would ask her did she
have a communication from her attorney about why she should
cooperate and testify at this criminal trial.
THE COURT:  Did she have a communication from her
attorney about why she should cooperate and testify at this
trial.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
MS. MENNINGER:  I mean, I could start with the
question of does she know whether her attorney shared that with
someone else, which is the waiver question, in my mind, anyway.
But the ultimate question I would like to get to is her
attorney told her that.
THE COURT:  Right.  So you want to get to a
communication between attorney and client.  It's privileged,
right?  And you're arguing that it's been waived or what are
you arguing?
MS. MENNINGER:  Yes, I'm arguing that it's been waived
because it was communicated to the government.
THE COURT:  Ms. Moe.
MS. MOE:  Thank you, your Honor.
I think that question is a few moves down the
chessboard.
THE COURT:  Could you pull up the microphone, please.
MS. MOE:  Yes, your Honor.
I think there would be no issue with a question about 
this witness's understanding of whether the outcome of this 
case would help in a civil case or whether at the time she 
decided to cooperate with the government and be interviewed she 
thought that would help her get money in a civil case.  That 
would be just a question about whether she had bias and motive; 
that wouldn't go to issues of attorney-client privilege about 
her general understanding.  I think the question becomes, if 
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
she says no, if a privileged communication with her attorney 
would be a proper basis for impeachment.   
On that score, if we get to that scenario, this 
witness's counsel is in the courtroom.  I've conferred with him 
about the privilege issue.  My understanding is his view is 
this is privileged and he'd like to confer with his client 
about that.  But I think he'd like to be heard on the question 
of privilege and waiver.  It's not the government's privilege 
to hold or waive or speak to; and so we'd ask for him to be 
heard on that question. 
THE COURT:  Well, I guess it still depends what we're
talking about.  What is the "this" in that sentence?
MS. MOE:  It sounds like, your Honor, if defense
counsel plans to impeach this witness about bias by offering a
statement of her attorney to the government, that that
implicates a privilege question.  If separately defense counsel
plans to ask this witness just generally --
THE COURT:  The statement from the attorney to the
government is not privileged.  This is not privileged.  The
question goes to her communication with her attorney, that's
where the privilege is.
MS. MOE:  Exactly, your Honor.
THE COURT:  I'm not yet seeing the connection between
what I -- I don't know what the basis of admissibility would be
with respect to this email that's been handed up, which is a
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
nonprivileged communication, right, between the attorney and
the witness's attorney and the government.
MS. MOE:  Yes, your Honor.  That is my note to file
about a conversation with Mr. Glassman.  In our view, my notes
about a conversation with someone who's not this witness can't
be an exhibit at the trial.  There are separate questions about
her conversations with her attorneys that implicates other
privilege issues.
THE COURT:  You don't have any objection to
Ms. Menninger asking the witness if she has any awareness of
her participation in this criminal proceeding impacting -- what
is the underlying question?  Let me just get the underlying
question before we get -- Ms. Menninger.
MS. MENNINGER:  Your Honor, the underlying question is
she expected to get a higher payout in her civil case if she
testified in and cooperated in this criminal case.  That's the
ultimate underlying issue.
THE COURT:  Did she have any basis to believe that by
testifying in this criminal case, it would aid the payment she
would get in the -- with respect to the fund or the civil case?
MS. MENNINGER:  Well, they ultimately became as one.
But at the time her initial advice from Mr. Glassman came in,
there was not a victims' compensation fund.  That arose during
the course of her civil case.  And so --
THE COURT:  And the line you're interested in is that
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
he mentioned he told her it would help her case?
MS. MENNINGER:  Yes, your Honor.  Because prior to
that line, he's disclosing that he discussed whether
cooperating with the case and then ultimately gets to the
question of testifying in the case, he says, were the morally
right thing to do.  And they had discussed how testifying at
trial was the right thing to do.  He also mentioned that he had
told her it would help her case.  It is slightly ambiguous.  I
don't know if it refers back to the entirety of the things said
before it, but that's what the email or the note says.
THE COURT:  Okay.  So you want to ask her if she had
any basis to conclude that her participation as a witness here
would help her civil litigation recovery prospects.
MS. MENNINGER:  Right, your Honor.  If it were a
cooperation agreement and a witness had cooperated and someone
had promised that they would get a lesser sentence if they
cooperated, I can see that also being admissible.  So maybe
just the --
THE COURT:  The attorney's advice to the client about
whether they should take a plea and what assistance that might
get them and all of that obviously is privileged.
MS. MENNINGER:  It is, until you disclose it to the
government.  I totally agree with that, your Honor.
THE COURT:  Okay.  So then the question is if she
answers yes to that question, I had some reason to believe that
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
it would -- it might have some impact -- my participating would
have some impact on the civil litigation, do you have
additional questions?
MS. MENNINGER:  May I confer, your Honor?
THE COURT:  Yes.
(Counsel conferred) 
MS. MENNINGER:  Your Honor, I suppose that there might
be additional question -- you know that your lawyer told the
government that.
THE COURT:  So however she answers that, I suppose you
want to ask, Do you know that your lawyer told the government
that?
MS. MENNINGER:  Yes.
THE COURT:  Do you have an objection to the "Do you
know that your lawyer told the government that"?
MS. MOE:  I'm sorry, your Honor.  I'm trying to follow
the logic of trying to impeach a witness by her knowledge of an
attorney's statement to the government about a client's
intention.  I don't think that tracks the logic of impeachment
by bias or by a prior inconsistent statement.  I'm not sure how
that establishes impeachment under the rule.
THE COURT:  The fact that she knows her lawyer told
the government that.
MS. MOE:  Your Honor, that appears to be an end-run
around getting in her conversations with her attorney.  Because
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569
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
the question is, Are you aware that your attorney made a
statement to the government about his conversation with you
about your expected outcome in the case.
THE COURT:  Well, okay.  At the first step, you agree
they can ask if she had any basis to believe that her
participation as a witness here would have any impact on her
potential compensation in civil litigation.  You don't object
to that question?
MS. MOE:  No, your Honor, no objection.
THE COURT:  So then we have what if she says yes and
what if she says no.  So if she says yes, their follow-up
question is, Are you aware that your attorney told the
government that?  
I think I agree with you.  I don't know what the 
relevance of that is.  And it is an attorney-client 
communication.   
What's the relevance of whether she knows her attorney 
told the government that? 
MS. MENNINGER:  Your Honor, I think it gets into her
expectations that she -- that the government knows that she
knows.  And so at that point she's testifying with an
expectation that -- you know, if the government doesn't -- is
unaware of her attorney's advice, then it's just a secret
between her and her attorney.  But if the government who is
calling her to testify is aware of her plan, intent to get more
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
money by testifying in the criminal case, that can affect, you
know, whether or not it's an appropriate -- you know, whether
the witness has an expectation that is somewhat colored by the
government's plan or putting them on the stand, you know,
knowing that.  It's an issue of whether the witness is coming
and testifying knowing that the person who's calling them to
the stand is aware of this whole plan to get more money from
the civil case by testifying here.
THE COURT:  What does that tell us at all about her
motivation?  The two pieces aren't linking up.  There's does
she have in her mind that testifying might help her in the
civil case.  The answer to that is yes.  I don't see -- it
seems to me it's potentially -- it's attorney-client privilege
issues because it's about what her attorney communicated to
her.  And it's hard to see any additional relevance that comes
from whether the fact -- whether the government knew -- whether
she knew that the government knew that she believed that -- or
testifying would help her civil case, because it doesn't link
up to the benefit part.
So I think the first question would be fine.  If the 
answer is yes, my inclination is not to allow the second 
question on both privilege, 401/403 grounds.  So then the 
question is if the answer is no, then what do you propose? 
MS. MENNINGER:  Your Honor, as with some of the other
issues in this case, if she says no, I think that there is
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
evidence that could be put on extrinsically, specifically, her
attorney's testimony.
THE COURT:  So you want to then call her attorney and
ask her attorney if he told her, advised her that if she
participated in this case, she would -- it would help her in
the civil case.
MS. MENNINGER:  Right.  Because that is the only
portion that was waived.  That's what he -- whatever he
communicated to the government is what was waived.  I don't
think he's waived -- I'm not arguing for subject matter waiver,
for example.
THE COURT:  So, first of all, as I've said before, you
have to brief that.  This is not enough.  I haven't looked at
any law on that question.  You've put none before me.  I made
very clear you'd have to brief it.  So we're not doing that
today.
MS. MENNINGER:  No, I understand, your Honor.
THE COURT:  Ms. Moe, what's your response to the
waiver question?
MS. MOE:  Your Honor, having not had an opportunity to
research it or consider it or confer with Mr. Glassman, who --
it's not my privilege to hold, so I can't speak to its waiver
without researching the issue and conferring with Mr. Glassman.
THE COURT:  The government not infrequently objects to
privilege grounds to questions during trial.  So the government
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
certainly has a position, I'm sure.
MS. MOE:  Yes, your Honor.  
I would just want to make sure I was conferring with 
her counsel about that issue and being mindful.   
Broadly speaking, your Honor, to the extent this 
evidence is offered for the purpose of impeaching the 
credibility of the prosecutors in this case, which is what I 
think what Ms. Menninger was suggesting, I think that would be 
entirely improper. 
THE COURT:  I think that's, in part, like the
mysterious implication of the second question that I said I
wouldn't allow.
MS. MOE:  Yes, your Honor.
THE COURT:  Because it just doesn't match up to
anything in motivating her.
So we know where the branch of the tree ends.  If the
question is yes, that's the end of it.  If the question is no,
then it sounds like we're done with this witness with that
question.  And then you're going to brief calling her lawyer
only on the question of whether he told the government that her
participating -- testifying would help her civil case.
MS. MENNINGER:  He told her that.  No, he told Jane
that.
THE COURT:  Right.
MS. MENNINGER:  Yes.  And, your Honor, that would be
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
something to -- I mean would be --
THE COURT:  It would be waiver argument.  You're going
to brief waiver as to that on the basis that he told that to
the government.
MS. MENNINGER:  Exactly.  The waiver was the telling
to the government.  The question for him on the stand would be
what he told his client.  But the briefing would be on the
waiver question.
THE COURT:  Well, right.  But whether he waived --
whether the privilege -- it's the client's to waive, I think.
That will be part of the briefing, I suppose.
Okay.  But if the answer is no, you don't have 
anything further for this witness? 
MS. MENNINGER:  I understand, your Honor.
THE COURT:  That was a question.
MS. MENNINGER:  Yes, that's right.  I understood your
Honor to say there is no other question, so I --
THE COURT:  Well, no, it was a question.  If she says
no, do you have other questions for her?
MS. MENNINGER:  On this topic, no.
On other topics, yes. 
THE COURT:  Yes, of course.
MS. MENNINGER:  Okay.
THE COURT:  I think Ms. Moe had something.
MS. MOE:  Yes, your Honor.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
Just to facilitate clarity with respect to the
threshold question here about the witness, about her
understanding if the question is phrased as her understanding
about testifying at trial today and the effect of a civil case,
I think the answer to that question has to be no because there
is no civil case, there is no pending claim, it's all been
resolved.
And so I just wanted to clarify whether the question 
is at the time she started meeting with the government was that 
her understanding, while the case was active, or whether the 
question will be about her testimony here at trial.   
Jane has testified on direct that her understanding is 
she has no financial stake in the outcome of this case.  The 
civil matter is resolved and the verdict in this case won't 
affect what she's received from those settlements.  And so I 
just wanted to clarify in terms of how that question is phrased 
and what we're getting at about the issue about testifying at 
trial or her initial decision to cooperate with the government. 
THE COURT:  Fair enough.
MS. MENNINGER:  That's fair.
In the paragraph itself it refers to cooperating with 
the case and it refers to testifying.  So I think any reason to 
believe either one of those -- 
THE COURT:  Can you just give us the specific
question.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
MS. MENNINGER:  Do you have any basis to believe --
any reason to believe that your cooperation would help with
this case, would help you with your civil case, that's one
question.
The other is do you have any reason -- 
THE COURT:  I'm sorry.  I don't think that
clarifies -- I think it's unclarifying on two points that
Ms. Moe has raised.
MS. MENNINGER:  Okay.
THE COURT:  One, cooperating in this case, meaning by
testifying or more broadly.  And two, since she no longer has a
pending civil case, I think she'd probably be left wondering
what you're referring to.
Can you clarify the question -- I think what you're 
asking is at any point during your -- at any point in your 
cooperation with the government -- "cooperation" is loaded 
because it's not like there's a cooperation agreement or 
something.  But for lack of a better term, cooperating with the 
government with respect to this criminal case, did you ever 
have an understanding that it might benefit you in what was 
then a pending civil litigation?   
Ms. Moe, is that getting at what you're suggesting? 
MS. MOE:  Yes, your Honor.  I just wanted to make sure
it was clear for the witness.
THE COURT:  Okay.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
MS. MOE:  Thank you.
THE COURT:  Ms. Menninger, is that getting at what you
are suggesting?
MS. MENNINGER:  It is.  I believe that he also
communicated that testifying would benefit her in the criminal
case.
THE COURT:  Okay.
MS. MENNINGER:  And so I'm not privy to whether, you
know, at what point in time --
THE COURT:  How about did you ever have an
understanding that any cooperation with the government,
including testifying in this trial, would aid you in any way in
your efforts to recover in the then-pending civil litigation?
Does that get at it, Ms. Menninger?  I'm not disputing that you
should ask the question.  I agree with Ms. Moe there's points
for confusion, so let's just --
MS. MENNINGER:  I think it does, your Honor.
I would have to kind of -- I would like to just write 
out the question so I understand.  But I do think, as I 
mentioned a little bit earlier, because the civil litigation 
morphed into the victims' comp fund, there may be a similar 
question with respect to the comp fund.  But I think I can 
draft this language and we could -- I can tell your Honor what 
it is in just a minute. 
THE COURT:  Okay.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
(Pause) 
THE COURT:  What else do we need to take up?
MS. MOE:  Your Honor, I'm not quite sure about the
timing for the length of cross, but I did want to just remind
the Court that the next witness raises the prior consistent
statements issues we discussed at the conclusion of the Court
day yesterday.
THE COURT:  I'm sorry, that what?
MS. MOE:  That the next witness we anticipate calling
would be the witness identified as Matt.  And so just wanted to
tee up any issues relating to prior consistent statements.
THE COURT:  I think where we left it was that, as
Ms. Sternheim said, we'll evaluate when you seek to introduce a
prior consistent statement whether, in fact, it's consistent
and whether they have attacked the veracity of that and, if
not, you won't object.
MS. STERNHEIM:  Right.
THE COURT:  And if they do object, I'll decide.
MS. MOE:  Yes, your Honor.  
I just wanted to clear that in advance. 
THE COURT:  Thank you.
Okay.  What do you have, Ms. Menninger? 
MS. MENNINGER:  Under the authority of Rule 611(c), I
have redrafted it into a leading question, if that's
permissible, your Honor.  And what I would ask is --
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578
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
THE COURT:  It's cross, so --
MS. MENNINGER:  Right.  Why not?
-- you knew that cooperating with the government, 
including testifying, would benefit you in your civil 
litigation against the Estate of Epstein and Ms. Maxwell?  And 
then the same question with respect to the victims' 
compensation fund. 
THE COURT:  I'll never win this argument with a
lawyer, but I always think it's a better question just to ask
them did you know.  But you do you.
Okay.  Any objection to that question? 
MS. MOE:  No, your Honor.
THE COURT:  And the same formed question with respect
to the victim compensation fund?
MS. MOE:  Yes, your Honor.
THE COURT:  Okay.  Good.
Anything else we can take up?  And if not -- 
MS. MOE:  Your Honor, if possible, it would be helpful
to have a sense of timing for the duration of cross for timing
of next witnesses.
THE COURT:  Okay.  Ms. Menninger?
You took your foot off the gas for about the last half 
an hour there.  Was that because you were looking forward to 
have some time during lunch or -- 
MS. MENNINGER:  No, your Honor.  I have low blood
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579
          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
sugar.  Sorry.  I did revive myself with a Diet Coke.
Your Honor, I think I would estimate about 45 minutes.
THE COURT:  Okay.  And then, Ms. Moe, do you
anticipate substantial redirect?
MS. MOE:  I do anticipate redirect, but I don't
anticipate it being lengthy.
THE COURT:  Okay.  We have a plan.
I think we can get the jury.   
And we can bring the witness back up please.   
(Witness present) 
(Jury present) 
THE COURT:  Thank you for your patience, members of
the jury.  I hope you had a nice lunch.  And we will continue
with the cross-examination of Witness Jane.
Jane, I remind you you are under oath.   
Ms. Menninger, you may continue. 
MS. MENNINGER:  Thank you, your Honor.
JANE, resumed. 
BY MS. MENNINGER:  
Q.
I want to go back to something I needed to skip earlier.  I
was asking you about whether or not you had traveled on Jeffrey
Epstein's expense commercially after you moved to Los Angeles.
And I started to show you Exhibit J-37, so I'd like to do that
and go to page 13, about three-quarters of the way down.
See if you recognize your name. 
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
A.
Yes.
Q.
And the date associated with your name?
A.
4/17/2000.
Q.
And the amount?
A.
$343.
Q.
Does that refresh your recollection that you were -- a trip
was paid for you in April of 2000 for $343?
A.
No, it doesn't.
Q.
Do you think that looking at other pages of your travel
would refresh your recollection?
MS. MOE:  Objection.
MS. MENNINGER:  If the answer is no, I'm planning on
moving on, your Honor.  I can show other ones.
THE COURT:  Is there anything that would refresh your
recollection?
THE WITNESS:  No.
Q.
We were talking a little bit earlier about your decision to
testify in this case and cooperate with this case.  You met
with the government, I think we established, ten or more times
over the last couple of years.  Is that fair?
A.
Something like that.
Q.
And in each of those meetings, you had your attorney with
you or the vast majority of those meetings?
A.
Yes.
Q.
Your attorneys are Mr. Glassman and Mr. Werksman, right?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
A.
Mr. Glassman.
Q.
At any point during your cooperation with the government,
including testifying, you knew that your cooperation with the
government, including testifying, would benefit you in your
civil litigation against the Epstein estate and Ms. Maxwell;
correct?
A.
No, I don't know that.
Q.
You knew that cooperation with the government, including
testifying, would benefit you in your claim for the victims'
compensation fund; correct?
A.
No, I don't know that.
Q.
Yesterday, you testified a bit about your inability to
speak with your mother about what happened -- you say happened
between you and Epstein; correct?
A.
Correct.
Q.
You testified that you and your mother did not have that
kind of relationship, right?
A.
That's right.
Q.
You testified that you were raised in a household where you
would be in trouble if you said something, right?
A.
Said something about what?  Can you clarify?
Q.
Something personal.
A.
Something, yeah, that personal, yes.
Q.
And the effect on you is you felt you could not tell your
mother about Epstein, right?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
A.
Yes.
Q.
You told the jury about an incident with your guidance
counsellor, right?
A.
Yes.
Q.
Where you got in trouble --
A.
Yes.
Q.
-- for telling the guidance counsellor that your mother was
unavailable and unsupportive, right?
A.
Yes.
Q.
So when you were in high school and you were mine, you
didn't feel like your mother would get your back if you told
her about Epstein's misconduct, right?
A.
Yes.
Q.
And your mother would not want you to report that to
others, right?
A.
Right.
Q.
I want to ask you about another incident that happened when
you were at the Palm Beach School of the Arts.  Do you remember
a time when you claim a teacher pulled your hair?
A.
Yeah.
Q.
You recall telling your mother about the teacher pulling
your hair?
A.
Yes.
Q.
You recall your mother hiring a lawyer for you?
A.
I don't know that.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
Q.
You recall you and your mother filing a lawsuit against
your teacher?
A.
I didn't know that.
Q.
I'd like to show you a couple of exhibits.  They've been
marked for identification purposes as J-7 and J-9.
I'd like to show you what's been marked for
identification purposes, this J-7, second page.  Does that
refresh your recollection that you sued your teacher for
pulling your hair on one occasion?
A.
No, I had no idea my mother did this.
Q.
I'm going to show you Exhibit J-10 -- I apologize, J-9.
MS. MENNINGER:  Your Honor, we have the original of
this document present in the courtroom.  This one is redacted
for the name, but, if it's necessary, may I approach the
witness?
THE COURT:  Show it to the government.
Ms. Menninger. 
MS. MENNINGER:  Your Honor, what we have is an
original of a document that was certified.  It's been marked --
those two pieces have been marked J-8 and J-9.  But they are
combined as originals from the Court; it is one document.
THE COURT:  Okay.
MS. MENNINGER:  So I wanted the record to be clear
what I would be showing the witness.
THE COURT:  You're showing her a combination of J-8
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
and J-9.
MS. MENNINGER:  Yes, your Honor, that are unredacted.
THE COURT:  Yes.  Without objection, Ms. Moe?
MS. MOE:  No objection, your Honor.
THE WITNESS:  Okay.
BY MS. MENNINGER:  
Q.
Does looking at that document refresh your recollection
about a lawsuit that you and your mother filed against your
teacher?
A.
No, I literally had no idea she did this.
Q.
You recognize the name of the teacher --
A.
Yes.
Q.
-- as the same person who was on your Interlochen
application we looked at earlier; correct?
A.
Yes.
MS. MOE:  Objection, your Honor.  We're now testifying
about documents not in evidence.
THE COURT:  That's true.
I'll allow that question and then you're not going to 
do more.  You asked if it refreshed her recollection.  The 
answer is clearly -- is no.  She's answered the same way.   
So let's go. 
MS. MENNINGER:  I'm a little unclear, your Honor.  And
I don't know if we need a sidebar, because there are two other
names that -- without my saying them out loud to ask her if she
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585
          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
remembers who those persons are.
THE COURT:  Well, so you want to point her somewhere
in the document and say, Do you recognize a name?
MS. MENNINGER:  If I could -- I'll try to do it
without naming the names because I don't know if that's a
problem.
THE COURT:  Right.
MS. MENNINGER:  But on J-7, on the second page, they
are in the first paragraph.  And I'm just going to direct the
witness to that line so that we can see the names.
BY MS. MENNINGER:  
Q.
Do you recognize the names of the persons in that first
paragraph?
A.
I remember my teacher, I remember the principal.  I don't
remember the guidance counsellor.
Q.
And do you know whether you and your mother sued the
principal of your high school?
A.
No, I don't.  And we're friends on Facebook, so I had no
idea that we even had an issue.
MS. MENNINGER:  Your Honor, at this time I would offer
into evidence the originals of the document that is a combined
document of Exhibits J-8 and J-9.  I think the Court can take
judicial notice.  They are certified copies.
THE COURT:  You're moving J-8 and J-9?
MS. MENNINGER:  Well, in the combined original exhibit
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586
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
would be the court exhibit, your Honor.
THE COURT:  Right.
MS. MOE:  I object, your Honor, both on relevance and
foundation grounds.
THE COURT:  I'll take a look at the document and then
we'll move on.
MS. MENNINGER:  Okay.
THE COURT:  Can I have the witness's copy?
Go ahead.
MS. MENNINGER:  Thank you, your Honor.
BY MS. MENNINGER:  
Q.
You consider yourself an actor?
A.
Yes.
Q.
An actor plays the role of a fictional character --
A.
Yes.
Q.
-- for a living?
A.
Yes.
Q.
An actor endeavors to effectively communicate the character
they are playing to an audience?
A.
Yes.
Q.
Using their voice, body, actions, right?
A.
Yes.
Q.
An actor takes lines borrowed from a writer and uses those
lines to convincingly portray someone else in front of an
audience; correct?
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
A.
Yes.
Q.
Been an actor for a very long time?
A.
Yes.
Q.
Since middle school?
A.
Yes.
Q.
You performed numerous times as a teenager?
A.
More singing than acting, but yes.
Q.
You traveled away from school to perform?
A.
Yes.
Q.
You performed around the state?
A.
Yes.
Q.
You competed internationally?
A.
This was all singing though, but yes.
Q.
What?
A.
This was all singing, but yes.
Q.
You performed at a number of different venues?
A.
Yes.
Q.
You received coverage in the local newspapers; correct?
A.
Yes.
Q.
Before you began your senior year of high school, you had a
professional agent?
A.
Somewhere in the senior year, yes.
Q.
Before your senior year.
A.
I don't recall if it was before or during.
MS. MENNINGER:  If we could show the witness
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
Government Exhibit 761 at page 4.
THE COURT:  It's been admitted?
MS. MENNINGER:  Not yet, your Honor.  I was just going
to use it to refresh.  I believe there's a witness coming
today.
Q.
Do you recognize that document?
A.
Yes.
Q.
You do?
A.
Yes.
Q.
And what is it?
A.
Well, I actually don't -- can you go back to the first
page?  I recognize that I wrote this.  I don't know what the
document is.
Q.
Okay.
A.
Okay.  Yes.
Q.
And you see the date on there?
A.
Yes.
Q.
And that was before you were a senior?
A.
Yes.
Q.
And then if you go to page 4, you listed your agent;
correct?
A.
Actually, that was a manager, that's why it was -- I didn't
remember.  I had a manager, not an agent.
Q.
But you got an agent in your senior year?
A.
Yes.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
Q.
You got a manager and an agent by your senior year?
A.
Yes.
Q.
All right.  And you moved to New York for the purpose of
going to that high school here; correct?
A.
Not to go to that high school.  The high school wasn't a
performing arts school; it just was a private school.
Q.
Professional Children's School?
A.
Yes.  It was for kids who were seeking professions in --
entertainment professions.  And if they booked a job, then the
school would work with them of sending them homework, but we
didn't do any arts in that school.
Q.
I see.  Thank you for that clarification.
And you did have work in your senior year; correct? 
A.
I did not, actually, not till after I graduated.
Q.
Okay.  You don't remember any school notes in which they
commented that you had been missing a lot of school because of
your work in your first quarter at that school?
A.
They might have written those notes that I was working, but
I was not working.
Q.
That you were working, but you weren't?
A.
No, I was skipping school.
Q.
Later in your -- after your senior year, you got this job
in Los Angeles, right?
A.
Yes.
Q.
And you moved to Los Angeles to work on the soap opera?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
A.
Yes.
Q.
And you recently commemorated 20 --
A.
-- something years, yes.
Q.
Twenty-something years on that show.
A soap opera is characterized by tangled interpersonal
situations, fair enough?
A.
It's a very eloquent way to put it, I guess.
Q.
And melodramatic are sentimental treatment of those
interpersonal situations, right?
A.
Hopefully, not melodramatic, just dramatic.
Q.
Your character has been involved in a number of different
plot lines over those 20-something years, fair?
A.
Naturally, yes.
Q.
You've played a protective mom?
A.
Yes.
Q.
You've been bullied?
A.
Yes.
Q.
You've battled cancer?
A.
Yes.
Q.
You've played a car crash victim?
A.
I forgot about that one, but yes.
Q.
Mental health issues?
A.
Yes.
Q.
You've been stalked by serial killers?
A.
Yes.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
Q.
You played a prostitute?
A.
Not my favorite storyline.
Q.
You ran a restaurant?
A.
Yes.
Q.
You took down a Mexican drug cartel?
A.
Yes.
Q.
Essentially, there's no melodramatic role that you haven't
played?
A.
If you want to call it melodramatic.  I just say dramatic,
but yeah.
Q.
It involves a significant amount of drama; correct?
A.
Yes.
Q.
You're able to cry on command?
A.
No, not always.  It's not really how it works.
Q.
You express pain through your characters?
A.
Yeah, of course.
Q.
Vulnerability?
A.
Yes.
Q.
The job you've trained for for a long time, right?
A.
Yes.
Q.
You've been hired to work on other TV shows and series,
right?
A.
Yes.
Q.
A feature-length movie?
A.
Yes.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
Q.
Christmas specials, a wide range, right?
A.
No Christmas special yet, I don't think, but yeah.
Q.
You had a reality show we talked about a little while ago?
A.
Unfortunately, yes.
Q.
Which was not real?
A.
No, it's not real.
Q.
Your accusations in this case depend significantly on
you -- your memory that you were 14 when you met Epstein;
correct?
A.
Correct.
Q.
You repeated it a number of times on the stand, right?
A.
Right.
Q.
Well, actually, when you first met with the government, you
told them that you were 13 when you met Epstein, right?
A.
No, I said I might have been 13 going on 14; because my
birthday is in August, and I believe I met them earlier in the
summer.  So it was just a small technicality, I guess.
Q.
Well, in your civil complaint in the first paragraph, you
said it all started in 1994, when 13-year-old Jane met Epstein
and Maxwell; correct?
A.
Correct.  I was 13 in June and July.
Q.
You didn't say "13, going on 14."
A.
I don't know.  I don't know.
Q.
Okay.  Do you want to take a look at 3509-007, paragraph 1.
A.
Okay.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
Q.
And there you just said you were 13, right?
A.
It says there that I'm 13, yeah.
Q.
And that was what was filed by your attorney in court?
A.
Yes.
Q.
And you told the government 13, but later they refreshed
your memory that maybe you were 14, right?
A.
No, I always from the beginning said 13, but I turned 14
that summer.
Q.
Okay.  I'll have you take a look at 3509-008, page 11.  And
looking at that, do you recall the government asking you --
THE COURT:  Where?
MS. MENNINGER:  I apologize.  The second from the --
second full paragraph from the bottom up.
Q.
Does that refresh your recollection about a conversation
you had with the government?
A.
No, because I didn't write any of this.  The second half of
that makes sense, which is I was probably 13.  And it says here
that I turned 14 that summer.
Q.
So you were not asked if it was possible that you met
Epstein after you turned 14?
A.
I don't remember.
Q.
But I understand now you're saying you believe you were 14
because it was later in the summer, right?
A.
What was later in the summer?
Q.
When you met Epstein.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
A.
No, I said it was earlier in the summer.
Q.
Okay.  So you thought you met him earlier in the summer?
A.
Yes.
Q.
And then we talked about The Lion King, where you thought
you were 14 when you saw the Broadway show, but then realized
you were not; correct?
A.
Correct.
Q.
It actually came out when you were 17; correct?
A.
Correct.
Q.
Now, you recall meeting Mike Wallace of 60 Minutes fame in
New York, right?
A.
Yes.
Q.
And you believed that you were 15 when you met him?
A.
I don't remember.
Q.
You met him with Epstein, I should clarify, right?
A.
Yes.
Q.
And your first meeting with the government -- I'll have you
look at 3509-001 on page 5 in the middle of the page.
A.
I see it.
Q.
And you told the government about meeting Mike Wallace?
A.
Yes.
Q.
And that was Mike Wallace's 80th birthday party; correct?
A.
I think so.
Q.
And you came in and said happy birthday to Mr. Wallace;
correct?
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
A.
I sang Happy Birthday, yes.
Q.
And that's when you were 15?
A.
I'm not sure.  That's why it says approximately.  I
couldn't remember, and I don't know how old Mike Wallace was
when --
Q.
Okay.
A.
-- is now or he's passed away.
Q.
He has passed away.
A.
Passed away.
Q.
You recall it being his 80th birthday party though;
correct?
A.
Yes.
Q.
Okay.  And you don't know what his birthday is, I think you
just said; correct?
A.
No, I don't know.
Q.
If I can have you take a look at J-33, on the right side.
Do you have any reason to believe that that birthday is
incorrect?
MS. MOE:  Objection.
THE COURT:  Sustained.
Q.
Does it refresh your recollection?
MS. MOE:  Objection.
THE COURT:  Sustained.  No basis for refreshing.
Q.
It's true that Mike Wallace's birthday party, 80th birthday
party, was in May of 1998; correct?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
MS. MOE:  Objection.
THE COURT:  Overruled.
A.
I don't remember.
Q.
You might have been 15 or it might have been some other
date, right?
A.
Right.
Q.
You moved to New York in or around 1998, right?
A.
Yes.
Q.
And you went to your senior year here from '98 to '99?
A.
Yes.
Q.
What you put in your civil complaint is that you moved to
New York in 1996 to go to school here; correct?
A.
I don't remember saying that.
Q.
Let's go back to 3509-007, paragraph 20.  And in your civil
complaint, you alleged that you moved to New York in 1996 when
you were 16; correct?
A.
No, I don't think I said that, because I didn't move to New
York then.
Q.
Do you want to look at the first page of this?
A.
No, I -- I know.  I know what it is.
Q.
You know your lawyer signed it?
A.
Yes.
Q.
The lawyer that you met with the government with multiple
times, right?
A.
Yes.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX5                 Jane - cross
MS. MENNINGER:  If I could have one moment, your
Honor.
THE COURT:  You may.
(Counsel conferred) 
BY MS. MENNINGER:  
Q.
In this civil case -- just a moment.
In your civil case, you were given something called
interrogatories.  Do you know what those are?
A.
No.
Q.
They are questions for you to answer under oath.  Does that
ring a bell?
A.
No.
Q.
Do you recall answering any questions under oath?
A.
No.
Q.
Do you know what your lawyer put down as your answers under
oath to any particular questions?
A.
No.
Q.
I'm going to show you a document that we have marked as
J-15.  I have one that's redacted, but if you would like to see
the entire document, just let us know.  We have that available.
Do you recognize the caption on this case?
A.
Yes.
Q.
Is this your lawsuit that you filed?
A.
Yes.
Q.
And this is signed by your attorney in June of 2020;
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
correct?
A.
I don't see a date.
Q.
On the last page.  Sorry.  I forgot you didn't have --
A.
Yes.
Q.
And in June of 2020, you answered, through your attorney,
interrogatories, right?
A.
Right.
Q.
And interrogatory number nine, if I could have you turn to
that, on page 4, asked you to identify all persons other than
decedent, Mr. Epstein, who have ever committed or attempted to
commit sexual misconduct or offenses against or otherwise
concerning you, including, without limitation, any unwelcome
behavior of a sexual nature, sexual abuse, sexual assault,
threats or intimidation of a sexual nature or sexual
exploitation, regardless of whether the misconduct or offenses
involved physical touching, and you responded none.  Correct?
MS. MOE:  Objection.
THE COURT:  Are you moving this?
MS. MENNINGER:  Yes, your Honor, this interrogatory.
MS. MOE:  Your Honor, I think the record is that this
witness doesn't recognize it, doesn't know anything about it,
and so for that reason we'd object.
MS. MENNINGER:  Your Honor, it's a legally binding
document.
THE COURT:  Can I see the whole document?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX5                 Jane - cross
MS. MENNINGER:  Yes, your Honor.
THE COURT:  Are you making an authentication
objection?
MS. MOE:  Your Honor, it's about relevance and
personal knowledge.  She's being asked about --
THE COURT:  Yes, I understand.
MS. MOE:  Thank you.
THE COURT:  Overruled.
J-15 is admitted. 
(Defendant's Exhibit J-15 received in evidence) 
MS. MENNINGER:  Thank you.  No further questions.
(Continued on next page) 
 
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
THE COURT:  Let me just ask about J-8, the combined
J-8 and J-9.  I'll overrule the objection, and it's admitted.
MS. MENNINGER:  Thank you, your Honor.
(Defendant's Exhibits J-8 and J-9 received in 
evidence) 
THE COURT:  Redirect.
MS. MOE:  Thank you, your Honor.
REDIRECT EXAMINATION 
BY MS. MOE:  
Q.
Since we were just talking about Defendant's Exhibits J-15,
I just want to be clear, do you recognize this document?
A.
I don't have a document in front of me.  Which one, this
last one?
Q.
Yes.
A.
No.
Q.
Did you write this?
A.
No.
MS. MOE:  Your Honor, may I proceed?
THE COURT:  Yes.
MS. MOE:  Thank you.
Q.
Jane, you were asked questions on cross-examination about
your meetings with the government.  Do you remember being asked
about that?
A.
Yes.
Q.
And you were asked about your meetings with me.  Do you
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
remember being asked about that?
A.
Yes.
Q.
And you were asked about whether in your meetings with the
government you were asked about the questions that I was going
to ask you on direct examination.  Do you remember being asked
about that?
A.
Yeah.
Q.
Did I or any other prosecutor ever tell you what to say on
the witness stand at this trial?
A.
No.
Q.
What did we tell you to do?
A.
Just tell the truth.
Q.
Has anyone told you what to say at this trial?
A.
No.
Q.
You were asked some questions on cross-examination about
notes of meetings with the government.  Do you remember being
asked about that?
A.
Yes.
Q.
I want to ask you about your meetings with the government.
When you met with the FBI and the government, did you cover
every detail of your entire relationship with Maxwell and
Epstein in every meeting with the government, or did you talk
about different topics at different times at different
meetings?
A.
Different topics, different times, different meetings.
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LC1Qmax6                 Jane - Redirect
Q.
Did you take any notes during the meetings?
A.
No.
Q.
Who took the notes?
A.
I don't know.
Q.
Did you have any opportunity to review any notes or reports
of any meetings for accuracy?
A.
No.
Q.
And before Ms. Menninger showed you some notes during your
cross-examination, had you ever seen any of that before?
A.
No.
Q.
In your conversations with prosecutors, were there times
when we asked you about additional details of your experiences
in followup meetings?
A.
Yes.
Q.
Did we discuss every topic at every meeting?
A.
No.
Q.
I want to back up and ask you about your first meetings
with the government.
Can you explain for the jury, was it difficult to talk 
to the government in your first meetings? 
A.
Yes, absolutely.
Q.
Why was that difficult?
A.
Because I was sitting in a room full of strangers and
telling them the most shameful, deepest secrets that I'd been
carrying around with me my whole life.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
Q.
In those first meetings, were you able to share with the
government all of the details of what had happened to you?
A.
No.
Q.
Why was that?
A.
Because it was too difficult, too difficult emotionally,
too difficult on every level.
Q.
Over time, did you become more comfortable sharing the
details about what happened to you with the government?
A.
Yes.
Q.
Why was that?
A.
Because I guess I became more familiar with the people
sitting in front of me, and starting to feel like I could trust
them, and it didn't feel quite as embarrassing.
Q.
Did there come a point in your meetings with the government
where fewer people were in the room?
A.
Yes.
Q.
And did you have an understanding at the time about why in
your meetings with the government there started to be fewer
people in the room?
A.
I believe it was to make me more comfortable.
Q.
And how did you feel once you started having meetings with
the government with fewer people in the room?
A.
It started feeling easier.
Q.
I want to ask you about your last few meetings with the
government leading up to the trial.  During those meetings in
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
the last few months, was your attorney present?
A.
No.
Q.
In general, who was in the room?
A.
Just me and you guys.
Q.
You were asked some questions on cross-examination about
your living situation when you were in middle school and high
school living in Palm Beach.  Do you remember those questions?
A.
Yes.
Q.
So I just want to ask you about where you were living at
the time.  In the summer of 1994, when you first met Maxwell
and Epstein, where were you living?
MS. MENNINGER:  Objection.  Leading, your Honor.
THE COURT:  Overruled.  You may answer.
A.
That summer we were still living on Palma Way at my
mother's friend, Joan, in her pool house in her back yard, and
we -- when we came home from camp that summer, we were still
living in that place.
Q.
Did your family struggle financially during the years that
you were in high school?
A.
Yes.
Q.
Was there ever a time when you and your brothers had a hard
time paying for lunch at school?
MS. MENNINGER:  Objection, your Honor.  403.
THE COURT:  Overruled.  You may answer.
A.
Yes.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
Q.
Can you tell the jury what you remember about that?
A.
I mean, I remember my mother never had any money.  She
didn't work, so she didn't have money to really pay for
anything.  We had food stamps that she refused to use because
her pride was too big, and she would sort of, you know,
scrounge for quarters, and sometimes I would give my brothers
my lunch money and pretend like I had some so that they could
eat.
Q.
Did your family's financial circumstances improve after you
met Maxwell and Epstein?
A.
But -- no.
Q.
Did Jeffrey Epstein help your family financially?
A.
In some ways, yes.
Q.
Can you describe for the jury the ways that Jeffrey Epstein
helped your family financially?
A.
Well, he -- he handed me cash.  He gave us a computer.  He
paid for some school stuff.  He -- he paid for Interlochen Arts
Camp for the next two summers.  He paid for my younger
brother's Interlochen Arts Academy his entire year at boarding
school.  Gave us gifts.  And, you know, so on and so forth.
Q.
Did there come a time when your family moved out of the
pool house?
A.
Yes.
Q.
And where did you move to?
A.
That's when we moved to that second house that was first
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
discussed, that three-bedroom house.  My sister was the one who
rented it for us.
Q.
Approximately when did you move out of the pool house and
into the three-bedroom house?
A.
We moved out of the pool house in, I think, spring of '96.
Wait.  Sorry.  I'm tired.  The spring of '95.  Sorry.
Q.
Do you recall being asked some questions on
cross-examination about whether you traveled internationally
when you were in high school?
A.
Yes.
Q.
Just to be clear, did those trips have anything to do with
Maxwell and Epstein?
A.
No.
Q.
Without discussing any specifics about your family members,
do you have some family members who live abroad?
A.
Yes, that's -- the country that we would travel to, that's
where we were from, and any time those dates that were
discussed earlier, that would be a family trip home.
Q.
Do you recall being asked on cross-examination questions
about whether you had ever talked to a reporter?
A.
Yes.
Q.
And you were asked about whether you made a statement to a
tabloid about what had happened to you with Jeffrey Epstein.
Do you remember being asked about that?
A.
Yes.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
Q.
Can you please explain for the jury what were the
circumstances under which a reporter approached you?
A.
Well, it was a reporter who called me and said --
MS. MENNINGER:  Objection.  Hearsay, your Honor.
A.
Okay.  Sorry.
MS. MOE:  I'm happy to rephrase, your Honor.
THE COURT:  Go ahead.
Q.
When you had that conversation with the reporter, did you
want to have that conversation?
A.
No.
Q.
Why did you agree to speak to that reporter?
A.
Because he basically blackmailed me.
MS. MENNINGER:  Objection, your Honor.  Hearsay.
THE COURT:  Overruled.  Go ahead.
A.
He said that he -- that court documents with my name on it
were unredacted, and that the Epstein's little black book was
out, and my name was in it, and he was going to print --
MS. MENNINGER:  Objection, your Honor.  Hearsay.
THE COURT:  We'll limit what the witness has testified
to as not being offered for the truth of what was stated by
someone else but the effect on the listener.  
And let's re-narrow the question. 
MS. MOE:  Yes, your Honor.  May I ask a leading
question to navigate through this?  
THE COURT:  Let me hear the question.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
Q.
When you spoke with that reporter, did that reporter
threaten to reveal your identity publicly if you wouldn't speak
with him?
A.
Yes.
Q.
Is that why you spoke with the reporter?
A.
Yes.
Q.
Did you make an agreement with the reporter in order to
make sure your identity wasn't revealed?
A.
Yes.
Q.
And what was that agreement?
A.
The agreement was to briefly discuss only how I had met
Jeffrey Epstein.
Q.
And in exchange for doing that, what did the reporter agree
to do?
A.
He promised to keep my name anonymous.
Q.
Did the reporter keep your name anonymous?
A.
Yes.
Q.
Was that important to you at the time?
A.
Yes.
Q.
Why was that so important to you?
A.
It was important because I was -- I was scared.  I was
embarrassed, ashamed.  I didn't want anybody to know any of
this about me.  I wanted to stay out of it.  I -- I'm working
on a TV show, and I didn't want everybody to know that that was
me and associate me with any of this, and so I desperately did
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
whatever I had to do to make sure that he didn't reveal my
name.
Q.
What were you scared of?
MS. MENNINGER:  Objection, your Honor.  Asked and
answered.
THE COURT:  Sustained.
Q.
Approximately how long was that conversation with the
reporter?
A.
I don't remember.
Q.
Was it in person?
A.
No.  It was in my car on the side of the road with my phone
plugged in.
Q.
Was that a phone conversation or an in-person conversation
in your car?
A.
Just a phone conversation.
Q.
Was it a detailed conversation?
A.
I tried to make it not so detailed.
Q.
You were asked some questions on cross-examination about
your attorney, Robert Glassman.  Do you remember those
questions?
A.
Yes.
Q.
Can you just explain for the jury without getting into any
privileged conversations, how did you find this attorney?
A.
He was a referral.  Actually, he's friends with my
husband's best friend, and I met with him, and I just liked
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
him.
Q.
You were asked some questions on cross-examination about
your applications for admission to Interlochen.  Do you
remember those questions?
A.
Yes.
Q.
I'd like to just ask you a few questions about those
particular applications.
A.
Okay.
MS. MOE:  If I could just have a moment, I'm going to
grab a copy of them.
Your Honor, I'd ask for permission for the witness and 
the jurors to view Defendant's Exhibit J-3 which I believ is in 
evidence under seal. 
THE COURT:  Let me just verify.  Yes.
MS. MOE:  Thank you, your Honor.  May the jurors turn
to that in their binders?
Ms. Menninger, without objection? 
MS. MENNINGER:  Yes, your Honor.
THE COURT:  Jurors, you may pick up your binder and
turn to J-3, correct?
Q.
Jane, do you have that up in front of you?
A.
Yes.
Q.
Just to be clear, what we're talking about is Defendant's
Exhibit J-3, your application for admission to Interlochen for
the summer of 1994?
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
A.
Yes.
Q.
How old were you when you applied to go to Interlochen in
1994?
A.
13.
Q.
I want to ask you about a few things on this application.
But when I do, I just want to be careful we are not reading
anything into the record that's identifying about you.
If we could turn to the second page of that 
application, and directing your attention to the second section 
towards the bottom, do you remember Ms. Menninger asking you 
questions about whether you told Interlochen you were having 
any difficulties? 
A.
I don't remember.
Q.
Let me just be clear about this portion of the application.
I want to direct your attention to the portion of the middle
section that says:  List two difficult works performed in
orchestra, band or ensemble within the past year.  Do you see
that question?
A.
Yes.
Q.
Is that the question you answered:  Nothing has been
difficult for me?
A.
I guess I did.
Q.
And what did you mean when you said that?
A.
I have no idea.
Q.
At the time, were you fairly talented?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
A.
Yes, and very cocky, apparently.
Q.
Just to be clear, nowhere in this application did you say
you weren't having any difficulties at home, right?
A.
No.
Q.
Were you having difficulties at home during this time?
A.
Absolutely, yes.
Q.
You were asked some questions about the recommendation
letters in your applications to Interlochen.  Do you remember
those questions?
A.
Yes.
Q.
And you were asked about whether your recommenders talked
about your family in a favorable light.  Do you remember those
questions?
A.
Yes.
Q.
The people who you asked to recommend you for Interlochen,
did they know what was going on in your house at home?
A.
No.
Q.
Why was that?
A.
Because we were very good at hiding what was going on at
home, and these recommendation letters are basically just from
our school teachers.
Q.
I want to ask you one last question about this application.
If you could turn back to the first page of Defendant's Exhibit
J-3.  And I want to focus your attention at the top section
with applicant information.  You see a few lines down, there's
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
a line that starts F, above sex, M or F?
A.
I'm sorry, I'm having a hard time finding it.  Where is it?
Q.
So, in the very -- I'm looking in the first page of
Defendant's Exhibit J-3 in the top header, the very first top
of the document under applicant information, do you see about
five lines down underneath the names of your siblings, the line
there?
A.
Yes.  Yes.  Sorry.
Q.
In your application, did you have to list your height and
weight?
A.
Yes.
Q.
And how tall were you when you were going to summer camp
that summer?
A.
Five-two.
Q.
How many pounds did you weigh?
A.
90.
Q.
What grade were you in?
A.
Seventh grade.
Q.
I want to ask you about the next year you went to
Interlochen.  If you could turn to --
MS. MOE:  I'd ask for permission for the jurors to
turn to Defendant's Exhibit J-4 which is in evidence under
seal.
THE COURT:  Without objection, you may.
MS. MENNINGER:  Yes, your Honor.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
THE COURT:  You may.
MS. MOE:  Thank you, your Honor.
THE COURT:  J-4 for the jurors.
BY MS. MOE:  
Q.
On this application, I want to ask you about that same
section about the applicant information?
A.
Mmm-hmm.
Q.
Directing your attention to that same line, by the next
year in 1995, how tall were you by then?
A.
It says I was five-four.
MS. MENNINGER:  Objection, your Honor.  It misstates
the date on the document.  The date on the document is not what
was just represented by counsel.
THE COURT:  Ms. Moe, go ahead.
BY MS. MOE:  
Q.
In your application for the next year at summer camp, how
tall were you by then?
A.
It says I was five-four.
Q.
You'd grown two inches?
A.
I don't know, I may have been fibbing.
Q.
What grade were you in by then?
A.
Eighth grade.
Q.
Do you recall defense counsel asking you about Government
Exhibit 761 and whether that was your application to the
Professional Children's School?
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615
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
A.
I'm sorry, I don't know what that means.
Q.
Do you remember being shown a document on cross-examination
and being asked about whether that was your application to the
Professional Children's School?
A.
Yes.
Q.
And did you recognize that document as your application to
the Professional Children's School?
A.
No.
Q.
Do you recognize the handwriting on that document?
A.
Is it here?  Can I see it or --
Q.
That's all right.  I can move on.
A.
Okay.
Q.
You were asked some questions on cross-examination about
your career as an actor.  Do you remember being asked about
that?
A.
Yes.
Q.
Do you know the difference between acting on television and
testifying in court?
A.
Yes.
Q.
What's the difference?
A.
Acting on television is not real, and testifying in court
is real, is the truth.
Q.
Are you acting here today?
A.
No.
Q.
What are you here to do?
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
A.
I am here to hopefully finally find some sort of closure to
all of this.  This is something that I have been running from
my entire life up until now, and I'm just tired of it, and I
was just hoping that I could help in any way to make that
happen and to hopefully find some peace and healing some day.
Q.
I want to ask you a few more questions about the summer of
1994.  About how many weeks were you at summer camp that
summer?
A.
Eight weeks.
Q.
Were there weeks when you were at summer camp that summer
when you were 13?
A.
Yes.
Q.
Were there weeks when you were in summer camp that summer
when you were 14?
A.
Yes.
Q.
Is your birthday in the summer?
A.
Yes.
Q.
Do you remember which week of summer camp you met Ghislaine
Maxwell and Jeffrey Epstein?
A.
No.
Q.
How strong is your memory of meeting Ghislaine Maxwell and
Jeffrey Epstein at summer camp in 1994?
A.
Pretty strong.
Q.
Why is that memory pretty strong?
A.
Because it was the beginning of when my life would change
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617
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
forever.
Q.
You were asked on cross-examination about your memories of
being sexually abused.  Do you remember those questions?
A.
Yes.
Q.
How old were you when you first touched Jeffrey Epstein's
penis?
A.
14.
Q.
Can you describe for the jury how you touched his penis
when you were 14?
MS. MENNINGER:  Your Honor, this exceeds the scope of
cross.  I didn't ask this question.
MS. MOE:  Your Honor, I believe there were questions
on cross-examination about whether she remembers details how
strong those memories are.
THE COURT:  Overruled.
MS. MOE:  Thank you, your Honor.
THE COURT:  You may answer.
A.
I mean, how do you touch a penis, you put your hand around
it?
Q.
And what would you do when you touched his penis when you
were 14?
A.
Umm, masturbate him?
Q.
Who would give you instructions about what to do during
incidents when Jeffrey Epstein sexually abused you when you
were 14?
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
A.
Well, the first time was Ghislaine.
Q.
Why does that stand out to you in your memory?
A.
Because it was just significant.  It's when that sort of
like fun, casual relationship I had with her just changed.
Q.
When you say the first time, when you talk about first
times, what do you mean by that?
A.
Meaning that the first time I was ever like unclothed with
just the both of them.
Q.
You were asked a lot of questions on cross-examination
about first and first times.  Do you remember those questions?
A.
I think so.
Q.
Fair to say there were a lot of firsts for you when you
were 14 and 15 and 16 with Maxwell and Epstein?
MS. MENNINGER:  Objection.  Leading, your Honor.
THE COURT:  Sustained.
MS. MOE:  Your Honor, if I could just have one moment.
THE COURT:  Okay.
(Pause) 
MS. MOE:  Thank you very much.
BY MS. MOE:  
Q.
I want to ask you about just one last topic.  You were
asked some questions on cross-examination about the award you
received from the Epstein Victims' Compensation Fund.  Do you
remember being asked on cross-examination about that?
A.
Yes.
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619
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
Q.
To be clear, would you give that money back if it meant
that you weren't abused as a kid?
MS. MENNINGER:  Objection.  Leading, your Honor.
THE COURT:  Sustained.
Q.
Jane, in your own words, can you tell the jury what that
money meant to you?
A.
Sorry.
Q.
It's all right.  Take your time.
A.
I mean, it -- oh, I wish I would have never received that
money in the first place because of what happened.  You know,
when you're seeking some sort of closure, and I guess in, you
know, laws in this country, compensation is the only thing you
can get to try to move on with your life and for the, you know,
pain and abuse and suffering that I received, and all the
out-of-pocket money I paid to try to make this go away and to
try to fix myself.
MS. MENNINGER:  Objection.  Narrative, your Honor.
THE COURT:  Overruled.
A.
So, you know, hopefully this just puts it all to an end,
and I can move on with my life.
Q.
Do you have any financial stake in the outcome of this
trial?
A.
No.
MS. MOE:  Nothing further, your Honor.
THE COURT:  Okay.  Ms. Menninger.
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620
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
MS. MENNINGER:  No recross.  Thank you.
THE COURT:  Thank you, Jane.  You may step down.  You
are excused.
(Witness excused) 
THE COURT:  Members of the jury, we will take our
mid-afternoon break.  Your snacks are here.  We will break for
about 15 minutes.  Thank you.
(Jurors not present)  
THE COURT:  You may be seated.
Matters to take up before the break? 
MS. MOE:  Not from the government, your Honor.
MS. STERNHEIM:  I have a matter, Judge.  I believe the
next witness is Matt, whose issue was teed up yesterday.  In
advance of his testimony, just to make sure that it is
compliant with the Federal Rules of Evidence, I would request
that the government give a proffer of what he is going to say,
as there are things in his 3500 material that did not come out
on direct examination, and it would be improper for him to be
able to testify as to things that are not prior consistent
statements.
THE COURT:  There are things in his 3500 material that
the previous witness said to him --
MS. STERNHEIM:  Yes.
THE COURT:  -- that were not asked about of the
witness.
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621
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1Qmax6                 Jane - Redirect
MS. STERNHEIM:  Right.
THE COURT:  Okay.  Can you confer?
MS. MOE:  Yes, your Honor.
THE COURT:  During the break?
MS. STERNHEIM:  Of course.
THE COURT:  Great.  I appreciate you raising it, and
let me know if there's disagreement.  Thank you.
MS. STERNHEIM:  Will do.
THE COURT:  We'll break for ten.
(Recess)  
(Jurors not present)  
THE COURT:  Matters to take up?
MS. MOE:  Not from the government your Honor.
MS. STERNHEIM:  Just very briefly, Judge.  I did have
an opportunity to confer with Ms. Moe.  I just want to state
for the record, with regard to the introduction of prior
consistent statements, it is my understanding that there needs
to be a similar exactitude as one would have with prior
inconsistent statements, and I understand that the government
is offering their next witness, Matt, to establish the fact
that there was some colloquy discussion between Matt and Jane
at an earlier time before this.  I have no problem with that.
The issue is that, at least in the 3500 material, the 
statements that Matt made are not -- they don't dovetail 
entirely with what went on on the direct examination.  One 
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
example would be, his 3500 material is that she said that 
Ms. Maxwell brought girls.  There was no testimony to that.   
There was testimony that there were women, but not 
that she brought them.  There was testimony of her presence, 
but not necessarily that she told the group that everything 
would be okay.   
That's the kind of statements that are in the 3500 
material.  And I have addressed this with Ms. Moe.  We're not 
entirely sure how it will come out, but it isn't a prior 
consistent statement.  There is a prior conversation or 
discussion, but the statements themselves are not consistent. 
THE COURT:  Ms. Moe.
MS. MOE:  Your Honor, I believe the Court's ruling on
this is that we would evaluate the statements as they come out
through the witness.  And as a preview, after conferring with
Ms. Sternheim on this issue, we did confer with Matt and asked
him about what he recalls, specifically about the woman he
recalls Jane telling him.  Again, it's always difficult to
predict the precise testimony of a lay witness, but my general
expectation is that he would explain that in conversations with
Jane, she explained that there was a woman at the house who
made her feel comfortable; that sometimes there was that woman
at the house, sometimes there were girls; and so that made her
feel comfortable in the house.
I don't expect that the testimony would go beyond 
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LC1Qmax6                 Jane - Redirect
that, but again, we're talking about a number of conversations 
during this time period.  That's my current expectation.  But I 
think with respect to I think some of the granular issues, the 
difference between woman and girls, I think, especially in this 
context is not so different that it would not be a prior 
consistent statement.  And beyond that, your Honor, we think 
this tracks the rule. 
MS. STERNHEIM:  Judge, I disagree.  The distinction
between a girl and a woman is precisely what this case is
about, and she was very clear that she felt like she was the
only one.  The other people were women.
THE COURT:  She said she didn't know what their ages
were.
MS. STERNHEIM:  She didn't know their ages, but she
did not refer to them as girls.
THE COURT:  But wasn't the recent testimony, I think
it was on cross, which was:  Were there underage girls.  And
she said, "I wouldn't know the ages."
MS. STERNHEIM:  That's fine, but to call them girls
connotes that they are minors, and that parlays right into the
government's theory of the case, and they're bringing it out
through a witness whose sole purpose is substantiated prior
consistent statement, and that is not consistent with the
testimony that we've heard.
If he wants to say there were prior women, I can't 
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
make objection to that, but I do object to the term girls, and 
I do object to other aspects of his 3500 material insofar as 
there was no testimony, and this witness should not be used to 
supplant what the primary witness did not testify about. 
THE COURT:  I agree with you on that distinction.
This witness can't testify as a prior consistent statement that
Jane told him that there were -- I mean, there's ambiguity in
the term, but I think since the witness couldn't testify if
they were underage or not, I can't allow the witness to make
that as an implication since that implication wouldn't be
consistent with the testimony.
MS. MOE:  Yes, your Honor.  I think on this point, to
be clear, the government doesn't intend to argue in closing
that the jury must infer from the evidence that there were
underage girls in the room because of Matt's testimony.  I
think it is, unfortunately, common that often women above the
age of 18 are referred to as girls.  That's how he remembers
it.
I would be happy to lead him through that testimony, 
if the Court would prefer, and use the term females.  It's not 
our intention to elicit the testimony to suggest anything in 
particular about the ages of those folks, but that's how he 
remembers it, and that's the word he uses. 
THE COURT:  Why don't you -- I'll let you lead, but
why don't you just say other people, or something like that.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
MS. MOE:  If I ask him about that, I do expect he
would say, yes, other girls.  And so I think unless it's a
leading question, I just want to front that in order to avoid
creating an issue there.
THE COURT:  Yes.  Well, lead, and that way I don't
have to strike the testimony as not a prior consistent
statement.
MS. MOE:  Yes, your Honor.  If the Court authorizes us
to lead, I think we can navigate through this area.
THE COURT:  Ms. Sternheim, okay if she leads through
this portion?
MS. STERNHEIM:  I have no problem with that, Judge,
but if the witness on his own sua sponte says girls, I will be
objecting to that.  I cannot rely on what they are going to do
or not do in closing.
THE COURT:  I agree with that.  That's why I said -- 
MS. STERNHEIM:  That's fine.
THE COURT:  -- I will let Ms. Moe lead so I don't have
to strike that testimony.  I think we are in agreement that if
he were to testify that she told her that there were girls, the
implication would be underage; that implication wouldn't be a
prior consistent statement, and so I wouldn't allow that
implication to stay with the jury.
MS. STERNHEIM:  I understand, and I thank you for
that.  But the other part would be there was no testimony on
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
direct that Ms. Maxwell brought women.  There were women there
but not that she brought them, and I think that Ms. Menninger
cleared that up on cross-examination as well.
THE COURT:  Okay.
MS. MOE:  Your Honor, particularly, if I'm permitted
to ask leading questions, I wouldn't expect to ask that
particular question.
THE COURT:  Okay.  You won't ask it, it sounds like.
MS. MOE:  Yes, your Honor.
MS. STERNHEIM:  Thank you Judge.
THE COURT:  Okay.  Thank you.  Anything else?
MS. MOE:  Your Honor, very briefly, I just wanted to
clarify because I believe in briefing the subject of prior
consistent statements, defense counsel had raised the prospect
of recall of the witness.  So I just wanted to make sure in
terms of our contacts with Jane, we had clarity on that status.
THE COURT:  Yes.  And I didn't hear it from anyone on
the 615 issue on the timing that I said, so I assumed you
worked that out, correct?  
MR. ROHRBACH:  Yes, your Honor.  Our understanding is
that none of the witnesses who are testifying as victims are
intending to observe any of the trial until at least both sides
have rested, which we've conveyed to the defense, and we
understand there would be no objection to that.  
THE COURT:  So then the open question is might there
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
be recall that would prohibit the government from conferring
with a witness who's completed their testimony?
MS. MOE:  Yes, your Honor.  We just wanted to navigate
that, otherwise I think we would make arrangements for Jane to
travel home to her family today.  And so if we wanted to make
those arrangements, we will need to be in touch with her to
make those arrangements, otherwise not planning to have
substantive communications, but I wanted to be very transparent
and candid about those contacts and just the state-of-play on
this issue.
MS. MENNINGER:  Your Honor, my recollection is that
there was a second witness who was going to be offering prior
consistent statements for Jane.
MS. MOE:  That's correct, your Honor.  I think our
preference would be for Jane to be permitted to leave the
district, but if we can be in touch with her about the
possibility of a need for recall after today, if there are
additional prior consistent statements, we can navigate it that
way.  Otherwise, Jane would have to remain in the district for
I think potentially a long time.
MS. MENNINGER:  I have no objection to that, your
Honor.  I do have one clarifying question, which is, while not
observing the trial in the courtroom, there is certainly
substantial coverage of the trial including relaying witnesses'
testimony.  So I don't know whether that has been clarified
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1Qmax6                 Jane - Redirect
with the witness that not just sitting in the overflow room,
but we're not reading media about it either.
THE COURT:  I'm sure you all discussed this when I
raised the 615 issue weeks ago, right?  Maybe it surprised you
there's media coverage.
Why don't you talk -- I am going to bring in the jury, 
so you'll talk about it and let me know if you disagree. 
MS. MOE:  Thank you, your Honor.
THE COURT:  Okay.  Bring in the jury.
I'm sorry.  Two administrative matters before we bring 
in the jury.  I admitted J-8 and 9. 
MS. MENNINGER:  Yes, your Honor.
THE COURT:  And to be clear, that needs to be admitted
under seal because it has specific identifying information of a
witness whom I've permitted to testify under a pseudonym.
Tell me if that's true for J-15 as well. 
MS. MENNINGER:  Your Honor, I believe that was a
pleading that was filed under a pseudonym.  I can check it
certainly to be sure and confer with the government.  We'll
check it one more time, your Honor --
THE COURT:  Okay.
MS. MENNINGER:  -- and confer.
And then as for 8 and 9, we were going to put 8 and 9 
on the sticker, make copies to replace in the binder. 
THE COURT:  Okay.  So confer and let me know if J-15
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LC1Qmax6                 Jane - Redirect
needs to be admitted under seal.
MS. MOE:  Thank you, your Honor.  We'll review the
transcript from today and confer about exhibits and their
status under seal.
THE COURT:  And then, to be clear, the next witness
I'm permitting to testify under a pseudonym to protect the
identity of the prior witness.
MS. MOE:  Yes, your Honor.
THE COURT:  And so I guess consistent with that,
sketch artists should not draw an exact likeness of the next
witness who will also be testifying under a pseudonym.
MS. MOE:  Yes, your Honor.
THE COURT:  Now we can bring in the jury.
(Jury present) 
THE COURT:  Please take your seats as you come in.
Everyone may be seated.  Thank you, members of the jury.
Ms. Moe the government may call its next witness. 
MS. MOE:  Thank you, your Honor.  The government calls
a witness identified as Matt.
THE COURT:  The witness identified as Matt may come
forward.
 MATT, 
     called as a witness by the Government, 
     having been duly sworn, testified as follows:  
THE COURT:  Ms. Moe, you may begin your direct
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LC1Qmax6                 Matt - Direct
examination of the witness testifying under the pseudonym Matt.
MS. MOE:  Thank you your Honor is the Court's order
with respect to sketch artists now in effect?
THE COURT:  It is.
MS. MOE:  Thank you.
DIRECT EXAMINATION 
BY MS. MOE:  
Q.
Good afternoon.
A.
Good afternoon.
Q.
Are you testifying under the name Matt today?
A.
Yes.
Q.
Are you using a pseudonym in order to protect the privacy
of the person you are going to be testifying about today?
A.
Yes.
Q.
I'd like you to just take a look at the witness stand.
There's a folder in front of you.  Would you mind just taking a
look at that document.  And that is what's marked for
identification as Government Exhibit 17?
A.
Yes.
Q.
Without saying what's on the document, do you recognize
that?
A.
Yes, I do.
Q.
What is that?
A.
It's my driver's license.
Q.
Is that your true name?
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LC1Qmax6                 Matt - Direct
A.
Yes, it is.
MS. MOE:  Your Honor, the government offers Government
Exhibit 12 under seal.
MS. STERNHEIM:  No objection.
THE COURT:  Without objection, GX-12 is admitted under
seal to protect the identity of the witness who I permitted to
testify under a pseudonym.
MS. MOE:  Apologies, your Honor.  My colleagues just
alerted me it's Government Exhibit 17, not 12.  I misspoke.
THE COURT:  Or I did.  GX-17.  Thank you.
MS. MOE:  Thank you, your Honor.
(Government's Exhibit 17 received in evidence under 
seal) 
MS. MOE:  May the jurors now view that exhibit in
their binders?
THE COURT:  Without objection, Ms. Sternheim.
MS. STERNHEIM:  No objection, your Honor.
THE COURT:  Jurors may pick up your binders and look
at Exhibit GX-17, please.  Large binder, GX-17.  Thank you.
BY MS. MOE:  
Q.
Now that the jurors are there, just to be clear, on
Government Exhibit 17, is that your true name?
A.
Yes, that is.
Q.
Is that your driver's license?
A.
Yes, that is.
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LC1Qmax6                 Matt - Direct
Q.
For today's purposes --
THE COURT:  Ms. Moe, can you come closer to the mic?
Q.
For today's purposes, we'll be referring to you as Matt.
Is that okay?
A.
Yes, that's okay.
Q.
All right.  If the jurors could keep their binders for a
moment up, we'll turn to another exhibit in a moment.  Let me
pause here and just ask you, Matt, how far did you go in
school?
A.
High school.
Q.
What kind of work do you do now?
A.
I'm an actor.
Q.
Do you work on a television show?
A.
Yes, I do.
Q.
Are you employed full time as an actor in a television
show?
A.
Yes, I am.
Q.
For how many years have you been employed full time as an
actor?
A.
I'd say on and off for the last 15 years.
Q.
And if you could please take a look at the binder in front
of you, and take a look at Government Exhibit 12, which is in
evidence and under seal.  Do you have Government Exhibit 12 in
that folder?
A.
Yes, I do.
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LC1Qmax6                 Matt - Direct
Q.
I would ask that the jurors please turn to Government
Exhibits 12 in their binder, which is in evidence and under
seal.
THE COURT:  Without objection, Ms. Sternheim?
MS. STERNHEIM:  No objection.
THE COURT:  You may look at GX-12, please.
MS. MOE:  Thank you, your Honor.
Q.
Focusing on Government Exhibit 12, I want to direct your
attention to the top left corner of that document.  Without
saying her name, do you recognize the person listed on that
birth certificate?
A.
Yes, I do.
Q.
For today's purposes, we're going to refer to that person
as Jane.  Will you do that?
A.
Yes.
MS. MOE:  Thank you, your Honor.  I think that's all
we need for the binders today?
THE COURT:  Okay.  Put the binders away.
Q.
Now that we know who we're talking about, I want to ask you
some questions about Jane.  How do you know Jane?
A.
She's my ex-girlfriend.
Q.
Approximately what year did you first meet Jane?
A.
First time was 2002 and the second time was 2006.
(Continued on next page) 
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX7                 Matt - direct
BY MS. MOE:  
Q.
Did there come a time when you were in a romantic
relationship with Jane?
A.
Yes.
Q.
During approximately what years were you in a romantic
relationship with Jane?
A.
2006 till 2014, approximately.
Q.
During those years, did you live together?
A.
Yes.
Q.
What years did you live together?
A.
2007 till 2014.
Q.
Did you keep in touch with Jane after you broke up?
A.
Yes.
Q.
What's the nature of your current relationship with Jane?
A.
We're friends.
Q.
Have you had a professional relationship with Jane?
A.
Yes, I have.
Q.
What's the nature of your professional relationship with
Jane?
A.
Jane and I, we work on the same TV show.
Q.
During the years that you lived with Jane, did you get to
know some of her family members?
A.
Yes, I did.
Q.
Were there times when Jane would talk to you about what her
home life was like when she was growing up?
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LC1VMAX7                 Matt - direct
A.
Yes.
Q.
Let me just take a step back and ask you some questions
about how that topic came up.  In general, how would the topic
of Jane's home life come up during the course of your
relationship?
A.
There's different aspects of the home life, but just most
likely, I would say, getting to know her family and getting to
know the relationships between her and her siblings and her
mother and the struggles that she went through.
Q.
During the years that you were dating Jane, did she tell
you about what her home life was like when she was a kid?
A.
Yes, she did.
Q.
What did she tell you about that?
MS. STERNHEIM:  Objection.
THE COURT:  Do you want a more specific question?
MS. STERNHEIM:  Well, that is hearsay.  That is not
the basis of this witness's testimony.
MS. MOE:  Your Honor, it's both the foundation for a
prior consistent statement and a prior consistent statement
itself.
THE COURT:  In light of cross, I think that's right,
but I'll hear you if --
MS. STERNHEIM:  If I may be heard briefly.
THE COURT:  Yes.
(Continued on next page) 
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LC1VMAX7                 Matt - direct
(At sidebar)  
THE COURT:  We discussed this yesterday, didn't we?
MS. STERNHEIM:  Judge, the witness is going to talk
about home life.  It's not the subject matter of his testimony,
it's whether she revealed to him at a time earlier than meeting
with the government allegations concerning Ms. Maxwell.
THE COURT:  Well, but Ms. Menninger crossed on the
veracity of her poverty and financial situation growing up and
the relationship with her mother, and I assume that's where
we're going.
MS. STERNHEIM:  I think the government -- I don't
think that's the issue here.  The issue is whether she stated
at sometime earlier that she was abused.
THE COURT:  Well, that's true.  But you've put in
issue her credibility about everything.  Why did you cross her
on whether she grew up poor?
MS. STERNHEIM:  Because they raised it.  They raised
the fact that she lived in a pool house.  The witness testified
under oath that she lost her home after her father died.  I
don't think that's the issue --
THE COURT:  So you've attacked her credibility on
that.  You said her credibility on everything is an issue.  You
specifically attacked her credibility on that.  Why can't it
come in as a prior consistent -- you're saying this witness can
only testify about --
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX7                 Matt - direct
MS. STERNHEIM:  Judge, if that was the case, then
anytime a witness is on the stand who spoke about their home
life, you could bring a witness in?  I've never seen that
before.  I understand the subject matter with regard to the
allegations in this case.
THE COURT:  Right.  For sure.
MS. STERNHEIM:  But prior consistent, my father died,
I don't think that we're contesting that her father died.
THE COURT:  Right.  But you contested whether she grew
up poor, whether she had a relationship with her mother that
wouldn't allow her to -- you put all of those things at issue;
made a strong point that every inconsistency is an issue
because her credibility is central.  Good for the goose, good
for the gander.
MS. STERNHEIM:  No, that would mean they could pull
anyone she was involved with to support the fact that she had a
difficult --
THE COURT:  What is the nature of your objection?  So
that this witness -- I mean, either it's a prior consistent
statement or it's not.  I don't understand -- so under the Rule
801(b)(3), right, that's the evidentiary objection.  You
attacked her credibility on what she testified about her home
life.  What is the evidentiary objection?  Relevance?  403?
Tell me.
MS. STERNHEIM:  Judge, it seems like we're going to
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Matt - direct
have a witness here who's just going to testify about
everything he knew about her because he was in a relationship
with her and --
THE COURT:  No, I won't allow everything that he knew
about her.  I will allow issues that you specifically spent
time on cross-examination.
MS. STERNHEIM:  Okay.
THE COURT:  Attacking her credibility.
(Continued on next page) 
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX7                 Matt - direct
(In open court) 
THE COURT:  Ms. Moe, I'll ask you to rephrase, to
narrow the question.
MS. MOE:  Yes, your Honor.
BY MS. MOE:  
Q.
Matt, were there times when Jane would talk to you about
her family's financial circumstances when she was growing up?
A.
Yes.
Q.
What did she tell you about that?
A.
She told me that when her father got sick, that her mother
spent basically all of the money that they had for his
treatments, and obviously hoping that he would survive.  And he
didn't.  And basically she -- that she was the one who left
them broke.
Q.
And did Jane tell you what her family's financial
circumstances were like after her father passed away?
A.
Yes.
Q.
What did she tell you about that?
A.
That they basically had no money.  The mother was working a
small job.  And I think she said at one point the three of
the -- that her and her two brothers were sleeping in the same
bed at one point because they were living in such a small
place, and the three of them had to sleep in the same bed.
Q.
Did there come a time when Jane told you how she was able
to pay for things when she was a kid?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX7                 Matt - direct
A.
Yes, she did.
Q.
Approximately what year was it when this conversation came
up?
A.
It's probably 2006, 2007, when we -- when we first started
dating, just getting to know each other.
Q.
What did Jane tell you during that conversation about how
she was able to pay for things when she was a kid?
A.
She said her mom had a job that paid basically nothing; and
that she had it -- it was like a godfather, an uncle, a family
friend type person that basically helped her mom pay the bills.
Q.
Is this something Jane discussed with you once or more than
once during the course of your relationship?
A.
More than once.
Q.
During the conversations with Jane about this godfather
figure, did you come to learn the name of the uncle figure or
godfather figure?
A.
Yes, I did.
Q.
What did she tell you his name was?
A.
His name is Jeffrey Epstein.
Q.
In general, when Jane would talk with you about her
experiences with Jeffrey Epstein, how would that topic come up?
A.
First it was purely that he was -- you know, that he was a
godfather and, you know, he was looking out for her family.
And then the topic came up when she came to me when -- 
I think it was in two thousand -- like 2009, she was contacted, 
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX7                 Matt - direct
I think, by the FBI to see if she would tell her story, if she 
had a story.   
And she came to me and she said, I need to tell you 
something.   
And I said, Yeah.   
And she said, You know the godfather that I told you 
about, the person that was helping my family?   
And I said, Yes, I do.   
And she said, I need you to know that this is who it 
is.   
And it was public news.   
And that's when I said, That guy is your godfather?  
That's the guy that was helping you pay your bills and your 
family's bills?   
And she said, Yes. 
Q.
Did Jane tell you when she met Jeffrey Epstein?
A.
Yes.
Q.
What did Jane tell you about when she met Jeffrey Epstein?
A.
She told me she met him shortly after --
THE COURT:  Just a minute.  Just a minute.
THE WITNESS:  Sorry.
THE COURT:  More specific question.
MS. MOE:  Your Honor, I can lay some additional
foundation for that and return to it later, if that's
acceptable.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Matt - direct
THE COURT:  Okay.  And then you'll ask it as a more
specific question.
MS. MOE:  Yes, your Honor.
THE COURT:  Thank you.
BY MS. MOE:  
Q.
Did there ever come a time when Jane explained to you why
it was that she received financial help from Jeffrey Epstein?
A.
Yes, she did.
Q.
Approximately when did she tell you about that?
A.
When -- when the -- when she told me who it was, when she
told me the name of the person and --
Q.
What did Jane tell you about why it was that she received
this money from Jeffrey Epstein?
A.
Well, once -- once I learned who it was, I asked her if she
was one of the girls, and she said that she was.
MS. STERNHEIM:  Objection.
THE COURT:  I'll sustain the objection.
The jury will disregard the last statement of the 
witness.  And you'll ask a specific question, Ms. Moe. 
BY MS. MOE:  
Q.
Did Jane tell you what happened between her and Jeffrey
Epstein during the years that she knew him?
A.
Not specifically.
Q.
Did there come a time when she told you why it was that
Jeffrey Epstein gave her money?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX7                 Matt - direct
A.
Yes.
Q.
What did she tell you about that?
A.
Well, I was the one that asked her, based on after finding
out who it was, I asked her if she was doing that for the
money.
Q.
What did she tell you she was doing for the money?
A.
She said it wasn't --
THE COURT:  Just a minute.  Just a minute.
Sustained. 
Q.
In your conversations with Jane about Jeffrey Epstein, did
there come a time when she told you that she had to do things
she didn't want to do?
A.
Yes.
Q.
What did she tell you about that?
A.
She never went into detail; she just said it wasn't free.
Q.
Did she ever use any particular words to describe the
things that she had to do with Jeffrey Epstein?
A.
Nothing specific.  No specific words.
Q.
In your conversations with her, did she ever use the word
"massage"?
MS. STERNHEIM:  Objection.  Leading.
THE COURT:  Overruled.
I'll allow it.  You may answer. 
A.
Yes.
Q.
What did she tell you about that?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX7                 Matt - direct
A.
I think it was only because of the fact that it was public
knowledge, and that was as far as she would ever let me go into
the -- into the -- what happened, what she did.
Q.
Okay.  But focusing on her statements to you, what did she
tell you about massage?
A.
Just that was it, that -- basically, that was it.
Q.
Did Jane ever tell you how old she was when she had to do
things with Jeffrey Epstein?
MS. STERNHEIM:  Objection.
A.
Yes.
THE COURT:  Overruled.
Q.
And what did Jane tell you about how old she was when she
had to do things with Jeffrey Epstein?
A.
She said that it started at 14, when she met him.
Q.
Did she tell you where she met him?
A.
Yes.
Q.
What did she tell you about that?
A.
She said it was a camp.
Q.
In these conversations with Jane, did she ever tell you
that someone else was present during a massage?
A.
No.
Q.
In your conversations with Jane, did you ever have any
conversations with her about a woman?
A.
Yes.
Q.
In your conversations with Jane about Jeffrey Epstein, did
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX7                 Matt - direct
she tell you that there was a woman present at his house?
A.
Yes.
Q.
Did she tell you that the woman in the house made her feel
comfortable?
A.
Yes.
Q.
Why did you ask her about the woman in the house?
A.
I asked her because I couldn't understand why her mother
would let her go with a man without anybody else present.  And
then she told me sometimes there were other girls present.
MS. STERNHEIM:  Objection.
THE COURT:  Sustained.
The jury will disregard the witness's last statement.   
Ms. Moe, you'll lead. 
MS. MOE:  Yes, your Honor.
Q.
In your conversations with Jane -- withdrawn.
Approximately what year was it that Jane told you
about this woman who made her feel comfortable?
A.
It was when I found out about Jeffrey, approximately 2009.
Q.
And in your conversations with Jane about her interactions
with Jeffrey Epstein, did she tell you that this woman would
tell her that it was okay?
A.
Not specifically that.  She didn't use those words.
Q.
Okay.  What words did she use?
A.
She just said that having a woman there made her feel --
made her feel more comfortable.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Matt - direct
Q.
At the time when you were having these conversations with
Jane about this woman, did she tell you what the woman's name
was?
A.
No, she didn't.
Q.
In general, when Jane would tell you about what had
happened with her and Jeffrey Epstein, what was her demeanor
like?
MS. STERNHEIM:  Objection.
THE COURT:  Grounds.
MS. STERNHEIM:  Relevance.
MS. MOE:  Your Honor, it's --
THE COURT:  Overruled.
Go ahead.  You may answer. 
A.
What was the question again?
Q.
I'm happy to repeat it.
Matt, when you would have these conversations with 
Jane about her interactions with Jeffrey Epstein, what was her 
demeanor like when she would tell you about that? 
A.
Ashamed, embarrassed, horrified.
Q.
Without telling me what she said, did you ask her about the
details about what had happened with her and Jeffrey Epstein?
A.
Yes, I did.
Q.
In those interactions, did she provide you with details
about those interactions?
A.
No, she didn't.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Matt - direct
Q.
What was her reaction when you asked her for details about
those interactions?
A.
She would just say to me, Matt, the money wasn't fucking
free.
Q.
Did she go beyond that?
A.
No, she didn't.
Q.
I believe you testified that you met Jane's family members
when you were dating; is that right?
A.
Yes.
Q.
Based on your observations during the years that you dated
Jane, what was her relationship like with her mother?
A.
It was rough.  It was brutal.
Q.
Did there ever come a time when you saw Jane confront her
mother about Jeffrey Epstein?
A.
Yes, I did.
Q.
Approximately when was that?
A.
I think it was approximately 2011.
Q.
Where were you when that happened?
A.
I was at a house.
Q.
Who was in the room when you had that conversation?
A.
It was just --
MS. STERNHEIM:  Objection.
Sidebar please. 
THE COURT:  One word, grounds.
MS. STERNHEIM:  First time we are hearing this.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Matt - direct
THE COURT:  Okay.
(At sidebar) 
THE COURT:  What do you expect the witness to say?
MS. MOE:  That he recalls being present when Jane and
her mother were in a room.  He recalls Jane saying to her
mother, How could you not know the money wasn't for free?  How
could you not know?
THE COURT:  Is that in 3500 material?
MS. MOE:  Yes, I'm happy to pull it up.
MS. STERNHEIM:  There's been no testimony by Jane
about confrontation with her mother at this time.  She
testified that her mother was irate regarding a guidance
counsellor, but she didn't go toe-to-toe with her mother about
Jeffrey Epstein.
THE COURT:  So it's in the 3500 material; it's not the
first time you're hearing it.
MS. STERNHEIM:  I don't recall if it's this witness or
her brother.
THE COURT:  Okay.
MS. STERNHEIM:  But even if it is in the 3500
material, if it is not on the direct of Jane, why can it be
offered as a prior consistent statement when it never was
offered at all?
MS. MOE:  This is a statement from Jane to her mother
essentially acknowledging she was abused, expressing
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX7                 Matt - direct
frustration about that.  That is entirely consistent with her
testimony that she was, in fact, abused.
MS. STERNHEIM:  But not with regard to her mother
having a confrontation.
THE COURT:  Well, it's a prior consistent statement
that he heard related to the abuse which you've repeatedly
called into question in your opening and your direct and in
your cross-examination.
MS. STERNHEIM:  Judge, I understand that.  But we're
talking about prior consistent statements.
THE COURT:  Right.  The prior consistent statement is
that she was abused by Jeffrey Epstein.
MS. STERNHEIM:  But they are bringing out a
conversation.  If she wants to say, Did you know or learn that
she was abused?  Yes.  But a conversation that she had with her
mother is hearsay.
MS. MOE:  Your Honor, it's not hearsay because it's a
prior consistent statement of Jane about her experiencing
sexual abuse.
THE COURT:  Yes.  Overruled.
(Continued on next page) 
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650
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Matt - direct
(In open court)  
THE COURT:  Go ahead.
BY MS. MOE:  
Q.
Did there ever come a time when you saw Jane confront her
mother about Jeffrey Epstein?
A.
Yes.
Q.
Approximately when was that conversation?
A.
2011.
Q.
Who was present for that conversation?
A.
It was just me, her, and her mom.
Q.
What do you remember Jane saying to her mother during that
conversation?
A.
She told her mother that the money was not free, and
confronted her mother about it.  And her mother said, crying --
THE COURT:  Just a minute.
Q.
Just focusing on just what Jane said and not what her
mother said, can you explain to the jury what did Jane say to
her mother?
A.
How do you think I got the money, mom?
Q.
Did she ask her mother whether her mother knew?
A.
She told her mother that she knew.  She accused her of it.
Q.
What do you remember about the exact words that she used?
A.
That Jane used, right?
Q.
Yes.  Can you just explain for the jury, what did Jane say
to her mother?
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX7                 Matt - direct
A.
Jane told her mother that -- that she -- that the money was
not free, and that there's no way that she couldn't have known
that it wasn't free.
Q.
Did there come a time when you learned that a woman named
Ghislaine Maxwell was arrested?
A.
Yes.
Q.
Was that in 2020?
A.
Yes.
Q.
Without getting into details, how did you learn that
Ghislaine Maxwell was arrested?
A.
I saw it on the news.
Q.
When you learned that Maxwell had been arrested, did you
contact Jane?
A.
Yes.
Q.
What did you ask her?
A.
I just said, Is this the woman that you were referring to
when you told me?  And she said yes.
Q.
Just to be clear, during your relationship with Jane, did
she tell you that there was a woman at Jeffrey Epstein's house
who made her feel comfortable?
A.
Yes.
MS. STERNHEIM:  Asked and answered.
THE COURT:  Sustained.
MS. MOE:  Just a moment, your Honor.
THE COURT:  Okay.
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX7                 Matt - direct
(Counsel conferred) 
MS. MOE:  Nothing further, your Honor.
THE COURT:  All right.  Thank you.
Ms. Sternheim. 
MS. STERNHEIM:  No, thank you.
THE COURT:  All right.
No cross.   
Witness Matt, you may step down.   
You are excused. 
(Witness excused) 
THE COURT:  Government may call its next witness.
MR. ROHRBACH:  The government calls Daniel Besselsen.
THE COURT:  You may come forward.
Mr. Besselsen, come forward.   
Somebody is getting him, Mr. Rohrbach? 
MR. ROHRBACH:  Yes, your Honor.
We apologize for the delay.   
THE COURT:  You can take a standing stretching break,
if you'd like.
You may be seated.
 DANIEL ALAN BESSELSEN, 
     called as a witness by the Government, 
     having been duly sworn, testified as follows: 
THE COURT:  Go ahead.
MR. ROHRBACH:  Thank you, your Honor.
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653
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
DIRECT EXAMINATION 
BY MR. ROHRBACH:  
Q.
Good afternoon, Mr. Besselsen.
A.
Good afternoon.
Q.
Mr. Besselsen, where do you work?
A.
I work at Interlochen Center for the Arts.
Q.
What is Interlochen Center for the Arts?
A.
Interlochen is a nonprofit organization focused on arts
education.  We have our two largest programs, a arts camp in
the summer, and a boarding high school during September through
May.  And we're focused on arts education, as I mentioned.  So
we have visual arts, music, creative writing, dance, theater,
creative writing types of programming.
Q.
Where is Interlochen located?
A.
We're located in Interlochen, Michigan.
Q.
Where is Interlochen, Michigan?
A.
It's northern Michigan; it's about 20 minutes southwest of
Traverse City, Michigan, which is the largest town in northern
Michigan.
Q.
How long have you worked there?
A.
I've worked there 16 years.
Q.
What's your title?
A.
My title is assistant vice president of finance.
Q.
And what are your responsibilities as an assistant vice
president of finance?
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LC1VMAX7                 Besselsen - direct
A.
I oversee the finance department, including accounts
payable, accounts receivable, our purchasing, payroll.  I'm
involved in overseeing director of campus safety and security,
as well as the director of dining services.  And I'm involved
with the auditors, the banks, the investment companies, as well
as external audits.
Q.
And in that capacity, are you familiar with the normal
business practices of Interlochen?
A.
Yes.
Q.
In particular, are you familiar with the business practices
regarding communications with donors?
A.
Yes.
Q.
Does Interlochen maintain records of its communications
with donors?
A.
Yes.
Q.
What sorts of records?
A.
For our major donors or prospects, we keep all
correspondence with donors, whether it might be a letter, email
correspondence, records of phone conversations, notes from
visits with donors, things like that.
Q.
Let's talk about letters in particular.  How are letters
that are written to donors created?
A.
The letters are created by an individual in our advancement
department who's charged with managing that particular donor
relationship.  And so they would be the ones that would write a
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          SOUTHERN DISTRICT REPORTERS, P.C.
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LC1VMAX7                 Besselsen - direct
letter to a donor or to a foundation.
Q.
Is there any relationship between the level of donation
given and the person writing the letter to the donor?
A.
Yes.  Yup.  For example, our vice president of advancement
or even our president would handle a higher-end donor that
might be capable of donating half a million dollars or more,
for example.  And we would have major gift officers that would
be below that vice president of advancement that would handle
folks with capacity to give $100,000, $200,000, something like
that.
Q.
When these letters are written to donors, does Interlochen
put them in any sort of file?
A.
Yes, yup.  We keep track of all correspondence with donors.
Nowadays, it's all electronic within Salesforce, which is the
software we use to track fundraising and donations.
Historically, we have hard copy letters, for example.  Prior to
using Salesforce, we've got manila folders or files that we
kept for each donor that includes all of the correspondence
over time with that donor.
Q.
How long are those records kept?
A.
They are kept forever.
Q.
And are they kept by Interlochen in the ordinary course of
business?
A.
Yes.
MR. ROHRBACH:  Ms. Drescher, would you please display
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
for the witness, Court, and counsel what's been marked for
identification as Government Exhibit 741.
Q.
Do you recognize this, Mr. Besselsen?
A.
Yes.
Q.
What is it?
A.
This is a letter from Interlochen's vice president of
advancement to Mr. Epstein providing some information to him on
the concept of building a scholarship lodge on Interlochen's
campus and the level of donation that would be required to
build a lodge.
Q.
Mr. Besselsen, will you pick up the binder next to you.  It
has another copy of Government Exhibit 741.
Have you reviewed this exhibit before today?
A.
Yes.
Q.
And what is this exhibit?
A.
This exhibit are all of the letters or a portion of the
letters that were included in Mr. Epstein's file that we've
stored away in the filing cabinet in the basement of the
McWhorter dorm locked away.
Q.
How do you know these letters come from the Epstein file at
Interlochen?
A.
I myself went in and pulled it recently and saw these.
Q.
Thank you.
MR. ROHRBACH:  The government offers Government
Exhibit 741.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
THE COURT:  741 is how many pages?
MR. ROHRBACH:  It is -- I believe it's eight pages,
your Honor.
THE COURT:  Okay.
MR. ROHRBACH:  Yes, it's eight pages.
MS. STERNHEIM:  May I confer with the government for a
moment?
THE COURT:  You may.
(Counsel conferred) 
MS. STERNHEIM:  Thank you, Judge.
THE COURT:  So it's eight pages.
MR. ROHRBACH:  Yes, your Honor.
THE COURT:  All right.  Without objection, GX-741 is
admitted.
(Government's Exhibit 741 received in evidence) 
BY MR. ROHRBACH:  
Q.
Mr. Besselsen, are you familiar with Interlochen's business
practices regarding student records?
A.
Yes.
Q.
Does Interlochen keep a file on each student?
A.
Yes.
Q.
And how is that file maintained?
A.
The file is maintained in a locked room in the lower level
of the Maddy Administration Building.  Once again, it's manila
files or folders for each student, and includes information
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
from the student, on a student.
Q.
And what sort of information is contained in student
records, in student files?
A.
So the files include comments from faculty that were
involved with that student's time on a camp -- academy
programming or camp programming, as well as cabin life,
comments from the counsellors during the camp programming, as
well as applications, paper applications, if you go back in
time, if we're talking about a camper or academy student.
Q.
And are those records regularly put into the student file?
A.
Yes.
Q.
And does Interlochen regularly maintain those records?
A.
Yes.
Q.
How long are student records kept?
A.
Records are kept for 99 years per Interlochen's record
retention policy.
Q.
In your binder, would you turn to what's been marked for
identification as Government Exhibit 743.  
Without saying any names, do you recognize this? 
A.
Yes.
Q.
What is it?
A.
This is an application for admission to our summer camp in
1994.
Q.
Did you review this prior to today?
A.
I did.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
Q.
And turning to page 3 of that exhibit, is that photo part
of the application?
A.
Yes.
Q.
How do you know?
A.
Once again, this is something that I went in and tracked
down and pulled this particular camper's file myself.  And this
was -- and these documents were in it, and this was attached to
this particular application.
MR. ROHRBACH:  The government offers Government
Exhibit 743 under seal.
MS. STERNHEIM:  No objection.
THE COURT:  GX-743 is admitted under seal, consistent
with my ruling allowing the individual listed to testify under
a pseudonym.
(Government's Exhibit 743 received in evidence) 
Q.
Mr. Besselsen, does Interlochen keep records that a student
completes a program?
A.
Yes.
Q.
Who makes those records?
A.
Those records would be made or input by our admissions
office.
Q.
And how are those records maintained?
A.
When a student is accepted and enrolls in a program, that
is when those records are created in our software.
Q.
And to be clear, are those records kept in the ordinary
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
course of business?
A.
Yes.
Q.
In your binder, would you turn to what's been marked for
identification as Government Exhibit 744.
Do you recognize this? 
A.
Yes.
Q.
Without saying any names, what is it?
A.
This is a report out of Salesforce, which is our software
that we use not only for fundraising, but also for student
records, that I generated.  And it's a report on education
records, specifically pulling the completion year, first name,
last name, and education type, with a filter on the last name.
Q.
And just so the record is clear, you personally generated
this spreadsheet?
A.
I did, yes.
MR. ROHRBACH:  The government offers Government
Exhibit 744 under seal.
MS. STERNHEIM:  No objection.
THE COURT:  GX-744 is admitted under seal consistent
with my ruling allowing the individual listed to testify under
a pseudonym.
(Government's Exhibit 744 received in evidence) 
Q.
Mr. Besselsen, I'd like to walk briefly through some of the
exhibits we were just looking at.  
MR. ROHRBACH:  Ms. Drescher, would you please publish
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661
          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
Government Exhibit 741 for the Court, counsel, the witness, and
the jury.
Q.
Mr. Besselsen, what is this document?
A.
This is a letter from Interlochen's vice president of
advancement to Mr. Epstein providing him with additional
information on the scholarship lodge, building a scholarship
lodge on Interlochen's campus, and what it would take to -- in
regards to donating for that project.
Q.
You mentioned a scholarship lodge.  What is a scholarship
lodge?
A.
A scholarship lodge is a rental lodge, a small home on our
campus where parents of campers or academy students can come
stay on campus, be close to the performance venues and things
like that.  So parents or guests of Interlochen or even the
general public who come stay in this rental lodge and pay a --
like a fee, like a hotel room to stay in.
MR. ROHRBACH:  Ms. Drescher, would you turn to page 2
of this document.
Q.
What is this document?  What are we looking at,
Mr. Besselsen?
A.
This is a letter, again, from Interlochen's vice president
of advancement to Mr. Epstein thanking him for his donation of
$200,000 for a new scholarship lodge on our campus, and the
different updates provided in the letter about construction
timelines and things like that.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
Q.
Mr. Besselsen, what is the date of this letter?
A.
February 9, 1994.
MR. ROHRBACH:  And turning now to the next page,
Ms. Drescher.
Q.
Who is this letter from, Mr. Besselsen?
A.
The letter is from Tim Ambrose, vice president of
advancement.
MR. ROHRBACH:  Ms. Drescher, turn to page 5 of this
document.
Q.
Mr. Besselsen, what is this document?
A.
This is a letter from Interlochen's vice president of
advancement to Ms. Maxwell enclosing an envelope that was found
when Interlochen's custodial staff was cleaning the Epstein
scholarship lodge, returning the lost envelope to Ms. Maxwell,
as well as the next page of this provides a listing of items.
Q.
Mr. Besselsen, we'll get to the next page in a moment, but
would you read this letter for us?
A.
Yes.
Dear Ghislaine, enclosed is the envelope we recently 
found in cleaning the Epstein Lodge.  Apparently it lodged 
between the wall and the dresser.  It was not discovered until 
the unit was moved for cleaning. 
As we discussed, the final week of camp is August 14
through the 20th.  I've reserved the lodge for Jeffrey's use.
In addition, he has one more week that he can reserve for
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
himself or guests.  He may wish to have use it.
Attached is a list of the dry goods that are in 
storage as part of Jeffrey's personal inventory.  Please advise 
if we are missing any items you are aware of being sent here.  
Please convey to Jeffrey how pleased we are to have such a 
facility on our campus.  In fact, the president-elect will be 
staying in the lodge until his family's furniture arrives.  It 
is a remarkable place.  We are grateful.   
Best wishes for a wonderful holiday season. 
Q.
Thank you, Mr. Besselsen.
MR. ROHRBACH:  Ms. Drescher, will you turn to the next
page.
Q.
A moment ago you mentioned an attached list.  Is this the
attached list?
A.
Yes.
Q.
And what sorts of items are on this list, Mr. Besselsen?
A.
Different types of linens, pillows, blankets, towels,
sheets, shams.
Q.
Mr. Besselsen, while you've been at Interlochen have you
been familiar with the Epstein Scholarship Lodge?
A.
Yes.
Q.
Does it have any other names?
A.
Yes, it does.
Q.
What are the names?
A.
The name is Green Lake Lodge.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
Q.
And what is this lodge, the Green Lake Lodge?
A.
It's a two-bedroom home, formerly known as the Jeffrey
Epstein Scholarship Lodge.
MR. ROHRBACH:  Ms. Drescher, would you display for the
witness, the Court, and counsel what's been marked for
identification as Government Exhibit 745.
Q.
Mr. Besselsen, what is this?
A.
This is the Green Lake Lodge, formerly known as the Jeffrey
E. Epstein Scholarship Lodge.
Q.
Is this a fair and accurate photo of the lodge?
A.
Yes.
MR. ROHRBACH:  The government offers 745.
MS. STERNHEIM:  No objection.
THE COURT:  GX-745 is admitted.
(Government's Exhibit 745 received in evidence) 
MR. ROHRBACH:  Ms. Drescher, will you publish this,
with the Court's permission.
THE COURT:  You may.
MR. ROHRBACH:  Ms. Drescher, you can take it down.
I'd now like to turn to Government Exhibit 744, which 
I believe is in the heavier of the juror binders.  So if I 
could ask the Court to permit the jury to take out the binder? 
THE COURT:  It's already admitted?
MR. ROHRBACH:  Yes, your Honor.
THE COURT:  All right.  Without objection,
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
Ms. Sternheim?
MS. STERNHEIM:  No objection.
THE COURT:  And you said 744?
MR. ROHRBACH:  744.
THE COURT:  You may look at in the large binder,
GX-744, please.
BY MR. ROHRBACH:  
Q.
Mr. Besselsen, you testified earlier that you generated
this record from Interlochen's database?
A.
Yes.
Q.
How did you do that?
A.
I logged into Salesforce and went to the reports section in
Salesforce and modified the filters.  This is a report that --
the title of the report is MJS Report.  Went to that report and
created these filters that you see at the top, the last name.
Q.
Just to be clear, without saying the last name, is that the
filter you ran to generate this report?
A.
Yes.
Q.
Thank you, Mr. Besselsen.
What does this report show about people with this last 
name's attendance at Interlochen? 
A.
It shows which -- which years that they came to either the
arts camp, which is the education type, the far right column.
And that would be the summer then, if it relates to arts camp.
So the summer of '94, '95, and '96.  And then the arts academy
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
would be -- the completion would be the May of that year, so
May of 1999 and May of 2000.
MR. ROHRBACH:  With the Court's permission, I'd like
to turn the jury's attention to Government Exhibit 743, which
is also in evidence.
THE COURT:  Ms. Sternheim?
MS. STERNHEIM:  No objection.
THE COURT:  The jury may turn to 743 in the same
binder.
Q.
So, Mr. Besselsen, again, without saying any names or other
information, I would just ask you to take note of the address
in the third section on the first page.  Do you see this
address?
A.
Yup.
Q.
All right.
MR. ROHRBACH:  Then with the Court's permission, I'd
ask the jury to turn to Defense Exhibit J-4 in the defense
binder which is in evidence.  
And Mr. Besselsen, that is in the binder next to you. 
THE COURT:  Ms. Sternheim, without objection?
MS. STERNHEIM:  No objection to whatever is admitted.
THE COURT:  All right.  And that's -- the jury is
looking at J-4; correct?
MR. ROHRBACH:  Yes, your Honor.
THE COURT:  In the smaller binder.  J-4 in the smaller
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - direct
binder.
BY MR. ROHRBACH:  
Q.
Mr. Besselsen, do you note the address on page 1 of that
document?
A.
Yes.
Q.
Is it the same address as the address on the prior
document?
A.
Yes, it is.
Q.
And just to be clear, what is the document we're looking at
right now?
A.
This is an application for admission to our summer arts
camp, which would be the summer of 1995.
Q.
And the document we just looked at, Government Exhibit 743,
what is that document?  Again, without saying any names.
A.
That's an application for admission to our arts camp,
summer of 1994, previous summer.
Q.
And then, Mr. Besselsen, and with the Court's permission,
the jury, I would ask you to turn to Defense Exhibit J-5, which
is also in evidence.
THE COURT:  Ms. Sternheim.
MS. STERNHEIM:  No objection.
THE COURT:  You may turn to J-5 in the same small
binder, please.
Q.
Mr. Besselsen, do you recognize this document?
A.
Yes.
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          SOUTHERN DISTRICT REPORTERS, P.C.
           (212) 805-0300
LC1VMAX7                 Besselsen - cross
Q.
What is it, without saying any names?
A.
This is an application for admission to our arts camp in
the summer of 1996.
Q.
Do you see the -- without saying any identifying
information, do you see the address in the third section of
this document?
A.
I do.
Q.
Is that the same address or a different address than the
other address that you're looking at?
A.
I believe it's a different address.
Q.
Just to be clear, you think it's a different address?
A.
Yes, it's a different address.
Q.
Thank you.
MR. ROHRBACH:  No further questions, your Honor.
THE COURT:  Okay.  Thank you.
Ms. Sternheim? 
MS. STERNHEIM:  May I have a moment please?
THE COURT:  You may.
(Counsel conferred) 
MS. STERNHEIM:  Thank you, Judge.
THE COURT:  Do you anticipate more than five minutes?
MS. STERNHEIM:  Maybe less.
THE COURT:  Go ahead.
CROSS-EXAMINATION 
BY MS. STERNHEIM:  
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LC1VMAX7                 Besselsen - cross
Q.
Mr. Besselsen, just a few questions for you.
A.
Yes.
Q.
With regard to the --
THE COURT:  Take off your mask.
MS. STERNHEIM:  Thank you.
Q.
With regard to the applications that have been put in
evidence, did you produce to the government who paid for that
student?
A.
I did not provide that to the government; so no, I'm not
aware that we did provide that.
Q.
Because you do not have those records; correct?
A.
I believe that's correct, going back that far.
Q.
And you don't have records for the siblings of that
individual either; correct?
A.
I believe so.
Q.
And that would be for the years of attendance of those
three siblings, 1994, 1995, and 1996; correct?
A.
Correct.
Q.
Now, with regard to Mr. Epstein's invitation to come to the
lodge, it was for the end of August; correct?
A.
I believe the letter mentioned from Interlochen's vice
president of advancement that we were having the final concert
for our arts camp, I think it was August 7 or the week of
August 7, I believe.
Q.
And is it fair to say that in Interlochen, which some
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LC1VMAX7                 Besselsen - cross
people call band camp, that the end is like the equivalent of
color war for athletic camps?
A.
I'm sorry, I don't have any experience with color war.
Q.
Okay.
A.
I don't know what that term means.
Q.
It's when the performances are; it's the culmination of the
summer experience.  Correct?
A.
That's true, yeah.
Q.
And it is then that performances are going on as opposed to
classes going on; correct?
A.
The final day there are performances.  I'm not sure if the
entire week is like that or not, but --
Q.
But nonetheless, the donors, especially the major donors,
come for the performances; correct?
A.
Yes.  Some major donors do come to campus for performances.
Q.
And Mr. Epstein certainly was a major donor; correct?
A.
Correct.
Q.
And the invitation for him to have the lodge was for the
period of time which is the culmination of the summer program;
correct?
A.
That would be correct, I would imagine, yes.
MS. STERNHEIM:  May I have one moment, Judge?
THE COURT:  Okay.
(Counsel conferred) 
MS. STERNHEIM:  You're finished.  Thank you.
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THE WITNESS:  Oh, thank you.
THE COURT:  All right.  Mr. Rohrbach?
MR. ROHRBACH:  No redirect.  Thank you.
THE COURT:  All right.
Mr. Besselsen, you may step down.  You are excused. 
(Witness excused) 
THE COURT:  And that gets us at 5:02, jury.  I
apologize for keeping you a little bit late.
I will remind you of all of my instructions, of 
course.  Please keep them in mind.  Same schedule for tomorrow.  
Thank you for your continued attention and diligence.  Have a 
great night.  See you tomorrow morning. 
(Jury not present) 
THE COURT:  You may be seated.
Matters to take up, Mr. Rohrbach?
MR. ROHRBACH:  Nothing from the government, your
Honor.
THE COURT:  Ms. Sternheim?
MS. COMEY:  I apologize, your Honor.  We do have an
issue.  We will need to take it up at sidebar because it
relates to a pseudonym issue.
THE COURT:  Okay.  Sidebar pseudonym issue.
MS. COMEY:  It will be brief, your Honor.
(Pages 672 SEALED) 
(Continued on next page) 
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(At sidebar - not sealed) 
THE COURT:  Okay.  See you 8:45.  
The only thing I wanted to -- this isn't sealed.  But 
timing, if you're going to brief piercing the privilege. 
MR. PAGLIUCA:  When would you like it, your Honor?
THE COURT:  A month ago.
MS. STERNHEIM:  We can turn back the hands of time.
THE COURT:  I wish we could.
MS. STERNHEIM:  I don't think you would.
We might, but not you. 
MR. PAGLIUCA:  I think it's a little more complicated
than -- I think there are different issues related to different
potential witnesses, I guess is the issue.
I'm happy to have it briefed as best we can under the 
facts that we know right now, assuming that the Court wants 
briefed is the issue we discussed today.  Okay.  Because then 
we may have issues related to lawyer witnesses that are under 
subpoena, but will not be called under any circumstances unless 
it's briefed and the Court gives permission for the calling of 
those witnesses. 
THE COURT:  Let's start with the limited issue that
was raised today, which is that you would call -- you're
seeking to call Glassman.
MR. PAGLIUCA:  Glassman.
THE COURT:  You're seeking to call Glassman on the
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narrow question of whether under theory of waiver he told Jane
that it would -- testifying would help her in her case.
When would you like to do that? 
MR. PAGLIUCA:  How about Friday, your Honor?
THE COURT:  This would be a witness you would call in
your case-in-chief?
MR. PAGLIUCA:  Exactly.  So it's at least a week from
now, I would imagine.  I'm assuming the government has about a
week more of testimony, by my review of the witness list.
MS. COMEY:  Your Honor, I think that's right.  We're
unlikely to rest in less than a week from now.
THE COURT:  So is Friday okay?
MR. ROHRBACH:  We can respond on Monday, if that's all
right.
THE COURT:  Sure.  Great.
It will provide some general background on piercing 
privilege and waiver to the extent that will inform issues 
beyond the specific. 
MR. PAGLIUCA:  To the extent we can preview the
additional issues, we'll get that underway as well so that you
have a sense of what may or may not be coming down the road
here.
THE COURT:  Okay.  Can I ask, thinking about timing,
now that we're where we are, what is your estimate for the
trial?
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MS. COMEY:  Your Honor, I think it depends on the
length of cross-examination for some of the more substantial
witnesses.  If we can expect about the same length as we have
with Jane today, I expect we'll be able to rest the third week
of trial.  So not next week, but the week after, early that
week is my best estimate.
THE COURT:  And what's the defense's best estimate?
MS. STERNHEIM:  We'll let you know.
MR. PAGLIUCA:  I'm going to suspect the length of
cross-examination will be less for the remaining witnesses.
THE COURT:  We worked out some --
MR. PAGLIUCA:  Kinks, yes.
But I just think substantively it's likely to be less, 
and there's likely -- well, with the exception of one, there's 
less 3500 impeachment material that needs to be gone through 
potentially, so I think that will shorten the length of 
cross-examination.  And we will have whatever we need to have 
ready to go, understanding the format we're doing this in now. 
THE COURT:  All right.  See you in the morning.
(Adjourned to December 2, 2021 at 8:45 a.m.) 
 
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INDEX OF EXAMINATION 
Examination of:                               Page 
 JANE 
429
Cross By Ms. Menninger . . . . . . . . . . . . 
600
Redirect By Ms. Moe  . . . . . . . . . . . . . 
 MATT 
630
Direct By Ms. Moe  . . . . . . . . . . . . . . 
 DANIEL ALAN BESSELSEN 
653
Direct By Mr. Rohrbach . . . . . . . . . . . . 
668
Cross By Ms. Sternheim . . . . . . . . . . . . 
DEFENDANT EXHIBITS 
Exhibit No.                                    Received 
 J-4 
436
  . . . . . . . . . . . . . . . . . . . . 
 J-5 
440
  . . . . . . . . . . . . . . . . . . . . 
 J-15 
599
   . . . . . . . . . . . . . . . . . . . 
600
 J-8 and J-9   . . . . . . . . . . . . . . . . 
GOVERNMENT EXHIBITS 
Exhibit No.                                    Received 
 17 
631
   . . . . . . . . . . . . . . . . . . . . 
 741 
657
  . . . . . . . . . . . . . . . . . . . . 
 743 
659
  . . . . . . . . . . . . . . . . . . . . 
 744 
660
  . . . . . . . . . . . . . . . . . . . . 
 745 
664
  . . . . . . . . . . . . . . . . . . . . 
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