Cimberly Espinosa — Evidence Rulings and Direct/Cross
982 linesMR. EVERDELL: Your Honor, I think there are some issues with this first witness that I just want to raise with the Court first.
JUDGE NATHAN: That I have briefing on?
MR. EVERDELL: These are things that we've tried to talk with the government about. I don't think it's going to be a major dispute.
JUDGE NATHAN: Okay. I just wanted to make sure I hadn't missed it.
MR. EVERDELL: You did not miss anything.
JUDGE NATHAN: Okay. Go ahead.
MR. EVERDELL: The first witness is Ms. Espinosa.
JUDGE NATHAN: Right.
MR. EVERDELL: So the first issue, which I think the government and the defense agree on, is that there's a line of cross that we ask the government if they plan to get into, and they have agreed that they won't. And that's related to the following, which is that Ms. Galindo was a defendant in a civil lawsuit by one of the Epstein -- not one of the accusers in this case, but a different person. And so I've asked the government that they not get into that; they've agreed that they won't cross Ms. Espinosa about that.
JUDGE NATHAN: Okay.
MR. EVERDELL: I don't think there's any dispute about that.
JUDGE NATHAN: Agreement on that?
MS. POMERANTZ: Yes, your Honor.
JUDGE NATHAN: Thank you, Ms. Pomerantz.
MR. EVERDELL: And the second issue is we were just given by Ms. Espinosa some photographs that we would like to admit into evidence. She brought them with her today, so we just obtained them. I've shown them to the government. I can describe them for the Court. It's a series of photographs from the soap opera of Jane's -- that Jane was on, because Ms. Galindo -- sorry, Ms. Espinosa was a fan of the soap opera. And after Jane went and became a soap opera star, Jane sent her these photographs. And one is of her and there's some of other cast members as well. And she has the envelope as well. And we would like to admit those photographs and the envelope as exhibits in her testimony. I've shown them to the government. They were deciding whether or not they had an objection to this, but I was going to flag that for the Court.
MS. POMERANTZ: Your Honor, the government remains of the view it doesn't understand the relevance of these particular proffered exhibits; and would also note that this isn't impeaching her -- wouldn't be impeaching her testimony in any way. We just don't understand the relevance of these exhibits.
MR. EVERDELL: Your Honor, it's evidence that she maintained a relationship with the people in her abuser's -- alleged abuser's office. I mean, if she claims that she left New York and she fled this life with Epstein and didn't want anything more to do with it, this is evidence that she was keeping contact with people in his orbit. Ms. Espinosa worked in his office and was there with him in the office every day. So it goes to show that there was a continuing relationship. She voluntarily sent these photographs to her showing that she maintained that relationship voluntarily, which I think is the opposite of what you would do if what you wanted to do was put all this behind you and not be a part of this world anymore.
MS. POMERANTZ: Your Honor, my recollection of Jane's testimony was that she herself acknowledged that she had maintained a relationship with some of the individuals and their orbit on direct examination and in the course of her testimony. So, again, I don't understand the relevance of these photographs.
JUDGE NATHAN: So just to be clear, you're saying that evidence came in already that she maintained a relationship; correct?
MS. POMERANTZ: Your Honor, yes. There's no dispute about that. This wouldn't impeach her.
JUDGE NATHAN: I understand it wouldn't impeach, but first we start with the relevance question. That's already in.
MS. POMERANTZ: Yes, your Honor.
JUDGE NATHAN: Okay.
MR. EVERDELL: Your Honor, we don't simply have to take the witness's testimony. We are allowed to show that same point through other evidence. And these photographs show that the relationship continued. And we are entitled to argue not just from the witness's testimony, but from these photographs, that there was a continuing relationship and what that means in the defense's estimation, how we view -- how we can argue to the jury what that means in terms of her state of mind.
JUDGE NATHAN: All right. That the point is already in establishes relevance. I don't think it's 403 prejudice to have duplicative evidence of the nature of the relationship. I don't hear an argument for prejudice otherwise. So obviously mindful of the need to continue to protect the anonymity of the witness, I would allow it.
MR. EVERDELL: Yes, your Honor. And I've met with the witness and I've impressed upon her that she should only use the name Jane. And if she's referring to Jane's family members, say the mother or the brothers, she will say it that way, Jane's mother, Jane's brothers. And she will only refer to the soap opera, not the particular name of the soap opera.
JUDGE NATHAN: All right. What else?
MR. EVERDELL: I don't think anything from the defense at the moment, your Honor.
MR. ROHRBACH: Nothing from the government, your Honor.
JUDGE NATHAN: We have one more juror we're waiting on. Oh, while we have a moment, so I did work out logistics for the charging conference. We can do Saturday at 9 a.m. in this courtroom. And as I said, the DE and other courthouse staff will ensure significant public access. We'll have room in the courtroom and in overflow courtrooms for the charging conference. Anything else?
MR. EVERDELL: Sorry, I did forget one thing. With respect to those photos, your Honor, if they do get admitted, there's only one copy of each. So my plan on publishing them to the jury would be to just walk down the jury row with the photos so they can see them, because we don't have physical -- we just got them this morning; we don't have copies of the photos.
JUDGE NATHAN: You can't run off some copies?
MR. EVERDELL: We can try in the meantime.
JUDGE NATHAN: Okay.
MR. EVERDELL: But --
JUDGE NATHAN: I just think we have a standard for how we're doing this; and the need to make some photocopies isn't a sufficient burden to --
MR. EVERDELL: Well, we don't really have the resources --
MS. COMEY: Your Honor, the government is happy to make the copies.
JUDGE NATHAN: We'll do the copying.
MR. EVERDELL: All right. That's fine. I wish we did have a copier in our room, but we don't.
MS. STERNHEIM: Judge, may we have a two-minute break?
JUDGE NATHAN: Yes.
MS. STERNHEIM: Thank you.
JUDGE NATHAN: We'll adjourn until we have our jury. Thank you.
(Recess)
JUDGE NATHAN: All right. We have our jury. Anything to take up before I bring them in?
MS. STERNHEIM: Just very quickly, Judge.
JUDGE NATHAN: Sure. Please be seated.
MS. STERNHEIM: This has to do with a witness that may be coming in. It may be Dr. Loftus. We would like to be able to use the screen which you can draw on. And the technical people have assisted us in doing it. The only thing is this equipment does not save anything. So I would ask permission that we would be able to take a picture of it for the record. It's a demonstrative; it's not being put into evidence. But if the Court wished it to be part of the record, the only way to preserve it would be by a copy of it.
JUDGE NATHAN: What's an example? Usually you just use words to describe for the record what's being indicated.
MS. STERNHEIM: There's an opportunity for her to do a demonstrative for the jury. If we weren't in COVID, she would get up, she would stand before the jury with a whiteboard. We cannot do that under these circumstances. And the equipment is for that very purpose. It's been done in other cases; it's just that this equipment --
JUDGE NATHAN: So it would be like a whiteboard.
MS. STERNHEIM: Yes.
JUDGE NATHAN: Whiteboard doesn't come into evidence.
MS. STERNHEIM: I'm not saying it's coming into evidence.
JUDGE NATHAN: She can draw on it, but I don't see a need to take a picture.
MS. STERNHEIM: I'm only saying if the Court wished there to be a -- part of the record. But if the Court does not, that's fine.
JUDGE NATHAN: I'm sorry, I misunderstood. I thought you were asking for it to be part of the record.
MS. STERNHEIM: No. I'm just saying that there's -- she will be describing it and we will make sure it gets in the record. But I did not know if the Court wished there to be it as sort of a marked exhibit for identification just for the record, not in the record.
JUDGE NATHAN: I've never done that.
MS. STERNHEIM: Then that's fine. I'm just --
JUDGE NATHAN: If somebody requests it, I'm happy to hear the request, but it's not something I've ever --
MS. STERNHEIM: Then it's not necessary. I did not know if the Court would prefer that.
JUDGE NATHAN: All right.
MR. EVERDELL: Your Honor, if the Court would like, I have just 3500 material for the witness in paper copy.
JUDGE NATHAN: Okay. Thank you.
MR. EVERDELL: I also have a copy for the witness which I can put in the box.
JUDGE NATHAN: Yes. Okay. Can we get our jury. Yes. Thank you, Ms. Williams. Who will call the witness, just so I can designate the right person to call the first witness?
MR. EVERDELL: I will be calling the first witness.
JUDGE NATHAN: All right. Thank you, Mr. Everdell.
MR. EVERDELL: Your Honor, I'll check if the witness is there. THE MARSHAL: Are you ready for her? She's outside.
MR. PAGLIUCA: Your Honor, we'll check --
JUDGE NATHAN: Of course. Thank you. Not yet. Thank you. Bring in the jury.
(Continued on next page)
(Jury present)
JUDGE NATHAN: Thank you, everyone. Please be seated. Good morning, members of the jury. Nice to see you. All right. I hope everyone is well. We will proceed with the next phase of the case. Mr. Everdell, the defense may call its first witness.
MR. EVERDELL: Thank you, your Honor. The defense calls Kimberly Espinoza.
JUDGE NATHAN: Cimberly Espinosa may come forward. CIMBERLY ESPINOSA, called as a witness by the Defendant, having been duly sworn, testified as follows:
JUDGE NATHAN: Come forward into the box, you can take your seat, you may remove your mask, and please state and spell your name for the record.
CIMBERLY ESPINOSA: My name is Cimberly Espinosa, and it's spelled C-i-m-b-e-r-l-y E-s-p-i-n-o-s-a.
JUDGE NATHAN: Thank you. I will ask you, if you can, pull up as close to the mic as you can and please speak directly into the microphone. Thank you. Mr. Everdell, you may inquire.
MR. EVERDELL: Thank you, your Honor.
DIRECT EXAMINATION BY MR. EVERDELL:
MR. EVERDELL: Good morning, Ms. Espinosa.
CIMBERLY ESPINOSA: Good morning.
MR. EVERDELL: Ms. Espinosa, how old are you?
MR. EVERDELL: And where do you live?
CIMBERLY ESPINOSA: I live in California.
MR. EVERDELL: How far did you go in school?
CIMBERLY ESPINOSA: About a year and a half of college.
MR. EVERDELL: Are you married?
CIMBERLY ESPINOSA: Yes.
MR. EVERDELL: And do you work currently?
CIMBERLY ESPINOSA: Yes.
MR. EVERDELL: What is your current job?
CIMBERLY ESPINOSA: I'm an executive assistant to the CEO of a global company.
MR. EVERDELL: Is that in California?
CIMBERLY ESPINOSA: Yes.
MR. EVERDELL: And how long have you been doing that job?
CIMBERLY ESPINOSA: It will be 10 years.
MR. EVERDELL: I want to direct your attention now to October of 1996.
CIMBERLY ESPINOSA: Okay.
MR. EVERDELL: About how old were you in October 1996?
MR. EVERDELL: And where were you living around that time?
CIMBERLY ESPINOSA: I was living in Midtown.
JUDGE NATHAN: Pausing for technical issues. Thank you very much. Go ahead, Mr. Everdell.
MR. EVERDELL: Thank you, your Honor.
MR. EVERDELL: Ms. Espinosa, I actually want to jump back for a second. You mentioned your current job is an executive assistant for a CEO; is that right?
CIMBERLY ESPINOSA: Correct.
MR. EVERDELL: Can you describe generally what you do in that position.
CIMBERLY ESPINOSA: I am basically the gatekeeper for the CEO. All appointments are scheduled through me, I book a lot of travel, book a lot of meetings. I'm also, I guess, the senior executive assistant supervising about six other executive assistants for the company.
MR. EVERDELL: Now I will direct your attention back to October of 1996. Say again where you were living around that time.
CIMBERLY ESPINOSA: Well, I moved from California to New York, and when I first moved to New York, I lived on the Upper East Side. I previously said Midtown, but that's because I moved from the Upper East Side to Midtown during my employment.
MR. EVERDELL: But you started out on the Upper East Side. Okay. Did you get a job when you came to New York?
MR. EVERDELL: And what job did you get at that time?
CIMBERLY ESPINOSA: I was hired by J. Epstein & Co. for the legal team, legal counsel being Jeff Schantz and Darren Indyke. I was hired as the legal assistant, the legal admin.
MR. EVERDELL: And J Epstein & Co. was whose company?
CIMBERLY ESPINOSA: Jeffrey Epstein's company.
MR. EVERDELL: And had you held any jobs as of this type of assistant before working for Mr. Epstein?
CIMBERLY ESPINOSA: Yes. I was previously -- before I came here, I was an executive assistant to the CEO of a small startup technology company for about two years before I moved here.
MR. EVERDELL: And how did you find the job with Jeffrey Epstein's company?
CIMBERLY ESPINOSA: One of the papers, either the New York Times or the Daily News, I'm not sure, but it was an ad that I answered or responded to by calling a job agency, and I interviewed with the job agency who sent me to two or three places to interview in a day and one of them was J. Epstein & Co.
MR. EVERDELL: Did you have to interview with anybody at the J. Epstein company to get the job?
MR. EVERDELL: Who did you interview with?
CIMBERLY ESPINOSA: I interviewed with four people. First it was Jeff and Darren themselves --
MR. EVERDELL: Let me pause you there. Can you say their full names?
CIMBERLY ESPINOSA: Jeff Schantz and Darren Indyke.
MR. EVERDELL: Who were they?
CIMBERLY ESPINOSA: They were the legal counsel representing Jeffrey Epstein.
MR. EVERDELL: And who else, who were the other two?
CIMBERLY ESPINOSA: And then I passed the cut, I guess, from Darren and Jeff, and was asked to interview with Ghislaine Maxwell.
MR. EVERDELL: And can you describe that interview.
CIMBERLY ESPINOSA: Yeah. It was rather unique. She had been running around doing errands and wasn't able to make it up to the office where I had been interviewed with Jeff and Darren, and so she had asked if -- the receptionist asked me if it would be okay if I can come down and have the interview in the back of the sedan that was driven by a chauffeur. So our interview took place driving around Manhattan in the back of a limousine.
MR. EVERDELL: And how did that interview go?
CIMBERLY ESPINOSA: It went well. It was a different interview than I had experienced before, so I liked it, it was fun and I liked meeting Ghislaine.
MR. EVERDELL: Did you meet with anybody else or interview with anybody else after your interview with Ghislaine?
CIMBERLY ESPINOSA: Yes. After I passed that test, I was allowed to meet with Jeffrey Epstein, who would make the final decision on whether I would be hired or not.
MR. EVERDELL: And how did that interview go?
CIMBERLY ESPINOSA: And I interviewed back at the office with Jeffrey Epstein after waiting for a few hours for him. And when he came, we had a normal interview, if will you, and I left. And I found out the next day that I was given a job offer.
MR. EVERDELL: Now you mentioned that you were -- did you take the job? Okay.
JUDGE NATHAN: I'm sorry. Could you state the answer.
CIMBERLY ESPINOSA: Yes, I did take the job.
MR. EVERDELL: Be sure to state the answer as we can't do nodding.
CIMBERLY ESPINOSA: Okay.
MR. EVERDELL: You mentioned before that the job you got was with the legal counsel with Jeffrey Epstein?
MR. EVERDELL: Did your job change at any point?
CIMBERLY ESPINOSA: It did.
MR. EVERDELL: How did it change?
CIMBERLY ESPINOSA: One day, Ghislaine's assistant had called in sick or was on vacation a day or -- a day or a week or something and I was filling in for Ghislaine. After my fill-in, she decided that she would like me to support her. So I switched after getting conversations with Jeff and Darren to make sure they were okay that I go and work for Ghislaine instead.
MR. EVERDELL: And so your position changed at that point?
MR. EVERDELL: And what was the new position?
CIMBERLY ESPINOSA: It would be the executive assistant to Ghislaine.
MR. EVERDELL: And how long did you work as Ghislaine's executive assistant?
CIMBERLY ESPINOSA: I would say approximately six years.
MR. EVERDELL: So from roughly when to when in years?
CIMBERLY ESPINOSA: Probably November of 1996 to the end of the summer of 2002. Something like that. Summer to fall.
MR. EVERDELL: In the roughly six or so years that you worked with Ghislaine, about how much time did you spend with her and work with her?
CIMBERLY ESPINOSA: I spent a lot of time with her in the office. So she would come into the office almost every day. I was in the office every day. We worked together just about every day.
MR. EVERDELL: And you mentioned the office. Where was the office?
CIMBERLY ESPINOSA: The office on 457 Madison Avenue.
MR. EVERDELL: In the time that you worked with her, did you get to know her during that time?
MR. EVERDELL: What was your impression of Ghislaine?
CIMBERLY ESPINOSA: I highly respected Ghislaine. I kind of -- no, not kind of. I looked up to her very much. And I actually learned a lot from her as far as administrative and being able to handle a lot of calls, a lot of duties. It was a very high-volume work -- lots of work to do as far as arrangements to be made. I attribute my career right now as an executive assistant to what I learned at supporting Ghislaine.
MR. EVERDELL: And how did she treat you as an employee?
CIMBERLY ESPINOSA: She treated me fair and nice and it was fun.
MR. EVERDELL: What did you think of your experience working for Ghislaine?
CIMBERLY ESPINOSA: Well, she was demanding, in a way, where, you know, every task that was given needed to be done as soon as possible, if not yesterday, and I enjoyed that challenge. But I was able to do my job and do everything that was needed to be done in a day. So it worked well.
MR. EVERDELL: Did you have any contact with Ghislaine after you stopped working as her assistant?
CIMBERLY ESPINOSA: Yes, I did.
MR. EVERDELL: What sort of contact did you have?
CIMBERLY ESPINOSA: Kind of milestone contacts, birthday wishes, Christmas wishes. I asked for a couple of letter of references, personal references for future jobs after I left Epstein & Co.
MR. EVERDELL: You mentioned birthday wishes. Do you remember when Ghislaine's birthday was?
CIMBERLY ESPINOSA: Absolutely.
MR. EVERDELL: When was it?
CIMBERLY ESPINOSA: Christmas day, 12/25.
MR. EVERDELL: Do you remember what year that was?
CIMBERLY ESPINOSA: She's about five years older than me, so '61.
MR. EVERDELL: Would you recognize Ghislaine today?
CIMBERLY ESPINOSA: Of course.
MR. EVERDELL: Would you look around the courtroom, please, Ms. Espinosa, and do you see Ghislaine Maxwell in the courtroom today?
CIMBERLY ESPINOSA: I do.
MR. EVERDELL: Will you please point her out and identify an article of clothing she's wearing.
CIMBERLY ESPINOSA: She is right across from me right there in what appears to be a purple-hue turtleneck.
MR. EVERDELL: Let the record reflect that the witness has identified Ghislaine Maxwell.
JUDGE NATHAN: It may so reflect. Thank you.
MR. EVERDELL: Ms. Espinosa, when you were working for Jeffrey Epstein's company, where, physically, did you work?
CIMBERLY ESPINOSA: In the office, 457 Madison.
MR. EVERDELL: That's in Manhattan?
MR. EVERDELL: Did you work there the whole time that you were working for Mr. Epstein?
MR. EVERDELL: Did you work anywhere else?
CIMBERLY ESPINOSA: Maybe just a handful of times I would work at Ghislaine's residence, but that was towards the end of my career there.
MR. EVERDELL: And about how much time did you actually spend in Ghislaine's residence, all tolled, roughly?
CIMBERLY ESPINOSA: Maybe a week or two, max. Not straight. It was just a day here, a day there.
MR. EVERDELL: Over the course of your whole six years?
MR. EVERDELL: Did you ever work out of Jeffrey Epstein's residence in Manhattan?
MR. EVERDELL: What were your typical working hours in the office?
CIMBERLY ESPINOSA: Typical working hours for me were about 9:30 to 6:30.
MR. EVERDELL: Now, I want to focus your attention on the time period when you started your job, so the mid to late '90s, '96, '97, '98. Who were the people who worked in the office in that time period?
CIMBERLY ESPINOSA: We had Jeff Schantz and Darren Indyke, the legal team. There was another attorney, Amanda Milroy. There was an accounting team, Harry Beller, Eric Gany, a woman by the name of Bella, I don't remember her last name. Also another woman named Gee, I don't remember her last name. We had a receptionist, Michelle. Jeffrey Epstein had his executive assistant, at the time was a woman named Maureen when I first started. We had -- did I say the receptionist?
MR. EVERDELL: You mentioned, I think, Michelle was a receptionist. Do you remember Michelle's last name?
CIMBERLY ESPINOSA: Healy.
MR. EVERDELL: Were there any other receptionists you recall?
CIMBERLY ESPINOSA: Yes, there was a Helen Kim that came after Michelle left.
MR. EVERDELL: And you mentioned, I think, Mr. Epstein's executive assistants; is that right?
MR. EVERDELL: Is that separate or the same as the receptionists?
CIMBERLY ESPINOSA: Separate.
MR. EVERDELL: And you mentioned a Maureen. Were there any other executive assistants that were there during your time in the office?
CIMBERLY ESPINOSA: Yes, Leslie Roth and Suann Pisap.
MR. EVERDELL: Who came before who, Suann or Leslie?
CIMBERLY ESPINOSA: Suann was before Leslie.
MR. EVERDELL: Was Leslie there when you left?
MR. EVERDELL: Were there any other people in the office that you recall working there in any of the offices there?
CIMBERLY ESPINOSA: On a daily basis, I can't remember if there was anybody else there working on a daily basis. We did have other personal assistants come through and hang out, not necessarily all day, but kind of like pit stops. That would be Emmy Taylor and Sarah Kellen.
MR. EVERDELL: So with respect to Emmy Taylor, I'm focusing your attention on the 1996, '97, '98. Do you recall seeing Emmy Taylor during that time period?
CIMBERLY ESPINOSA: I don't recall when I first saw her. I don't know. I would say it was the middle of my time there, in the middle of that time.
MR. EVERDELL: You also mentioned a Sarah Kellen. Do you remember when you started seeing Sarah Kellen?
CIMBERLY ESPINOSA: That was more towards the end.
MR. EVERDELL: So in the time period, '96, '97, '98, do you recall seeing Sarah Kellen?
CIMBERLY ESPINOSA: Hard to say, but I don't think so.
MR. EVERDELL: We'll talk about those folks in a minute. Can you describe the layout of the office space at Madison Avenue from when you get off the elevator.
CIMBERLY ESPINOSA: Sure. So you get off the elevator and immediately to your left were the restrooms. Immediately in front of you was the accounting team office, then the reception desk would just be kind of pitched to the right. Behind the reception desk was a hallway where the offices were. The legal team sat on the left-side office, and that was followed by Jeffrey's office, which was a corner. Directly next to Jeffrey's office and directly behind the receptionist at the end of the hall would have been Jeffrey Epstein's assistant, and then I sat to the left of Jeffrey Epstein's assistant. So we were, like, in a row. If all doors were open, I could see Jeffrey in the corner, his assistant, myself. And then in my office, which was Ghislaine's office, there were three desks — one was Ghislaine's, one was mine, and one was the legal assistant's.
MR. EVERDELL: Do you remember the legal assistant's name when you were there?
CIMBERLY ESPINOSA: Lauren Quitner (ph.).
MR. EVERDELL: Lauren Quitner?
MR. EVERDELL: So in the office where you sat and where Ghislaine sat, how many people actually sat in that office?
CIMBERLY ESPINOSA: Three.
MR. EVERDELL: Were there cubicles or was it a shared space?
CIMBERLY ESPINOSA: Shared space. Shared open space.
MR. EVERDELL: In your time there, do you recall Ghislaine having her own private office, ever?
MR. EVERDELL: When you started the job, did you have to sign any legal documents or agreements?
MR. EVERDELL: What did you have to sign?
CIMBERLY ESPINOSA: A nondisclosure agreement.
MR. EVERDELL: Did you have any particular reaction -- withdrawn. What did the nondisclosure agreement mean to you?
CIMBERLY ESPINOSA: Just not to repeat any of my work. My work was my work not to be shared with the privacy and out of respect and privacy for Jeffrey Epstein, you know, not to share who his clients are or anything that I might be privy to.
MR. EVERDELL: In your work as an executive assistant for other CEOs, did you ever have to sign a nondisclosure agreement for them?
MR. EVERDELL: That's happened in the past?
MR. EVERDELL: Did you have any particular reaction to signing these NDAs?
MR. EVERDELL: Were you ever given any instructions about how you could or could not interact with other employees in the office?
MR. EVERDELL: Were you ever given any instructions about how you could or could not interact with Jeffrey Epstein?
MR. EVERDELL: I want to talk to you in a little bit more detail about your duties and responsibilities at the office. We'll start first with the job you briefly had as the admin to the lawyers. What were your responsibilities there?
CIMBERLY ESPINOSA: A lot of photocopying, filing. That was the gist of it. And taking messages for them if they weren't available for a phone call.
MR. EVERDELL: And do you know what sort of functions the lawyers performed for Mr. Epstein, from your observations?
CIMBERLY ESPINOSA: I don't know exactly what they performed, but I know that they were pretty important to Jeffrey Epstein.
MR. EVERDELL: And about how soon after you started your job did you transition to becoming Ghislaine's executive assistant?
CIMBERLY ESPINOSA: I would say it was within a month. It was kind of quick.
MR. EVERDELL: What were your responsibilities as Ghislaine's executive assistant?
CIMBERLY ESPINOSA: Making arrangements. We had kind of a routine where she would come in, I'd sit at her desk, she'd give me a laundry list of tasks to do for the day, people she needed to talk to, things I needed to have shipped, things I needed to have purchased, reservations to be made. It could have been a list of anywhere from 25 to 50 things in a day.
MR. EVERDELL: And what was Ghislaine's employment role in the office, what jobs did she perform?
CIMBERLY ESPINOSA: She was the estate manager, in my mind. She ran the properties for Jeffrey Epstein.
MR. EVERDELL: And did you assist her with those jobs?
CIMBERLY ESPINOSA: I did.
MR. EVERDELL: And I'll get to the estates in a second, but as compared to the other people in the office, where, in your mind, did Ghislaine would fall in terms of importance?
CIMBERLY ESPINOSA: Ghislaine was very important to me. She was obviously important to Jeffrey Epstein because of his personal residences. I can't really say in Jeffrey Epstein's eyes what her importance was, but, again, to me, she was quite important.
MR. EVERDELL: Well, if Ghislaine managed Jeffrey's properties, were there other people in the office who handled other aspects of his life?
CIMBERLY ESPINOSA: Absolutely.
MR. EVERDELL: Like who?
CIMBERLY ESPINOSA: Like his finance people handling the money and his attorneys handling his business affairs.
MR. EVERDELL: To your knowledge, did Ghislaine have any role in managing those aspects of Jeffrey Epstein's life?
CIMBERLY ESPINOSA: Not to my knowledge.
MR. EVERDELL: Now you mentioned the properties, right. How many properties did Jeffrey Epstein own when you started working in the office?
CIMBERLY ESPINOSA: When I started working, he had already owned Zorro Ranch, 9 East 71st Street, and El Brillo, I believe.
MR. EVERDELL: You mentioned Zorro Ranch, where was that?
CIMBERLY ESPINOSA: That was in New Mexico.
MR. EVERDELL: 9 East 71st Street was where?
CIMBERLY ESPINOSA: New York.
MR. EVERDELL: And El Brillo was where?
CIMBERLY ESPINOSA: Florida.
MR. EVERDELL: Did there come a time when he acquired any additional properties while you were there?
CIMBERLY ESPINOSA: Yes. I believe he acquired a Paris apartment, and he also purchased the island, St. Thomas.
MR. EVERDELL: Do you remember the name of the island?
CIMBERLY ESPINOSA: It was Little Saint James, but the name was changed to Little Saint Jeffs.
MR. EVERDELL: Was that purchased, the island, at the time you were there?
CIMBERLY ESPINOSA: Yes. I would say probably the middle of my time there, it was purchased, and it was a humongous project.
MR. EVERDELL: Please describe, if you could, just that particular project of getting the island ready, what was involved in that and what roles did you and Ghislaine perform?
MS. POMERANTZ: Objection. Foundation.
JUDGE NATHAN: All right. You may inquire. Why don't you start with the latter part of the question.
MR. EVERDELL: Did you assist Ms. Maxwell in any way with the project. Island?
MR. EVERDELL: And what sort of things did you assist with?
CIMBERLY ESPINOSA: There was new construction being done on the island, there were, I think, new swimming pools. But the majority of what I did was furnish the house, furnish the resort style. There was, you know, every house good that you could think of — silverware, glasses, towels, beach towels, linens. We had to ship all of that over, all of the furniture, all of the artwork. We even shipped in sand and palm trees and all kinds of things to get the island to what he wanted it to be.
MR. EVERDELL: To be clear, you shipped in sand to a tropical island, why was that?
CIMBERLY ESPINOSA: He wanted more sand on the beach.
MR. EVERDELL: Palm trees, too?
CIMBERLY ESPINOSA: Uh-huh.
MR. EVERDELL: When you started when the island was acquired, was there anything, to your knowledge, on the island or was there nothing on the island?
CIMBERLY ESPINOSA: I think there may have been one building or something. It was a lot of construction going on. We even had a fire department on the island, a firehouse with a proper firetruck and firemen and all of that.
MR. EVERDELL: Was it part of your job to help Ghislaine do all this?
CIMBERLY ESPINOSA: It was part of my job to, yes. Ghislaine would tell me who she needed to talk to in a day, whether it be landscapers, designers, interior decorators.
MR. EVERDELL: So just focusing on that particular project with the island, how big a job was that to get the island up and running?
CIMBERLY ESPINOSA: It was more than full-time, in my eyes.
MR. EVERDELL: And how long did that project last?
CIMBERLY ESPINOSA: Months. I don't even know that it ever finished, to be honest.
MR. EVERDELL: So just broadly speaking, how big a job, from your observation, how big a job was it for Ghislaine to manage all of these properties for Mr. Epstein?
CIMBERLY ESPINOSA: It was a huge job.
MR. EVERDELL: Did she work hard?
MR. EVERDELL: And in connection with her responsibilities, did she ever have to travel to the properties to manage them?
CIMBERLY ESPINOSA: Sure.
MR. EVERDELL: And how often did she travel to do that?
CIMBERLY ESPINOSA: Well, she traveled on a weekly basis for the most part. I can't say, you know, when she went to each house for what purpose.
MR. EVERDELL: When she did travel, would she always travel with Jeffrey Epstein or would she sometimes travel herself?
CIMBERLY ESPINOSA: She sometimes traveled herself.
MR. EVERDELL: Did you ever travel with her?
MR. EVERDELL: If Mr. Epstein wanted to travel to one of his properties to visit, what preparation would need to occur before he traveled?
CIMBERLY ESPINOSA: Well, Jeffrey had -- we always had the houses prepared, all of the houses prepared for wherever he decided he wanted to go. So what needed to happen was there was bread flown in, his favorite bread that he liked. I think we did butter, as well. Make sure that the houses were stocked. There were certain things from New York that he wanted specifically in all of the residences, and it needed to be fresh for his arrival. So on occasion, it wouldn't be odd to ship out this food to each of the residences so that it would be there for whenever he decided to show up or go.
MR. EVERDELL: And whose job was it to supervise all of these logistics?
CIMBERLY ESPINOSA: It would be Ghislaine's.
MR. EVERDELL: And did you assist her with those?
CIMBERLY ESPINOSA: Absolutely. "Q. Do you recall someone named, I think you mentioned before, Emmy Taylor? A. Yes.
MR. EVERDELL: Who was Emmy Taylor?
CIMBERLY ESPINOSA: Emmy Taylor was an assistant to Ghislaine. I kind of looked at it more like a personal assistant as opposed to what I did sitting in the office as an executive assistant.
MR. EVERDELL: Can you describe a little bit about the difference between your job versus what her job was.
CIMBERLY ESPINOSA: Sure. She would look after the dog, you know, take the dogs for a walk, take it out if it needed, because Ghislaine would bring the dog to the office. She would carry her handbag and her coat and run out and get her coffee or pasta or whatever. So that's what I saw in the office that she did for Ghislaine.
MR. EVERDELL: Did Emmy work in the office or did she work elsewhere?
CIMBERLY ESPINOSA: She worked elsewhere. She was sometimes in the office, but not too often.
MR. EVERDELL: Were you friendly with Emmy Taylor?
MR. EVERDELL: Ms. Espinosa, how did Mr. Epstein typically travel to his different properties?
CIMBERLY ESPINOSA: On one of his planes, private planes that he owned.
MR. EVERDELL: Do you know how many planes he owned around the time you were working for him?
CIMBERLY ESPINOSA: I think three, three or four maybe.
MR. EVERDELL: Did you ever fly on his private planes?
MR. EVERDELL: Did you ever have any dealings with the pilots about flights that were going to take place on the private planes?
CIMBERLY ESPINOSA: Sure. On occasion I would have to tell them what time wheels up was. Jeffrey might call in and I'd pick up the phone and he'd say, tell Larry wheels up at 8 o'clock to wherever he was going.
MR. EVERDELL: And who was Larry?
CIMBERLY ESPINOSA: Larry, one of Jeffrey's pilots.
MR. EVERDELL: Did Ghislaine ever make a similar call when you were in the office to let Larry know when wheels up was?
CIMBERLY ESPINOSA: It was directed by Jeffrey Epstein, what time wheels were up. And on occasion, I'm sure Ghislaine also told Larry what time that would be.
MR. EVERDELL: Who in the office would most typically interact with the pilots about wheels up times and make arrangements for flights?
CIMBERLY ESPINOSA: It could be any of the assistants, me, Jeffrey's assistant, or Ghislaine herself.
MR. EVERDELL: And when you arranged the flights or when you had conversations with the pilots, what information did you give the pilots, typically?
CIMBERLY ESPINOSA: That was it. The time -- they always, you know, the planes were at Teterboro airport, so there was never a question of where they needed to be. It was just what time was wheels up and where were they going.
MR. EVERDELL: Did you typically have information about the names of the passengers that would be on the flights?
MR. EVERDELL: Do you know if Mr. Epstein ever traveled with guests on his plane?
CIMBERLY ESPINOSA: Sure. Yes.
MR. EVERDELL: Did you typically know the names of the guests that were flying?
CIMBERLY ESPINOSA: No, not really. Sometimes some of his friends would call and ask for a lift to Florida, something like that, but I don't recall the names or I wouldn't really know what guests were flying at any given time.
MR. EVERDELL: Did Epstein ever travel on commercial flights?
CIMBERLY ESPINOSA: Not to my knowledge.
MR. EVERDELL: Would Ghislaine ever travel on commercial flights?
MR. EVERDELL: And when would she do that?
CIMBERLY ESPINOSA: There were times where she would either fly to see family in London or she would fly to Miami a couple times. Couple times she came out to California. Just different -- just when she wasn't with Jeffrey, she would be somewhere else.
MR. EVERDELL: Did you help arrange those commercial flights?
MR. EVERDELL: Did you arrange commercial flights for anyone else in the office?
CIMBERLY ESPINOSA: No, not really that I can recall. Maybe, maybe I did, but I don't remember exactly.
MR. EVERDELL: When you arranged these commercial flights, did you call the airlines directly or did you use a travel service?
CIMBERLY ESPINOSA: We used a travel agency.
MR. EVERDELL: And what was the name of that travel agency?
CIMBERLY ESPINOSA: Shoppers Travel.
MR. EVERDELL: Do you know where that was located?
CIMBERLY ESPINOSA: It was in New York, but I don't know where. I never was there in person, just on the phone.
MR. EVERDELL: As part of your responsibilities as Ghislaine's executive assistant, did you ever book massages for Ms. Maxwell?
MR. EVERDELL: And where did you book those massages?
CIMBERLY ESPINOSA: She had her places in SoHo. She liked Bliss Spa, she liked the Red Door, Elizabeth Arden, places like that.
MR. EVERDELL: Were these professional massage places?
MR. EVERDELL: Did you ever schedule a massage for Jeffrey Epstein?
MR. EVERDELL: Do you remember how many times, roughly, you did that?
CIMBERLY ESPINOSA: Maybe ten my entire time I was there. I don't -- five to ten. A handful of times.
MR. EVERDELL: Do you remember any of the masseuses he used?
CIMBERLY ESPINOSA: I do remember a few names. What comes to mind is there was a Lydia, a Monica. I don't really remember. It's hard for me to recall off the top of my head, but if I hear them that's when I'm like, oh, I remember that name.
MR. EVERDELL: Were these people professional masseuses?
CIMBERLY ESPINOSA: Yeah.
MR. EVERDELL: Did you ever get a massage yourself?
CIMBERLY ESPINOSA: I did.
MR. EVERDELL: Do you remember who gave you that massage?
CIMBERLY ESPINOSA: Yes, that was Sophie Biddle.
MR. EVERDELL: Was that a masseuse that Mr. Epstein used?
MR. EVERDELL: Were you ever inside of Mr. Epstein's residence in New York?
CIMBERLY ESPINOSA: I did get a tour when I first started. I think I did meet Ghislaine there on occasion once or twice to either drop off something or retrieve something and take it back to the office.
MR. EVERDELL: And where was the residence?
CIMBERLY ESPINOSA: 9 East 71st Street.
MR. EVERDELL: Is that on the Upper East Side?
CIMBERLY ESPINOSA: I don't know if that's considered the Upper East Side, but, yes, it was right off the park, Central Park.
MR. EVERDELL: Were you ever in Ghislaine's residence?
MR. EVERDELL: Did she live in the same residence when you worked for her or more than one residence?
CIMBERLY ESPINOSA: She had more than one residence or she had moved. She was first on the Upper East Side and then she moved to 65th Street.
MR. EVERDELL: Do you remember roughly where on the Upper East Side she was living when you started the job?
CIMBERLY ESPINOSA: I want to say it was 84th Street. I lived on 88th Street, so I remember kind of feeling like we were in the same neighborhood.
MR. EVERDELL: And do you remember roughly when she moved to 65th Street?
CIMBERLY ESPINOSA: I would say that would be during the middle of my time there, maybe 2000, late '90s, early 2000.
MR. EVERDELL: And the 81st Street residence, what kind of residence was that?
CIMBERLY ESPINOSA: What kind of residence?
MR. EVERDELL: Was it a townhouse or an apartment?
CIMBERLY ESPINOSA: It was a townhouse with many levels.
MR. EVERDELL: Was that the 84th Street one or the 65th Street one?
CIMBERLY ESPINOSA: No, I'm sorry. I was thinking that we were talking about Jeffrey Epstein's on 71st Street. So now we went back to Ghislaine?
MR. EVERDELL: Yes. Let me be clear. I'm asking you about Ghislaine's different residences, you mentioned two, one on 84th Street, one on 64th Street?
CIMBERLY ESPINOSA: Correct.
MR. EVERDELL: So let me first ask you about the 84th Street residence. What kind of a residence was that?
CIMBERLY ESPINOSA: That was a townhouse-type thing. Maybe it was an apartment. It was so long ago, I can't really recall that, but I do recall her residence on 65th Street.
MR. EVERDELL: Okay. What do you recall about the residence on 65th Street?
CIMBERLY ESPINOSA: That was a townhouse with, I think, three levels.
MR. EVERDELL: And to your knowledge, did Ghislaine always retain her own residence in New York while you were at your job?
MR. EVERDELL: To your knowledge, did she ever reside with Jeffrey Epstein?
MR. EVERDELL: Are you familiar with a residence at 44 Kinnerton Street?
MR. EVERDELL: Whose residence was that?
CIMBERLY ESPINOSA: Ghislaine's.
MR. EVERDELL: And what city was that in?
CIMBERLY ESPINOSA: London.
MS. POMERANTZ: Objection. Foundation, your Honor.
JUDGE NATHAN: Sustained.
MR. EVERDELL: Have you ever been to that residence?
MR. EVERDELL: When were you in that residence?
CIMBERLY ESPINOSA: Three years ago.
MR. EVERDELL: So do you know who owned that residence at the time you were there?
MS. POMERANTZ: Objection. Foundation.
JUDGE NATHAN: I'll take yes or no to this question and then sustain.
MS. POMERANTZ: I should also just say hearsay, your Honor.
JUDGE NATHAN: I'll take yes or no to the question, do you know who owned the residence at the time that you were there.
JUDGE NATHAN: Just yes or no. A. No.
MR. EVERDELL: How was it that you were at that residence three years ago?
CIMBERLY ESPINOSA: It was my first trip to Europe and I reached out to Ghislaine to ask her if I could stay there.
MR. EVERDELL: And so you were inside while you were there?
MR. EVERDELL: Was there a massage room in that residence when you were there?
MR. EVERDELL: I want to jump back to your work in the office a bit. From your work in the office, do you know whether Epstein gave to charity?
CIMBERLY ESPINOSA: He did give to charity.
MS. POMERANTZ: Objection, your Honor.
JUDGE NATHAN: I'll allow it. What's the next question?
MR. EVERDELL: What organizations did he give to.
JUDGE NATHAN: I'll sustain with respect to that.
MR. EVERDELL: Did he engage in any other types of giving?
MR. EVERDELL: What did you observe him -- what types of giving did you observe him doing?
CIMBERLY ESPINOSA: I know that he paid for some of the employees' kids' education. He was -- I believe that he also paid for other people's educations. He was a giver. He was generous and I always knew him to be donating to charities and just being a kind person.
MR. EVERDELL: Did Epstein ever give you any gifts?
CIMBERLY ESPINOSA: He did give me the massage a couple times. And, also, he had paid for a personal trainer for me to have. I guess that was a gift. I kind of thought of it more as an employee perk. I don't really think he gave me any gifts, other than when I left. My departure, I was given a watch.
MR. EVERDELL: Were there any special events he treated you to?
CIMBERLY ESPINOSA: Yes. That was going to The Lion King.
MR. EVERDELL: And was this the Broadway show or was this the movie?
CIMBERLY ESPINOSA: The Broadway show.
MR. EVERDELL: And about when did that happen?
CIMBERLY ESPINOSA: I believe that's when the show first came out, it was a hot ticket, and I recall him being friendly with the producer of the show. And during a time of a month or two, he was sending a lot of people to The Lion King.
MR. EVERDELL: And that included yourself?
CIMBERLY ESPINOSA: Uh-huh.
MR. EVERDELL: And about how soon after the show opened, in your recollection, was he handing out these tickets?
CIMBERLY ESPINOSA: That I can't say. I'm not sure.
MR. EVERDELL: But you recall it being a hot ticket?
CIMBERLY ESPINOSA: Oh, yeah. It was new. It was a new show.
MR. EVERDELL: Do you recall anybody else that he gave Lion King tickets to?
CIMBERLY ESPINOSA: I feel like he gave them to almost all of the employees if they wanted. It was just something that he was giving out at that time. I don't really recall who else.
MR. EVERDELL: I'm going to ask you a little bit more about the office. Did Epstein ever receive visitors in the office?
MR. EVERDELL: Were any of these visitors female?
MR. EVERDELL: I want to show you on the screen, this is an exhibit that's already admitted, Government Exhibit 12, but I believe it's admitted under seal. So if we can just display it --
MR. EVERDELL: May I confer, your Honor?
JUDGE NATHAN: You may.
MR. EVERDELL: All right. So if we can just display Government Exhibit 12 for the Court, the deputy, and the witness only. This is already admitted under seal.
MR. EVERDELL: Do you see that document in front of you?
CIMBERLY ESPINOSA: Yes, I do.
MR. EVERDELL: Now, without saying the name of that person out loud, do you recognize the name of the person on that document?
CIMBERLY ESPINOSA: Yes, I do.
MR. EVERDELL: I'm going to refer to that person as Jane and you should, too. Okay?
CIMBERLY ESPINOSA: Okay.
MR. EVERDELL: You can take that down now.
MR. EVERDELL: Ms. Espinosa, do you ever recall seeing Jane in the office?
MR. EVERDELL: How old did she appear to you to be when you first saw her?
CIMBERLY ESPINOSA: Probably 18.
MR. EVERDELL: And about when do you recall first seeing Jane in the office?
CIMBERLY ESPINOSA: I remember seeing Jane in the office with her mother.
MR. EVERDELL: And about when do you recall that happening for the first time?
CIMBERLY ESPINOSA: Probably the beginning to middle of my time there.
MR. EVERDELL: And about how many times did Jane visit the office, to your recollection?
CIMBERLY ESPINOSA: There was a few times. I can't really say how many times, but I would say maybe five.
MR. EVERDELL: And you mentioned Jane's mother. Do you recall how many times Jane's mother came with her to the office?
CIMBERLY ESPINOSA: I don't recall, but I know that Jane's mother called the office a lot because I spoke to her a lot on the phone.
MR. EVERDELL: About how often was Jane's mother calling the office?
CIMBERLY ESPINOSA: Hard to say, but I want to say there was, you know, a couple months where it was a lot.
MR. EVERDELL: And who was she asking to speak to when Jane's mother called the office?
CIMBERLY ESPINOSA: Jeffrey Epstein.
MR. EVERDELL: What, generally, do you recall about Jane and Jane's mother and their interactions with Mr. Epstein in the office?
CIMBERLY ESPINOSA: Well, Jane's mother had mentioned that her daughter --
MS. POMERANTZ: Objection, your Honor. Hearsay.
MR. EVERDELL: It's not offered for the truth, your Honor.
JUDGE NATHAN: Just a moment. I'll need a proffer.
(Continued on next page)
(At the sidebar)
MR. EVERDELL: Your Honor, I anticipate the witness is going to say that Jane's mother referred to Jane as Epstein's goddaughter and that that actually caused a reaction, that people in the office treated her a certain way because that's how she represented Jane to be. I'm not offering it for the truth, it's simply the effect on this listener and how she responded to Jane's mother when she was in the office.
MS. POMERANTZ: No objection.
JUDGE NATHAN: Do you want a limiting?
MS. POMERANTZ: It's fine, your Honor.
JUDGE NATHAN: Do you want a limiting?
MR. EVERDELL: I don't think so your Honor.
(Continued on next page)
(In open court)
MS. POMERANTZ: Objection withdrawn, your Honor.
BY MR. EVERDELL:
MR. EVERDELL: Let me ask you this, Ms. Espinosa, how did Jane's mother refer to Jane among the people in the office?
CIMBERLY ESPINOSA: Jane's mother said --
JUDGE NATHAN: Could you pull up to the mic, please. A. Jane's mother said that Jane was Jeffrey's goddaughter.
MR. EVERDELL: And how did that, if at all, affect the interactions of the people in the office with Jane and Jane's mother?
CIMBERLY ESPINOSA: Well, I know from myself and the girls that worked in the office, you know, she was treated with the utmost respect, kind of considered her family of Jeffrey's. So, you know, we always treated everyone that came in with courtesy and professionalism and respect, but given that we thought Jane was the goddaughter, she was just a little extra special.
MR. EVERDELL: Did Jane have any siblings?
MR. EVERDELL: Were they brothers, sisters, do you remember?
CIMBERLY ESPINOSA: Two brothers.
MR. EVERDELL: Again without saying their names, did they ever visit the office?
CIMBERLY ESPINOSA: I don't recall.
MR. EVERDELL: About how much contact would Jane's mother have with Epstein during the time period when they were in contact?
MS. POMERANTZ: Objection, your Honor. Foundation.
JUDGE NATHAN: Sustained.
MR. EVERDELL: You said you received calls from Jane's mother; right?
CIMBERLY ESPINOSA: Uh-huh.
MR. EVERDELL: And you said that she sometimes visited the office; is that right?
CIMBERLY ESPINOSA: Correct.
MR. EVERDELL: Do you recall over what span of time this occurred?
MR. EVERDELL: Do you know if Jane ever traveled on Mr. Epstein's planes?
CIMBERLY ESPINOSA: I don't know.
MR. EVERDELL: What was your impression of the relationship between Jane and Epstein?
MS. POMERANTZ: Objection.
JUDGE NATHAN: One word, grounds.
MS. POMERANTZ: Foundation.
JUDGE NATHAN: You can ask a foundation question.
MR. EVERDELL: Did you ever see Jane interact with Epstein in the office?
MR. EVERDELL: And how often did you see that interaction, how many times?
CIMBERLY ESPINOSA: Maybe three or four.
MR. EVERDELL: Based on those three or four interactions, what was your impression of the relationship between Jane and Epstein?
CIMBERLY ESPINOSA: I felt it was a loving relationship.
MR. EVERDELL: Did there come a time when Jane stopped visiting the office?
MR. EVERDELL: Do you know why that was?
CIMBERLY ESPINOSA: I think it was because she went to go work in California for a soap opera.
MR. EVERDELL: And how do you know that she ended up working for a soap opera?
CIMBERLY ESPINOSA: She told me and I also saw it myself, because it's one of my soap operas I watched my entire life.
MR. EVERDELL: Are you a fan of this particular soap opera?
CIMBERLY ESPINOSA: Big time.
MR. EVERDELL: And did you see Jane on the soap opera?
MR. EVERDELL: After she moved to LA and was on the soap opera, did you have any continuing contact with Jane?
CIMBERLY ESPINOSA: Only when she would call the office.
MR. EVERDELL: Any other type of contact with Jane after she stopped coming to the office and was in LA?
CIMBERLY ESPINOSA: Yes. She sent me a little envelope with headshots, signed headshots of the cast from the soap opera, a few single headshots and then the whole cast all signed.
MR. EVERDELL: Is that something that you asked for or did she send that to you as a gift?
CIMBERLY ESPINOSA: I think it was a gift.
MR. EVERDELL: Do you remember roughly when she sent you those headshots?
CIMBERLY ESPINOSA: I don't recall. I don't know. I've held onto them for very many years.
MR. EVERDELL: One moment, your Honor. Your Honor, I would like to approach the witness and show her some exhibits marked for identification. I have a copy for the Court, as well.
JUDGE NATHAN: Okay. Marked for identification as?
MR. EVERDELL: Marked for identification as defendant's CE3, CE4, CE5, CE6, CE7, and CE8. May I approach, your Honor?
JUDGE NATHAN: You may.
BY MR. EVERDELL:
MR. EVERDELL: Ms. Espinosa, if you could take the documents I just handed you and look at them, the documents that are marked for identification as CE3 through CE8. Have you had the chance to look at them?
MR. EVERDELL: Do you recognize what those are?
MR. EVERDELL: Sorry. I couldn't hear you.
MR. EVERDELL: And what are they?
CIMBERLY ESPINOSA: They are the headshots of three of the cast members and then a group cast member shot.
MR. EVERDELL: And is the envelope also there, too?
CIMBERLY ESPINOSA: The envelope is here, yes.
MR. EVERDELL: Are they the headshots that were sent to you and is that the envelope that they were sent in?
MR. EVERDELL: And how do you recognize these?
CIMBERLY ESPINOSA: They're mine. I've had them forever.
MR. EVERDELL: Have you had them in your possession since you received them?
MR. EVERDELL: And are they in the same or substantially the same condition as when you first received them?
MR. EVERDELL: Your Honor, at this time, the defense moves to admit CE3 through CE8, temporarily under seal so we can apply appropriate redactions to protect the privacy interests of witnesses.
MS. POMERANTZ: No objection, your Honor.
JUDGE NATHAN: CE3 through 8 are admitted temporarily under seal for the purpose of protecting the anonymity of a witness who I've permitted to testify under pseudonym. (Defendant's Exhibits CE3 through CE8 received in evidence)
MR. EVERDELL: Correct, your Honor. Your Honor, at this time, I do have copies for the jurors if the Court will permit me to hand them out.
JUDGE NATHAN: Thank you.
MR. EVERDELL: Ms. Espinosa, let's first take a look --
JUDGE NATHAN: I think they're waiting for me. Would you like the jurors to look?
MR. EVERDELL: Yes. May I publish this to the jurors, your Honor?
JUDGE NATHAN: So the jurors may look at the exhibits in the folder. Go ahead.
BY MR. EVERDELL:
MR. EVERDELL: Look first at CE3. Do you see what that is? Actually, can you hold that up? What is CE3?
CIMBERLY ESPINOSA: CE3 is a manilla envelope addressed to Ms. Cimberly, care of Epstein & Co., 457 Madison Avenue, from Jane.
MR. EVERDELL: Is there a date on the envelope?
CIMBERLY ESPINOSA: You can't read what the postage machine -- you can't see it.
JUDGE NATHAN: Just my copy of the envelope doesn't have a mark.
MR. EVERDELL: Understood. The physical copy of the exhibit is what has the sticker on it. I don't know if we were able to copy the entire thing because it's a large envelope.
JUDGE NATHAN: Do you want to direct the jurors to look at a photocopy of an envelope and that is what you're indicating is CE3?
MR. EVERDELL: Well, your Honor, I'm actually having the witness hold up the envelope itself, which is CE3. The photocopies are just copies of the envelope.
CIMBERLY ESPINOSA: It says CE3.
JUDGE NATHAN: Got it.
MR. EVERDELL: Just hold up the envelope so the jurors can see it. Is that the envelope that the headshots came in?
MR. EVERDELL: And can you tell from the envelope what the postmark date is or is it too hard to tell at this point?
CIMBERLY ESPINOSA: Can't tell.
MR. EVERDELL: You can set that down. Let's look at CE4, and I don't want you to hold that up, but you have the original photograph there; correct?
MR. EVERDELL: And the jurors have photocopies. First of all, who is in that photograph, using only the names we've agreed upon?
CIMBERLY ESPINOSA: Jane.
MR. EVERDELL: And is there an inscription on the front of that photograph?
CIMBERLY ESPINOSA: There is.
MR. EVERDELL: Without reading the name --
MR. EVERDELL: One moment, your Honor.
MR. EVERDELL: Without reading the name on the inscription, can you just read out the inscription on the front of the photograph?
CIMBERLY ESPINOSA: To Cimberly, with love, Jane.
MR. EVERDELL: Is there anything written on the back of the photograph that is CE4?
MR. EVERDELL: Again, substituting the name we've agreed upon, can you read out that inscription?
CIMBERLY ESPINOSA: Dearest Cimberly, thank you for always being so sweet and such a great help. Take care. Jane.
MR. EVERDELL: And just looking quickly at the others in succession, which is CE5, CE6, CE7, and CE8, what are those?
CIMBERLY ESPINOSA: They are photos, a group shot of the cast of the soap opera and three separate headshots of three of the actors.
MR. EVERDELL: And those actors are not Jane; right?
CIMBERLY ESPINOSA: Correct.
MR. EVERDELL: And just looking briefly at CE5, do you see Jane in that group shot?
MR. EVERDELL: And where do you see her?
CIMBERLY ESPINOSA: Middle row, all the way to the right.
MR. EVERDELL: So are these photographs in the envelope we just looked at what Jane sent you after she started working at the soap opera?
MR. EVERDELL: Thank you. You can put those away now.
MR. EVERDELL: With the Court's permission, I'll have the jurors put those down.
JUDGE NATHAN: Yes, please. You can put those under your seats. Thank you so much.
MR. EVERDELL: Your Honor, shall I continue? Okay.
BY MR. EVERDELL:
MR. EVERDELL: Ms. Espinosa, are you familiar with the address 301 East 66th Street?
MR. EVERDELL: And what is at that address?
CIMBERLY ESPINOSA: That is an apartment building.
MR. EVERDELL: Did you have any job responsibilities with respect to that apartment building?
MR. EVERDELL: Can you describe what those were?
CIMBERLY ESPINOSA: Sure. First it was managing the scheduling of the apartments, like a calendar, if you will. There was approximately a dozen apartments that Jeffrey Epstein owned, and there were employees that stayed there, family, friends, guests.
MR. EVERDELL: And when you say you managed the calendar, what do you mean by that?
CIMBERLY ESPINOSA: Well, that we had a notebook that told us who was staying in what apartment on any day, that way we would know what apartment was available to give to someone else.
MR. EVERDELL: And was your responsibility to manage that calendar?
MR. EVERDELL: Do you remember any of the names of the people who had regular apartments in that building, who regularly stayed there?
MR. EVERDELL: Who were some of those people?
CIMBERLY ESPINOSA: Jeffrey Epstein's pilots had apartments there. Jane stayed there, Jane's mother, Jane's brothers. We had -- let's see. There were some other executives that Jeffrey knew. Can't really recall other names. Shelly Lewis had an apartment there for a while.
MR. EVERDELL: Who was Shelly Lewis?
CIMBERLY ESPINOSA: Shelly was one of Jeffrey's friends, I guess.
MR. EVERDELL: Okay. Do you know if Emmy Taylor ever had an apartment there?
CIMBERLY ESPINOSA: Emmy Taylor had an apartment there.
(Continued on next page)
BY MR. EVERDELL:
MR. EVERDELL: Now, you mentioned that Jane and Jane's mother and Jane's brothers used the apartments; is that right?
MR. EVERDELL: Were they regular users of the apartments or did they use it every -- how many times did they use it?
CIMBERLY ESPINOSA: They were regular for a duration of time, and then it was come and go, specifically for the brothers and the mother.
MR. EVERDELL: About when do you recall Jane and Jane's mother and brothers using the apartments in New York?
CIMBERLY ESPINOSA: It was right around when I had met her. Again, I don't recall the date, but I know that it was towards the beginning of my -- beginning to middle of my term there.
MR. EVERDELL: All right. So if the beginning of your term was the end of 1996 --
CIMBERLY ESPINOSA: Right.
MR. EVERDELL: -- what, roughly, years are we talking about here, if you can estimate?
CIMBERLY ESPINOSA: Maybe late '90s, early 2000.
MR. EVERDELL: Okay. The best of your recollection?
CIMBERLY ESPINOSA: Yeah.
MR. EVERDELL: All right. Let's discuss your observations of the relationship between Epstein and Ghislaine. As part of working in the office with Ghislaine, were you able to observe Jeffrey Epstein and Ghislaine interacting with each other?
CIMBERLY ESPINOSA: Sure.
MR. EVERDELL: And when you first started in your job in 1996, what was your impression of the relationship between Epstein and Ghislaine?
CIMBERLY ESPINOSA: I thought they were a couple.
MR. EVERDELL: And what gave you that impression?
CIMBERLY ESPINOSA: Just their interaction together. They were a little flirty; and I just knew they were a couple, behaved like a couple.
MR. EVERDELL: Did their romantic relationship change at all during the time you worked for Epstein?
MR. EVERDELL: How so?
CIMBERLY ESPINOSA: They just kind of went their separate ways. Seems like Ghislaine moved on. I know that she started dating --
MS. POMERANTZ: Objection. Foundation.
JUDGE NATHAN: Sustained.
MR. EVERDELL: What, if anything, did you observe at the time that indicated to you that the romantic relationship was changing?
CIMBERLY ESPINOSA: Ghislaine started dating.
MR. EVERDELL: Dating other men?
CIMBERLY ESPINOSA: Yes, other men.
MR. EVERDELL: Okay. Anything else?
CIMBERLY ESPINOSA: Well, they would not show up at the office around the same time or leave together, things like that.
MR. EVERDELL: Okay. And roughly when do you recall noticing that Ghislaine was dating other men and not coming to the office as much?
CIMBERLY ESPINOSA: That would be probably the last two years of my employment.
MR. EVERDELL: Now, you mentioned that Epstein had visitors come to his office, right?
CIMBERLY ESPINOSA: Mm-hmm.
MR. EVERDELL: And I think you said some of these were female.
CIMBERLY ESPINOSA: Mm-hmm.
MR. EVERDELL: We've talked about Jane. But apart from Jane, how old were these females who were visiting Jeffrey Epstein in the office during your time there?
CIMBERLY ESPINOSA: I don't know how old they were.
MR. EVERDELL: Roughly, how old do they appear to you to be?
CIMBERLY ESPINOSA: Eighteen and over. Young women.
MR. EVERDELL: And what contact did you see them -- withdrawn. Do you remember some of the names of these women who came and visited Epstein in the office?
MR. EVERDELL: Sorry?
CIMBERLY ESPINOSA: I do remember.
MR. EVERDELL: What names do you recall?
CIMBERLY ESPINOSA: Celina Midelfart; Shelly Lewis; Jane, of course; Gwendolyn Beck.
MR. EVERDELL: Well --
CIMBERLY ESPINOSA: There were others. There were others, I just can't remember.
MR. EVERDELL: And what kind of contact did they have with Jeffrey Epstein that you observed when they came into the office?
CIMBERLY ESPINOSA: I didn't really observe the guests and him together too often, because most of the time it was them being escorted to his office. And the door would shut and they would visit in his office, and I wouldn't see that.
MR. EVERDELL: Okay. Now, you mentioned Celina Midelfart before.
MR. EVERDELL: Were you ever asked to do anything for Celina Midelfart?
MR. EVERDELL: What was that?
CIMBERLY ESPINOSA: Send her flowers.
MR. EVERDELL: And what kind of flowers were these?
CIMBERLY ESPINOSA: I recall an orchid at one time. There might have been another bouquet another time.
MR. EVERDELL: Based on your -- the tasks you were given for her and your observations of her, did you ever get the impression that there was a romantic relationship?
MS. POMERANTZ: Objection, your Honor.
JUDGE NATHAN: One-word grounds.
MS. POMERANTZ: Calls for speculation.
JUDGE NATHAN: Overruled.
MR. EVERDELL: Ms. Espinosa, based on the tasks you were given for Ms. Midelfart and your observations of her with Epstein, what, if any, sense did you have of their relationship with each other, put it that way?
CIMBERLY ESPINOSA: I felt like Jeffrey liked her very much; I felt like they were a couple. They were -- yeah, they were together, a couple.
MR. EVERDELL: And did this happen either during or after the time when it appeared to you that Ghislaine was in a romantic relationship with Epstein?
CIMBERLY ESPINOSA: I feel like it was at the very beginning of my employment, so I -- you know, being new, it could have been concurrent for a little bit of time.
MR. EVERDELL: Do you know whether or not Ghislaine knew about, for example, you buying the flowers for Celina Midelfart?
CIMBERLY ESPINOSA: No, she didn't know.
MS. POMERANTZ: Objection.
JUDGE NATHAN: Just a moment. I'll allow it.
MR. EVERDELL: Do you know whether or not Ghislaine Maxwell knew about you buying flowers for Celina Midelfart on behalf of Jeffrey Epstein?
CIMBERLY ESPINOSA: She did not know.
MR. EVERDELL: You also mentioned Shelly Lewis before.
MR. EVERDELL: Do you remember what nationality she was?
CIMBERLY ESPINOSA: English.
MR. EVERDELL: Did she speak in a British accent?
MR. EVERDELL: All right. I want to direct your attention now to the final years of your employment, okay, so roughly 2000 to 2002, all right? Were Epstein and Ghislaine still involved in a romantic relationship or was that over by this time?
CIMBERLY ESPINOSA: I think it was over by that time.
MR. EVERDELL: Was Ghislaine still working for Epstein at that time?
MR. EVERDELL: Did her employment role for Epstein stay the same at this time or did it change at this time?
CIMBERLY ESPINOSA: Stayed the same.
MR. EVERDELL: Okay. Did she have as much involvement in his affairs or were other people working for Epstein as well?
CIMBERLY ESPINOSA: Well, there were other people working for Epstein. I don't know.
MR. EVERDELL: Let me ask this: How often was Ghislaine coming into the office in the latter two years of your employment?
CIMBERLY ESPINOSA: Not often. It started -- you know, at first it was almost every day; then it became a few times a week; and then it was -- towards the end it was full-time she wasn't coming into the office.
MR. EVERDELL: Okay. Was there anyone else who was in the office who, for example, was sitting in the office where Ghislaine used to sit?
CIMBERLY ESPINOSA: That would have been Sarah Kellen.
MR. EVERDELL: Sarah who?
CIMBERLY ESPINOSA: Kellen.
MR. EVERDELL: Okay. I want to show you what's already in evidence as Government's Exhibit 327.
MR. EVERDELL: If we can put that on the screen.
JUDGE NATHAN: You may.
MR. EVERDELL: Thank you, your Honor. For the Court, deputy, the witness, and the jurors, with the Court's permission.
JUDGE NATHAN: It's a public document; correct?
MR. EVERDELL: It's not under seal, your Honor, as far as I know.
JUDGE NATHAN: Correct?
MS. POMERANTZ: I believe that's correct, your Honor.
MR. EVERDELL: We'll just confer with the government.
MS. POMERANTZ: Just take a quick look, your Honor. It's fine, your Honor. Thank you.
JUDGE NATHAN: Okay. So you can publish.
MR. EVERDELL: Thank you, your Honor. So we'll also put it on the jurors' screens, if we could.
BY MR. EVERDELL:
MR. EVERDELL: Ms. Espinosa, do you see the person in that photograph, Government's Exhibit 327?
MR. EVERDELL: Do you recognize who that is?
MR. EVERDELL: Who is that?
CIMBERLY ESPINOSA: That's Sarah Kellen.
MR. EVERDELL: Do you remember --
MR. EVERDELL: We can put that down now, with the Court's permission.
JUDGE NATHAN: Yes. Thank you.
MR. EVERDELL: Do you remember when Sarah Kellen was hired, when she first arrived?
CIMBERLY ESPINOSA: I don't remember the date.
MR. EVERDELL: Was it towards the beginning or towards the end of your employment, if you know?
CIMBERLY ESPINOSA: Towards the end.
MR. EVERDELL: Was it in the time period we're discussing now, 2000 to 2002?
MR. EVERDELL: What was her job for Epstein?
CIMBERLY ESPINOSA: I'm not sure what her job was, but she did accompany Jeffrey around to the properties and was basically where he was. I didn't really work with her much in the office, so I don't know what her -- her job was.
MR. EVERDELL: From your perspective, did she assist Epstein?
MR. EVERDELL: Okay. Now, was she, in your mind, Epstein's assistant or was she Ghislaine's assistant?
CIMBERLY ESPINOSA: Epstein's assistant.
MR. EVERDELL: Okay. Who was Ghislaine's assistant?
CIMBERLY ESPINOSA: I was still there. I was Ghislaine's assistant.
MR. EVERDELL: Okay. Now, in the 2000s, did Ghislaine still travel with Epstein to the properties?
CIMBERLY ESPINOSA: I believe so.
MR. EVERDELL: Okay. Do you know, did she travel to Palm Beach occasionally?
CIMBERLY ESPINOSA: Sure.
MR. EVERDELL: Did you help her arrange her travel when she traveled to Florida?
CIMBERLY ESPINOSA: Sometimes.
MR. EVERDELL: And when she traveled to Florida at this time, did she always go to Palm Beach or did she go to other locations?
CIMBERLY ESPINOSA: She visited other locations.
MR. EVERDELL: Where did she --
CIMBERLY ESPINOSA: Miami.
MR. EVERDELL: I'm sorry?
CIMBERLY ESPINOSA: Miami, Florida. Miami.
MR. EVERDELL: And how do you know that she was going to Miami?
CIMBERLY ESPINOSA: Because she asked me to book a flight for her to Miami.
MR. EVERDELL: Did you help her arrange where she stayed in Miami too?
CIMBERLY ESPINOSA: I sort of recall, but I -- I -- it was a hotel. I don't remember the name.
MR. EVERDELL: Okay. But your recollection is you booked hotels for her to stay in in Miami when she was traveling to Florida?
CIMBERLY ESPINOSA: Yes. I also think she had a friend there that she may have stayed in -- in the condo or whatever it was.
MR. EVERDELL: So when she was traveling to Florida around this time, was she always staying at Epstein's residence or did she stay at hotels?
MS. POMERANTZ: Objection. Foundation.
JUDGE NATHAN: Sustained.
MR. EVERDELL: Fair to say you booked hotels in Miami for her travel to Florida around this time, right?
CIMBERLY ESPINOSA: Correct.
MR. EVERDELL: Now, you mentioned that Ghislaine was dating other men in the 2000s, right?
CIMBERLY ESPINOSA: Mm-hmm.
MR. EVERDELL: Are you familiar with a man named Ted Waitt?
MR. EVERDELL: Who is Ted Waitt?
CIMBERLY ESPINOSA: Ted Waitt is somebody that she dated and eventually became a couple with.
MR. EVERDELL: All right. And do you know who Ted Waitt was, what his job was?
CIMBERLY ESPINOSA: I didn't know what his job was or who he was until I met him personally after I had already left Epstein and Company.
MR. EVERDELL: When did you meet Ted Waitt personally?
CIMBERLY ESPINOSA: Boy. 2009, '8, something like that. I don't recall the year.
MR. EVERDELL: And was Ghislaine still with Ted Waitt as a couple at that time?
MR. EVERDELL: Okay. And that was how many years after you left your employment with Epstein, roughly?
CIMBERLY ESPINOSA: Maybe three years, something like that.
MR. EVERDELL: I think you said you left in 2002; is that right?
CIMBERLY ESPINOSA: Correct.
MR. EVERDELL: And when do you think you met Ted Waitt?
CIMBERLY ESPINOSA: Before 2010. That's all I can really say.
MR. EVERDELL: And why was it that you were meeting Ted Waitt at that time?
CIMBERLY ESPINOSA: For a job interview.
MR. EVERDELL: Okay. Did Ghislaine help to arrange that job interview?
MR. EVERDELL: Okay. And what was the job?
CIMBERLY ESPINOSA: It was like an estate manager.
MR. EVERDELL: Did you end up getting the job?
MR. EVERDELL: Okay. Do you know if Ted Waitt had any children at the time you met with him?
CIMBERLY ESPINOSA: I don't --
MS. POMERANTZ: Objection. A. I don't know.
JUDGE NATHAN: The response was "I don't know." I'll allow that. Move on.
MR. EVERDELL: And just jumping back, do you recall roughly when it was that Ghislaine started seeing Ted Waitt as a couple?
CIMBERLY ESPINOSA: Well, it was before I left in 2002. Maybe --
JUDGE NATHAN: Could you speak into the mic? A. It was before I left in 2002, so probably 2001 or so.
MR. EVERDELL: The best guess from your recollection?
CIMBERLY ESPINOSA: Best guess.
JUDGE NATHAN: Mr. Everdell, we'll break here for the morning, unless --
MR. EVERDELL: Actually, if I could just have one moment, your Honor.
JUDGE NATHAN: Sure.
(Counsel conferred with defendant)
MR. EVERDELL: I think it's a good time to take a break, your Honor, if we could.
JUDGE NATHAN: How much longer do you anticipate?
MR. EVERDELL: I don't think I have very much, but I just wanted the chance to confer.
JUDGE NATHAN: All right. So we'll break for 15 minutes, members of the jury. See you shortly. Thank you.
(Jury not present)
JUDGE NATHAN: Ms. Espinosa, you may step down and out for the break. Thank you.
(Witness not present)
JUDGE NATHAN: Counsel, matters to take up before the break?
MS. POMERANTZ: Not from the government.
MR. EVERDELL: Nothing from the defense.
JUDGE NATHAN: I'll see you in ten in case there's anything to discuss before we resume.
(Recess)
JUDGE NATHAN: Anything to take up?
MR. EVERDELL: Not from the defense, your Honor.
MS. POMERANTZ: Not from the government. Thank you.
JUDGE NATHAN: All right. We can bring the witness back and we can get the jury.
(Witness present)
(Jury present)
JUDGE NATHAN: All right. Thank you, members of the jury. Mr. Everdell, you may continue with your direct examination of Ms. Espinosa. Ms. Espinosa, I remind you, you are under oath. Go ahead, Mr. Everdell.
MR. EVERDELL: Thank you, your Honor.
BY MR. EVERDELL:
MR. EVERDELL: Ms. Espinosa, directing your attention again to the end of your employment term, okay, in the 2000s, when -- the time period when you said Ghislaine was moving on, right, did you ever assist her during that time in hiring any other personnel at the office?
CIMBERLY ESPINOSA: I don't remember.
MR. EVERDELL: Who was taking care of the properties, Epstein's properties, on a day-to-day basis at the properties?
CIMBERLY ESPINOSA: Sarah Kellen.
MR. EVERDELL: Did you ever assist in hiring any other people to help assist with properties at that time?
CIMBERLY ESPINOSA: Not that I recall.
MR. EVERDELL: Okay. But your recollection is that Sarah Kellen was managing the properties at that time?
CIMBERLY ESPINOSA: Mm-hmm.
MR. EVERDELL: Speaking of Sarah Kellen, do you know if she ever got married?
CIMBERLY ESPINOSA: I heard that she got married.
MS. POMERANTZ: Objection, your Honor.
JUDGE NATHAN: Sustained. The jury will disregard.
MR. EVERDELL: Ms. Espinosa, were you ever contacted by the government in this case, by the prosecutors?
MR. EVERDELL: And did you sit down for an interview with those prosecutors in the case?
MR. EVERDELL: Do you recall when that was?
CIMBERLY ESPINOSA: I think it was during the summer of this year.
MR. EVERDELL: Do you remember the first time you sat down with them? Or this may have been a videoconference?
CIMBERLY ESPINOSA: It was a videoconference.
MR. EVERDELL: Do you remember when that videoconference occurred?
MR. EVERDELL: I want to show you something that may refresh your recollection. Do you see the folder that's below you on the floor next to the chair?
MR. EVERDELL: With the Court's permission, I'll have her turn to 3501.063-002, which should be behind tab 2 of your materials.
JUDGE NATHAN: Ms. Pomerantz, are you there?
MS. POMERANTZ: Yes, your Honor.
JUDGE NATHAN: Okay. Go ahead.
MR. EVERDELL: Do you have that document in front of you?
MR. EVERDELL: And if you could just look down at the bottom of the page where there is some information on the left-hand side. Does that refresh your recollection of when you had the videoconference with the government?
CIMBERLY ESPINOSA: Last year, I think. So repeat your question please.
MR. EVERDELL: Does that refresh your recollection of when you had this videoconference for the first time with the government?
CIMBERLY ESPINOSA: Yes, well, there's a date on here.
MR. EVERDELL: And does that generally refresh your recollection about when this would have happened?
MR. EVERDELL: Okay. And when did that happen?
CIMBERLY ESPINOSA: November 2020.
MR. EVERDELL: Okay. All right. Was that the only time you spoke to the government in this case?
MR. EVERDELL: Okay. Question about Ghislaine. In the time that you worked for Ghislaine Maxwell from 1996 to 2002, did you ever see Ms. Maxwell pregnant?
MR. EVERDELL: Ever were told that Ms. Maxwell was pregnant?
MS. POMERANTZ: Objection, your Honor.
JUDGE NATHAN: Overruled.
MR. EVERDELL: Ms. Espinosa, you said you left the job in roughly 2002; is that right?
CIMBERLY ESPINOSA: Correct.
MR. EVERDELL: Why did you decide to leave at that time?
CIMBERLY ESPINOSA: After 9/11, I had decided that it was time for me to move back to my roots; wanted to be with my family. My brother had his first child, and I just wanted to go back to where I came from.
MR. EVERDELL: And where was that?
CIMBERLY ESPINOSA: California.
MR. EVERDELL: Okay. When you left, did you continue to stay in touch with Ghislaine after you left?
MR. EVERDELL: Looking back on your experience working with Ghislaine, what are your impressions about the job and about Ghislaine?
CIMBERLY ESPINOSA: I feel like Ghislaine was a very good resource for my own career as far as experience and what I learned from her as far as how to handle multiple projects at one time at a fast pace. I think it helped me to get to where I am today in my job.
MR. EVERDELL: And what, if any, are your personal feelings and reflections about your job?
MS. POMERANTZ: Objection, your Honor.
JUDGE NATHAN: Sustained.
MR. EVERDELL: Besides your career path, are there any other reflections you have on your experience with Ms. Maxwell?
MS. POMERANTZ: Objection.
JUDGE NATHAN: Sustained.
MR. EVERDELL: In the time -- Ms. Espinosa, you are aware of the crimes that Ghislaine is accused of committing in this case?
MR. EVERDELL: In the time that you worked for Ghislaine, did you ever see her engage in any kind of inappropriate activity with underage girls?
CIMBERLY ESPINOSA: Never.
MR. EVERDELL: Did you ever see Jeffrey Epstein engage in inappropriate activity with underage girls?
CIMBERLY ESPINOSA: Never.
MR. EVERDELL: Did you ever see anything at all in the six years that you worked for Ghislaine that gave you the impression that anything like that was going on?
CIMBERLY ESPINOSA: Never. No.
MR. EVERDELL: One moment, your Honor.
JUDGE NATHAN: Okay.
(Counsel conferred)
MR. EVERDELL: I have no further questions, your Honor.
JUDGE NATHAN: All right. Ms. Pomerantz.
MS. POMERANTZ: Yes. Briefly, your Honor.
JUDGE NATHAN: Go ahead.
CROSS-EXAMINATION BY MS. POMERANTZ:
MS. POMERANTZ: Good afternoon, Ms. Espinosa.
MS. POMERANTZ: You worked out of Jeffrey Epstein's Madison Avenue office in Manhattan, right?
CIMBERLY ESPINOSA: Correct.
MS. POMERANTZ: You did not work out of any of Jeffrey Epstein's homes, right?
CIMBERLY ESPINOSA: Correct.
MS. POMERANTZ: You never went to Jeffrey Epstein's Palm Beach house, right?
CIMBERLY ESPINOSA: Correct.
MS. POMERANTZ: No further questions, your Honor.
JUDGE NATHAN: Okay. Anything?
MR. EVERDELL: No redirect, your Honor.
JUDGE NATHAN: All right. Thank you, Ms. Espinosa. You may step down. You are excused. Thank you.
(Witness excused)
JUDGE NATHAN: Mr. Everdell, the defense may call its next witness.
MR. EVERDELL: Yes, your Honor. The defense calls Mr. Raghu Sud. That's R-A-G-H-U, S-U-D.
JUDGE NATHAN: Okay. Mr. Sud may come forward. RAGHU SUD, called as a witness by the Defendant, having been duly sworn, testified as follows:
JUDGE NATHAN: Thank you. Mr. Everdell, you may inquire.
MR. EVERDELL: Thank you, your Honor.