Tracy Chapell — Direct/Cross
447 linesDIRECT EXAMINATION BY MR. ROHRBACH:
MR. ROHRBACH: Good morning, Ms. Chapell.
TRACY CHAPELL: Good morning.
MR. ROHRBACH: Ms. Chapell, where do you work?
TRACY CHAPELL: Federal Express Corporation.
MR. ROHRBACH: How long have you worked there?
TRACY CHAPELL: One year.
MR. ROHRBACH: What's your position at Federal Express?
TRACY CHAPELL: Senior paralegal.
JUDGE NATHAN: Mr. Rohrbach, could you pull the mic up a little please. Thank you.
MR. ROHRBACH: Of course. I apologize, your Honor.
JUDGE NATHAN: Thank you.
MR. ROHRBACH: And what are your duties and responsibilities as a senior paralegal at FedEx?
TRACY CHAPELL: To respond to subpoenas and produce the records of Federal Express.
MR. ROHRBACH: And as part of your job, are you familiar with Federal Express's recordkeeping practices?
TRACY CHAPELL: Yes.
MR. ROHRBACH: In particular, are you familiar with the business practices regarding billing invoices?
TRACY CHAPELL: Yes.
MR. ROHRBACH: How are billing invoices generated?
TRACY CHAPELL: They are generated through the scanning events and then populated through the revenue service department.
MR. ROHRBACH: Can you explain what you mean by scanning events?
TRACY CHAPELL: Well, each movement of the package is scanned so it can be tracked through the system as to where the package is. Once it meets the final delivery spot, then that final scan will generate an invoice.
MR. ROHRBACH: What sort of information is contained in an invoice?
TRACY CHAPELL: The account number, the invoice number, the invoice date, the account holder information, and the amount of the shipment.
MR. ROHRBACH: Does FedEx keep billing invoices in the ordinary course of business?
TRACY CHAPELL: Yes.
MR. ROHRBACH: And is making invoices a regular practice of FedEx?
TRACY CHAPELL: Yes.
MR. ROHRBACH: Ms. Chapell, in the binder next to you, would you please look at what's been marked for identification as Government Exhibit 801. Do you recognize this?
TRACY CHAPELL: Yes.
MR. ROHRBACH: What is it?
TRACY CHAPELL: It's a invoice on Jeffrey E. Epstein's account.
MR. ROHRBACH: Have you reviewed this before today?
TRACY CHAPELL: Yes.
MR. ROHRBACH: Is it a fair and accurate copy of an invoice held by FedEx?
TRACY CHAPELL: Yes.
MR. ROHRBACH: Your Honor, the government offers Government Exhibit 801 under seal to protect third-party and pseudonym-protected witnesses, and Government Exhibit 801-R not under seal.
MR. EVERDELL: No objection.
JUDGE NATHAN: All right. GX-801 is admitted under seal for the reason indicated. And 801-R is admitted as a public exhibit. (Government's Exhibits 801, 801-R received in evidence)
BY MR. ROHRBACH:
MR. ROHRBACH: Ms. Chapell, would you turn to Government Exhibit 802, what's been marked for identification as Government Exhibit 802 in your binder.
TRACY CHAPELL: Okay.
MR. ROHRBACH: And do you recognize this?
TRACY CHAPELL: Yes.
MR. ROHRBACH: What is it?
TRACY CHAPELL: Invoice on Jeffrey E. Epstein's account.
MR. ROHRBACH: Have you reviewed this before today?
TRACY CHAPELL: Yes.
MR. ROHRBACH: And is it a fair and accurate copy of the version held by FedEx?
TRACY CHAPELL: Yes.
MR. ROHRBACH: Your Honor, the government offers Government Exhibit 802 under seal for the same reasons, and Government Exhibit 802-R without any sealing.
MR. EVERDELL: No objection.
JUDGE NATHAN: All right. 802 is admitted under seal for the reason indicated. 802-R is admitted as a public exhibit. (Government's Exhibits 802, 802-R received in evidence)
BY MR. ROHRBACH:
MR. ROHRBACH: And finally, Ms. Chapell, would you turn to what's been marked for identification as Government Exhibit 803.
TRACY CHAPELL: Okay.
MR. ROHRBACH: Do you recognize this?
TRACY CHAPELL: Yes.
MR. ROHRBACH: And what is it?
TRACY CHAPELL: Invoice on Jeffrey E. Epstein's account.
MR. ROHRBACH: Have you reviewed it before today?
TRACY CHAPELL: Yes.
MR. ROHRBACH: And is this a fair and accurate copy of the version held by Federal Express?
TRACY CHAPELL: Yes.
MR. ROHRBACH: Your Honor, the government offers Government Exhibit 803 under seal for the same reasons, and Government Exhibit 803-R to the public.
MR. EVERDELL: No objection.
JUDGE NATHAN: GX-803 is admitted under seal; 803-R is admitted as a public exhibit. (Government's Exhibits 803, 803-R received in evidence)
MR. ROHRBACH: With your Honor's permission, may I publish the documents?
JUDGE NATHAN: Yes, you may publish the R versions.
MR. ROHRBACH: Yes. Ms. Drescher, will you please pull up Government Exhibit 801-R for everyone.
BY MR. ROHRBACH:
MR. ROHRBACH: Ms. Chapell, would you please turn to Government Exhibit 801 in your binder.
MR. ROHRBACH: And with the Court's permission, I would ask that the jury be instructed to turn to Exhibit 801 in their binders.
JUDGE NATHAN: Okay. Is it the large binder?
MR. ROHRBACH: My understanding, there's one binder.
JUDGE NATHAN: Okay. The only binder, 801 -- GX-801, please.
MR. ROHRBACH: Now that we're looking at it, Ms. Chapell, who is the account holder on this invoice?
TRACY CHAPELL: Jeffrey E. Epstein.
MR. ROHRBACH: And turning now to page 5 of the invoice and looking at the top row of the invoice.
TRACY CHAPELL: Okay.
MR. ROHRBACH: Who is the sender of this package?
TRACY CHAPELL: S. Kellen, and underneath it's Jeffrey E. Epstein.
MR. ROHRBACH: And what is the sender address?
TRACY CHAPELL: It is 457 Madison Avenue, New York, New York, 10022.
MR. ROHRBACH: And without saying any names, without saying the last name of the recipient, what is the first name of the recipient?
TRACY CHAPELL: Carolyn.
MR. ROHRBACH: And where is the city and state of the delivery?
TRACY CHAPELL: West Palm Beach, Florida.
MR. ROHRBACH: Thank you.
MR. ROHRBACH: And with the Court's permission, I would ask the jurors to hold their place here and turn to Government Exhibit 11 for a moment, which is in evidence.
MR. EVERDELL: No objection.
JUDGE NATHAN: All right. Please look at GX-11, and then turn back to this page.
MR. ROHRBACH: And on GX-11 we would direct the jury's attention to the date of birth.
JUDGE NATHAN: Okay. Okay. So you've looked at GX-11. And then you'll go back to GX-803.
MR. ROHRBACH: 801, your Honor.
JUDGE NATHAN: I'm sorry. 801. Apologies.
BY MR. ROHRBACH:
MR. ROHRBACH: Ms. Chapell, what is the date that this package was sent?
TRACY CHAPELL: It was picked up to be shipped on December 3rd, 2002.
MR. ROHRBACH: Keeping in mind the recipient's address, Ms. Chapell, I'd like to turn to Government Exhibit 802 and to the eighth page. And looking at the middle row, does the recipient have the same address as the recipient we were just looking at?
TRACY CHAPELL: Yes.
MR. ROHRBACH: Your Honor, if they haven't already done so, we'd ask the jury to turn to Government Exhibit 802.
JUDGE NATHAN: Okay. Please turn to GX-802.
MR. ROHRBACH: Ms. Chapell, directing your attention to the middle row on this page, who is the sender of this package?
TRACY CHAPELL: J. Epstein.
MR. ROHRBACH: And what is the address?
TRACY CHAPELL: 457 Madison Avenue, New York, New York.
MR. ROHRBACH: And would you spell the first name of the recipient here?
TRACY CHAPELL: C-A-R-D-I-N-E.
MR. ROHRBACH: And what is the city and state?
TRACY CHAPELL: West Palm Beach, Florida.
MR. ROHRBACH: On what date was this package sent?
TRACY CHAPELL: December 12th, 2002.
MR. ROHRBACH: And finally, your Honor, I would like to turn the jurors' attention to Government Exhibit 803.
JUDGE NATHAN: Okay. You may turn to 803, please.
MR. ROHRBACH: And Ms. Chapell, if you would please do the same. And turning to page 6 of this document and directing your attention to the bottom row, Ms. Chapell, who is the sender of this package?
TRACY CHAPELL: Cecilia Steen.
MR. ROHRBACH: Are there any other names listed?
TRACY CHAPELL: Yes, Jeffrey E. Epstein.
MR. ROHRBACH: What is the shipping address?
TRACY CHAPELL: 457 Madison Avenue, New York, New York.
MR. ROHRBACH: Without saying the last name, what is the first name of the recipient?
TRACY CHAPELL: Caroline.
MR. ROHRBACH: What is the city and state of the recipient?
TRACY CHAPELL: West Palm Beach, Florida.
MR. ROHRBACH: What is the date of this package?
TRACY CHAPELL: October 7th, 2002.
MR. ROHRBACH: Thank you.
MR. ROHRBACH: No further questions, your Honor.
JUDGE NATHAN: Okay. Mr. Everdell.
MR. EVERDELL: Thank you, your Honor.
JUDGE NATHAN: You may put your binders down. Thank you.
MR. EVERDELL: May I inquire, your Honor?
JUDGE NATHAN: You may.
CROSS-EXAMINATION BY MR. EVERDELL:
MR. EVERDELL: Good morning, Ms. Chapell.
TRACY CHAPELL: Good morning.
MR. EVERDELL: You just testified about a few invoices from Federal Express that were provided to you by the government; is that right?
TRACY CHAPELL: Correct.
MR. EVERDELL: And you testified that they were associated with a FedEx account of Jeffrey Epstein, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And all of those -- three of those invoices that we just looked at, Government's Exhibit 801, 802, and 803, were from the last few months of 2002; is that right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And those invoices each showed shipments for roughly a few week to a month period of time, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: I just want to look at a few of those invoices that we looked at. I'm going to start with Government's Exhibit 803, and I'm going to direct your attention to page 6 of 9.
MR. EVERDELL: With the Court's permission, I'll have the jurors look in the same binder at Government's 803.
JUDGE NATHAN: Yes. Members of the jury, please look at GX-803.
MR. EVERDELL: And just directing the jurors' attention to page 6 of 9.
JUDGE NATHAN: Page 6. Okay. 803, page 6.
MR. EVERDELL: Actually, I apologize. If we can just first start with page 1 just so we can orient ourselves.
JUDGE NATHAN: Okay.
BY MR. EVERDELL:
MR. EVERDELL: So, Ms. Chapell, if you look at page 1. So we're looking here on Government's Exhibit 803-R at the invoice dated October 14th, 2002, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: And as you said before, this is an invoice that's associated with an account, the FedEx account of Jeffrey Epstein, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And if you look up at that top left-hand corner, you see the billing account shipping address, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And it says Jeffrey E. Epstein, 457 Madison Avenue, New York, New York, 10022, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: That's the address associated with this account for billing purposes, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: Now, I want you to skip to the page I mentioned before, page 6 of 9. All right. Now, I think if you look down at the last transaction on that page, that's a shipment that was sent out or was picked up for shipment on October 7th of 2002, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And do you see the information that's over on the left-hand side under the heading "Sender"?
TRACY CHAPELL: Yes.
MR. EVERDELL: That information says Cecilia Steen; is that right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And it has then Jeffrey E. Epstein and the address 457 Madison Avenue, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And that is the information that is present on the FedEx slip that goes with the package, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: So whatever information is filled out on the slip that gets attached to the FedEx package is what appears under "Sender," right?
TRACY CHAPELL: Correct.
MR. EVERDELL: Okay. And you see that this, the recipient here -- and I'm not asking you to say her full name, but the first name of the recipient here is Caroline; is that right?
TRACY CHAPELL: Correct.
MR. EVERDELL: And I think you mentioned the city and state, is that right, of where this was going?
MR. EVERDELL: May I confer?
JUDGE NATHAN: Yes.
(Counsel conferred)
MR. EVERDELL: You said that this was going to West Palm Beach, Florida, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: Okay. And I just want to refer back to the sender though, okay. That sender says that the package was sent by Cecilia Steen; correct?
TRACY CHAPELL: Correct.
MR. EVERDELL: It goes without saying that Cecilia Steen is not Ghislaine Maxwell; correct?
TRACY CHAPELL: Correct.
MR. EVERDELL: Okay. And that is the only transaction on this invoice that the government showed you to discuss in your direct testimony, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: I want to show you another transaction on this invoice. If you can go to page 7 of 9.
TRACY CHAPELL: Okay.
MR. EVERDELL: And I want to show you the transaction in the middle of the page, the middle of the three. Do you see that one?
TRACY CHAPELL: Yes.
MR. EVERDELL: That is also a shipment that was picked up for shipment the same day, October 7th of 2002, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: And that is the same day as the package we just looked at that was sent by Cecilia Steen on the page before, isn't it?
TRACY CHAPELL: Yes.
MR. EVERDELL: All right. Well, looking at this one, you see the recipient there is one named Casey Wasserman, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: And you see the sender information on this shipment; correct?
TRACY CHAPELL: Correct.
MR. EVERDELL: And the sender there is listed as Ghislaine Maxwell; is that right?
TRACY CHAPELL: Correct.
MR. EVERDELL: And then, of course, there's the information below, Jeffrey Epstein, 457 Madison Avenue.
TRACY CHAPELL: Yes.
MR. EVERDELL: Okay. It goes without saying that -- well, I shouldn't say "goes without saying." There is no other transaction or there is no transaction on this invoice we're looking at where someone named Ghislaine Maxwell is sending a package to anyone named Carolyn; correct?
TRACY CHAPELL: Correct.
MR. EVERDELL: Okay. Let's look at the next one. This is government's 801. And I'm doing this because I believe this goes chronologically in order, right. The one we just looked at was October, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: So let's look at 801.
MR. EVERDELL: And the jurors can do the same, with the Court's permission.
JUDGE NATHAN: Yes.
MR. EVERDELL: And we'll go to the first page of 801-R. So, Ms. Chapell, do you have that?
TRACY CHAPELL: Yes.
MR. EVERDELL: So this is an invoice from December 16th of 2002, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: So that's just roughly two months after the invoice we just saw?
TRACY CHAPELL: Yes.
MR. EVERDELL: And it's the same billing information, it's the same account we're looking at?
TRACY CHAPELL: Yes.
MR. EVERDELL: That's the account of Jeffrey Epstein at 457 Madison Avenue, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: All right. Let's take a look at page 5. Do you have that page, Ms. Chapell?
TRACY CHAPELL: Yes.
MR. EVERDELL: All right. This is the transaction that you were shown by the government to discuss, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And this shows a shipment that was picked up for shipment, FedEx package that was picked up for shipment on December 3rd of 2002, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And here the recipient -- again, I'm just going to use first names here. The recipient is Carolyn, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: That was going to West Palm Beach, Florida, as well?
TRACY CHAPELL: Yes.
MR. EVERDELL: All right. But you see over at the sender information; correct?
TRACY CHAPELL: Yes.
MR. EVERDELL: The sender is listed as S. Kellen, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: Do you know who S. Kellen is?
MR. EVERDELL: Okay. Safe to say that S. Kellen is not Ghislaine Maxwell, right?
MR. EVERDELL: Okay. Now, you were shown this transaction by the government, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: I want to point you to a different transaction in the same invoice.
MR. EVERDELL: If we can go to page 6, the next page.
MR. EVERDELL: And I want you to look at the bottom of that page, the last transaction.
TRACY CHAPELL: Okay.
MR. EVERDELL: That is a shipment, a FedEx package that was picked up for shipment on December 9th, 2002, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: And you see that the recipient of that package is someone named Lisa Anasrons is how it's spelled?
TRACY CHAPELL: Yes.
MR. EVERDELL: And the sender of that is G. Maxwell; correct?
TRACY CHAPELL: Correct.
MR. EVERDELL: And safe to say that this is not a package going to anybody named Carolyn, right?
TRACY CHAPELL: It is not.
MR. EVERDELL: It's going to Lisa Anasrons, whoever that may be, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: Okay. Let's look at another one from this invoice, page 8. I'll ask you to look at both of these transactions, if we could. These are both FedEx packages that were picked up for shipment on December 10th of 2002; correct?
TRACY CHAPELL: Correct.
MR. EVERDELL: And if we look at the first one, the recipient there is listed there as Isabel Maxwell?
TRACY CHAPELL: Yes.
MR. EVERDELL: And the sender is G. Maxwell?
TRACY CHAPELL: Yes.
MR. EVERDELL: And if you look down at the next one, the recipient there is Ron Burckle, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And again, sender of that package same day is G. Maxwell, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: And in both the sender -- again, we have that information, Jeffrey Epstein, 457 Madison Avenue, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: So the first package looks like it's going to Isabel Maxwell, and the second going to Ron Burckle, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: Neither one of those is named Carolyn; correct?
TRACY CHAPELL: Correct.
MR. EVERDELL: And, in fact, there is no shipment or transaction reflected in this invoice where someone named Ghislaine Maxwell is sending a package to someone named Carolyn, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: All right. And let's just look at the last invoice you were shown by the government, that's Government's 802.
MR. EVERDELL: If you can pull that up.
TRACY CHAPELL: Okay.
JUDGE NATHAN: Jurors may turn to 802.
MR. EVERDELL: Thank you, your Honor.
MR. EVERDELL: All right. Ms. Chapell, do you have that in front of you?
TRACY CHAPELL: Yes.
MR. EVERDELL: All right. So looking at the first page, this is the invoice dated December 23rd, 2002; correct?
TRACY CHAPELL: Yes.
MR. EVERDELL: All right. Again, same account we're looking at of Jeffrey Epstein?
TRACY CHAPELL: Correct.
MR. EVERDELL: All right. Let's flip to page 8. I want you to take a look at the middle of the three transactions there. We'll pull that up. This was the transaction that you were shown by the government on your direct, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: And that is a FedEx package picked up for shipment on December 12th, 2002; correct?
TRACY CHAPELL: Correct.
MR. EVERDELL: All right. And the recipient there, I'm, again, not going to use full names, but the first name there is listed as Cardine; correct?
TRACY CHAPELL: Correct.
MR. EVERDELL: And the address is West Palm Beach, Florida, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: The sender there is J. Epstein, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: Safe to say that J. Epstein is not Ghislaine Maxwell, right?
TRACY CHAPELL: Right.
MR. EVERDELL: Okay. Now, I want to show you some other transactions on that same invoice that you weren't shown by the government. And I want to stay on the same page and I want to look at the first transaction on the page. Okay. Now, I want to be careful about this. I don't want to use any names when we discuss this transaction, okay?
TRACY CHAPELL: Okay.
MR. EVERDELL: All right. That is a package that was picked up for shipment on the same day as the one we just looked at, December 12th, 2002; correct?
TRACY CHAPELL: Yes.
MR. EVERDELL: And I'm not going to name who the recipient is, but I'm going to refer to that person as "Jane," okay?
TRACY CHAPELL: Okay.
MR. EVERDELL: So the recipient there is Jane.
TRACY CHAPELL: Yes.
MR. EVERDELL: The sender is someone named J. Epstein; correct?
TRACY CHAPELL: Correct.
MR. EVERDELL: Okay. Again, that is not Ghislaine Maxwell or G. Maxwell, right?
MR. EVERDELL: Okay. Let's look at just a few others. Page 4 of the same invoice, and we'll look at the middle transaction here. All right. Now, that is a FedEx package that was picked up for shipment on December 9th of 2002, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: That was just a few days before the shipments we just looked at on December 12th, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: And you see the recipient here is listed as someone named Laura Casey Wasserman, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And the sender is G. Maxwell?
TRACY CHAPELL: Yes.
MR. EVERDELL: This obviously is -- the recipient is not anyone named Carolyn or Cardine, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: And again, let's look at page 5, the next page. And look at the first transaction on this invoice. That is a FedEx package picked up for shipment on December 10th of 2002, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And the recipient there is someone named Danny Hillis?
TRACY CHAPELL: Yes.
MR. EVERDELL: And the sender is G. Maxwell?
TRACY CHAPELL: Correct.
MR. EVERDELL: Danny Hillis is not named Carolyn or Cardine or anything like that, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: Okay. And again, on this invoice there is no transaction reflected on this invoice where someone named Ghislaine Maxwell or G. Maxwell is sending any packages to anybody named Carolyn or Cardine or anything like that?
TRACY CHAPELL: Correct.
MR. EVERDELL: You can put those down.
MR. EVERDELL: And the jurors, with the Court's permission, can do the same.
JUDGE NATHAN: Yes. Thank you.
MR. EVERDELL: Ms. Chapell, I'll just wait a moment. Before you came to testify today, you had some phone calls with the government; is that right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And that was to prepare your testimony today; correct?
TRACY CHAPELL: Yes.
MR. EVERDELL: And before you spoke to them, they sent you those three invoices that we were just talking about, is that right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And you looked at them to verify that they were true and accurate records that FedEx had in their system, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And those were the only invoices they sent you to verify; is that right?
TRACY CHAPELL: Yes.
MR. EVERDELL: Those three that we were looking at?
TRACY CHAPELL: Yes.
MR. EVERDELL: Okay. And I think they were so old at that point that you actually had to go back and look at archived copies to verify that they were true records, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: They weren't still in your system; you had to go back to the boxes in the warehouse, right?
TRACY CHAPELL: Correct.
MR. EVERDELL: But you were able to do that?
TRACY CHAPELL: Yes.
MR. EVERDELL: Okay. Now, do you recall at any point where the defense sent you some invoices to verify?
TRACY CHAPELL: Yes.
MR. EVERDELL: And do you remember how many roughly you were sent by the defense?
TRACY CHAPELL: There were several hundred.
MR. EVERDELL: And were they from the same account or different accounts?
TRACY CHAPELL: Two different accounts.
MR. EVERDELL: Were those accounts associated with Jeffrey Epstein?
TRACY CHAPELL: Yes, they were both his.
MR. EVERDELL: And what were you asked to do with those records?
TRACY CHAPELL: Just verify the records.
MR. EVERDELL: Were you able to take those records and verify them with the records in the boxes, that they were accurate business records?
TRACY CHAPELL: Yes.
MR. EVERDELL: Okay. And these were all records for accounts that belonged to Jeffrey Epstein, right?
TRACY CHAPELL: Yes.
MR. EVERDELL: And can you explain just how you were able to verify them?
TRACY CHAPELL: I went back to the paper copies and verified the invoices one by one.
MR. EVERDELL: Okay.
MR. EVERDELL: Your Honor, I'm going to do this in paper, if I could. May I approach?
JUDGE NATHAN: You may.
MR. EVERDELL: Okay.
JUDGE NATHAN: Showing the witness what's been marked as Defendant's TC-1; is that correct?
MR. EVERDELL: Correct, your Honor.
JUDGE NATHAN: Okay.
BY MR. EVERDELL:
MR. EVERDELL: All right. Ms. Chapell, do you have in front of you what's been marked for identification as Defendant's Exhibit TC-1?
TRACY CHAPELL: Yes.
MR. EVERDELL: Now, do you recognize what those are?
TRACY CHAPELL: Yes.
MR. EVERDELL: What are they?
TRACY CHAPELL: Jeffrey Epstein invoices.
MR. EVERDELL: Are those some of the records that were provided to you by the defense?
TRACY CHAPELL: Yes.
MR. EVERDELL: Are they all of the several hundred records or just a subset of those records?
TRACY CHAPELL: Just a few.
MR. EVERDELL: And how many roughly are there?
TRACY CHAPELL: In this stack?
MR. EVERDELL: Yes.
TRACY CHAPELL: About 50.
MR. EVERDELL: And what year or years do those invoices come from?
TRACY CHAPELL: 2002.
MR. EVERDELL: And how is it that you recognize that that's what those are?
TRACY CHAPELL: Because I verified it with the originals that we produced.
MR. EVERDELL: But how do you know that it's the same invoices that you were asked to look at?
TRACY CHAPELL: I initialed at the bottom.
MR. EVERDELL: Now, were those records that you're looking at in Defense Exhibit TC-1 made at or near the time of the shipping records that are reflected in the invoice?
TRACY CHAPELL: Yes.
MR. EVERDELL: And are they based on information that was available at the time that those shipments were made?
TRACY CHAPELL: Yes.
MR. EVERDELL: And is it the regular practice of Federal Express to make invoices like this?
TRACY CHAPELL: Yes.
MR. EVERDELL: And were these invoices kept in the regular course of FedEx's business?
TRACY CHAPELL: Yes.
MR. EVERDELL: Your Honor, at this time the defense offers Defense Exhibit TC-1 under temporary seal. We have not yet had the chance to make the appropriate redactions, but we will do so as soon as we can.
MR. ROHRBACH: No objection.
JUDGE NATHAN: Thank you. Defendant's TC-1 is admitted under temporary seal until narrow redactions can be offered.
(Defendant's Exhibit TC-1 received in evidence)
MR. EVERDELL: Absolutely, your Honor. And if the jurors would like to take a look, with the Court's permission, there is a folder underneath their chairs with this exhibit.
JUDGE NATHAN: Yes, please. You can open the folder to Defendant's Exhibit TC-1.
BY MR. EVERDELL:
MR. EVERDELL: Ms. Chapell, I'm not going to go through these records with you -- and the jurors are free to review it if they like -- but I have no further questions for this witness.
JUDGE NATHAN: Okay.
MR. ROHRBACH: Nothing further, your Honor.
JUDGE NATHAN: Okay. Ms. Chapell, thank you. You are excused. You may step down.
(Witness excused)
JUDGE NATHAN: You may.
(Counsel conferred)
JUDGE NATHAN: Members of the jury, you may put the folder back under your seats.
MS. COMEY: Your Honor with the defense's consent, we'd ask to be heard in the robing room please.
JUDGE NATHAN: Okay. You anticipate an extended sidebar?
MS. COMEY: We just need to be in the robing room, your Honor.
JUDGE NATHAN: Okay. Why don't I send the jury back to the jury room for a break and then --
JUDGE NATHAN: Yes, to the regular room.
(Jury not present)
JUDGE NATHAN: All right. I'll hear you in the robing room. This is an extended discussion?
MS. MOE: I'm not sure, your Honor, but our joint preference would be to be heard in the robing room.
JUDGE NATHAN: Okay. All right.
(Pages 2020 to 2024 SEALED)
(Continued on next page)
(In open court)
JUDGE NATHAN: Bring in the jury.
MR. EVERDELL: Your Honor?
MS. MENNINGER: Our client is not here.
JUDGE NATHAN: I'm going to step off.
(Recess)
JUDGE NATHAN: We'll bring in the jury.
(Jury present)
JUDGE NATHAN: Thank you, members of the jury. I've been informed there's an attorney in the case who's ill, and that attorney needs to get care. We have no reason to believe it's COVID-related, but we do need that attorney for what was anticipated to happen today. So we need to break. My assumption is we'll resume tomorrow morning at our normal time. And I'll give you any additional information, if I have that information. But we want to make sure the attorney is taken care of. And rather than pause and delay, we're going to break for the day. So all of my instructions apply. Thank you for your time and attention. We'll see you tomorrow morning. Thank you.
(Jury not present)
JUDGE NATHAN: Counsel, is there anything we can take up now or wait until we get further word?
MS. COMEY: I don't believe there's anything we can take up now, your Honor. We will keep the Court and the defense informed.
JUDGE NATHAN: Okay.
MR. EVERDELL: Nothing from the defense, your Honor.
JUDGE NATHAN: All right. Thank you, everyone. We're adjourned till tomorrow.
(Adjourned to December 10, 2021 at 8:45 a.m.)