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U.S. v. Ghislaine Maxwell
Day 4 [12.2.21]
Day 4. New witness: Paul Kane of NYC’s Professional Children’s School.
AUSA: Look at Government Exhibit 721. Do you recognize it?
Day 4. New witness: Paul Kane of NYC’s Professional Children’s School.
AUSA: Look at Government Exhibit 721. Do you recognize it?
Kane: An enrollment application for a student.
AUSA: Don’t say the name. Is it an accurate copy?
Kane: Yes.

Maxwell’s lawyer: Objection – hearsay!
AUSA: It’s a business record.
Judge Nathan: Overruled.
Maxwell’s lawyer: Can I question the witness?
Judge Nathan: Go ahead.
Maxwell’s lawyer: The Professional Children’s School doesn’t verify the accuracy of the info on the form, does it?
Kane: I think they do.
Maxwell’s lawyer: All of it?
Kane: That, I don’t know.
Maxwell’s lawyer: So the info—
AUSA: Your Honor, may I?
Judge Nathan: You may.
AUSA: What happens to info coming in?
Kane: Contact the family by phone, then invite them to tour the school and have a conversation.
AUSA: Does the School rely on the form?
Kane: Yes.
[After sidebar, document is in]
AUSA: What grade was the person applying for?
Kane: 12th. Due to “move to New York.”
AUSA: Who’s listed as person of financial responsibility?
Kane: Mister Jeffrey Epstein.
AUSA: Thanks. No further questions.
Maxwell’s lawyer: You have no idea if Mr. Epstein actually paid.
Kane: I do not.
Maxwell’s lawyer: And for the mother, does it say unemployed?
Kane: It says self-employed. As an interior decorator.
Maxwell’s lawyer: And who is the listed agent?
AUSA: Objection!
Judge Nathan: Just make the jurors look at it.
Maxwell’s lawyer: Look the name in the corner. And the name of the prior principal. You don’t have to say them for the record. No further questions.
Judge Nathan: Thank you Mr Kane. Next US witness.
It’s Doctor Lisa Rocchio. “I have a Masters and PhD from U of Rhode Island.”
[After long presentation of credentials, Rocchio is in as an expert.]
AUSA: Did you interview anyone in this case?
Rocchio: No.
AUSA: Does your pay depend on outcome of the trial?
Rocchio: No.
AUSA: What is grooming?
Rocchio: Strategies to get children into sex
Rocchio: I’ve seen grooming in the Boy Scouts through a special camping trip. Or jewelry, anything to make the children feel they are appreciated.
[During the Daubert hearing, before trial, Maxwell’s lawyer asked, does this mean that grandparents are grooming?]
AUSA: How common is it for a child to be repeatedly abused by the same perp?
Rocchio: Very common. It’s by people close to the child.
AUSA: What is a grooming environment?
Rocchio: The perp develops trust with people around the child, for example with the parents
[long non-public sidebar]
AUSA: Are victims of child sexual abuse likely to report it to the police?
Rocchio: No.
AUSA: How do they talk about it?
Maxwell’s lawyer: Objection – no foundation.
Judge Nathan: I’ll sustain. Can you re-phrase?
AUSA: What is the long term impact?
Rocchio: They are at higher risk for adverse outcomes.
AUSA: Nothing further.
Judge Nathan: Let’s take our break.
Maxwell’s lawyer: Doctor Rocchio, you have a $45,000 contract for this, correct?
Rocchio: Yes.
Maxwell’s lawyer: If one had a brain injury, it might be hard to remember, right?
AUSA: Objection.
Judge Nathan: Sustained.
Maxwell’s lawyer: Alcohol would harm recall too, yes?
AUSA: Objection.
Judge Nathan: Sustained.
Maxwell’s lawyer: Are you familiar with confabulation?
AUSA: Objection!
Judge: Overruled.
Maxwell’s lawyer: It’s filling in the gaps.
AUSA: Objection.
Judge: Sustained.
Maxwell’s lawyer: My grandfather liked to take me to the Bronx Zoo. Was that grooming?
Next US witness is Juan Patricio Alessi.
AUSA: Where do you come from?
Alessi: Quito, Ecuador.
AUSA: When did you move to Florida?
Alessi: Early 1984. I worked for a wealthy family in Palm Beach, I was a maintenance guy. Then I worked for Mister Jeffrey Epstein
AUSA: How did you meet Epstein?
Alessi: I was working on Mister Wexner’s mother’s house. [!]
AUSA: Who is in this photo?
Alessi: Mr. Jeffrey Epstein
AUSA: When Mr. Epstein was in Palm Beach, where did you sleep?
Alessi: I had a room there.
AUSA: Who else worked there?
Alessi: I brought my wife to help me. And other girls.
AUSA: How did things changed after Ms. Maxwell got involved?
Alessi: Things were less cordial. Less conversation. I was not allowed to see Mr. Epstein anymore, unless he asked me question. Ms. Maxwell said, Don’t look at his eyes, “look at another part of him.”
[And with that, and a blueprint of the house on the screens]
Judge Nathan: The jurors’ lunch has arrived. Let’s break.
[Alessi is describing Epstein’s Palm Beach home in great detail. Presumably it will become relevant in the testimony of Survivor / Witnesses 2, 3 and 4.]
AUSA: Pull up Gov Exhibit 297. Mr. Alessi what is this?
Alessi: The 2d floor. That is toward Mr. Epstein’s bedroom. There was a huge bathroom.
AUSA: And what’s that other bathroom?
Alessi: That’s Ms. Maxwell’s bathroom.
AUSA: But they both came off the master bedroom?
Alessi. Yes.
AUSA: Where did Ms. Maxwell sleep in the Palm Beach house?
Maxwell’s lawyer: Objection! But it’s allowed.
Alessi: She slept in Mr. Epstein’s bedroom.
AUSA: How many times did you see females by Mr. Epstein’s pool?
Alessi: 100s. AUSA: How often were they topless?
Alessi: 75% of the time
AUSA: How about Little St. James?
Alessi: I was on a cruise with my wife to St. Thomas. They picked us up & showed us Little St. James. It was huge.
AUSA: Did you visit any Ms Maxwell property?
Alessi: Her townhome in London. She invited us. It had a red front door
AUSA: What conversations did you have with Ms. Maxwell about this booklet?
Alessi: I told her I could not do this checklist, with all my other work.
AUSA: Show them Gov Exhibit 606.
AUSA: How long is this book?
Alessi: 58 pages.
AUSA: What is it?
Alessi: List of what were supposed to do to maintain the house.
[Now Maxwell’s lawyer will question Alessi about the book of instructions.]
Maxwell’s lawyer: When you left, you didn’t have this in your possession did you?
Alessi: No I did not.
Maxwell’s lawyer: But this book was created after you left, at least by the date on it
Maxwell’s lawyer: We object to 606.
AUSA: He identified pages.
Judge Nathan: I’m overruling the objection. 606 is admitted.
AUSA: We you recognize the address at the bottom?
Alessi: Mr. Epstein’s residence.
AUSA: What does this instruction saw?
Alessi: “Do not discuss your personal problems with guests.”
AUSA: And this one?
Alessi: “Respect their privacy.”
AUSA: There’s a reference to the JE and the GM telephone directories. What were they?
Alessi: Books with hundreds and hundreds of names. Directions and addresses.
Alessi: They were 2 inches thick. Full of names.
AUSA [for some reason turning away from the 2 black books, at least for now] Let’s turn to page 23, about Ms. Maxwell’s desk. What does it say?
Alessi: Please the directory to the right of the phone.
Assistant US Attorney: What is this?
Alessi: Instructions for serving breakfast. Sometimes at 5 am.
AUSA: Who else worked there?
Alessi: Chefs. My wife. Ms Maxwell’s assistant. Then Sarah Kellen.
Alessi: Two females seemed to be underage.
AUSA: Don’t say their names. Jurors, look at the binders under your chairs. GX 12.
Alessi: Can I have a cup of water?
AUSA: Is that name the person we’ll call Jane?
Alessi: Yes. I met Virginia Roberts too.
AUSA: When you met Jane how old was she?
Alessi: Appeared 14 or 15. She was beautiful, beautiful eyes, long brunette hair, very pleasant. Three times she was there with her mother. Then, without her mother. Many times.
AUSA: How would Jane get to the house?
Alessi: I would pick her up, and the direction of Mr. Epstein or Ms. Maxwell.
AUSA: When did you meet Ms Virginia Roberts?
Alessi: I was at Mar-A-Lago with Ms. Maxwell. I waited in the car like the driver
Alessi: It was a hot day. Ms. Maxwell said, Stop, John, Stop. I did and Ms Maxwell went up to this girl.
AUSA: Where was this girl?
Alessi: She was coming down the ramp.
AUSA: How did she look?
Alessi: Young.
Alessi: Then by 5 pm I saw her [Virginia Roberts] back at the house.
AUSA: Show Exhibits 113 and 114 only to the witness and parties… How old did you think Ms Roberts was?
Alessi: 14 or 15.
AUSA: Did Ms. Maxwell ever instruct you to pick up Ms. Roberts?
Alessi: Yes.
AUSA: Did you ever see Ms. Roberts at Mr. Epstein’s home with luggage?
Alessi: Yes. I drove them to the plane.
AUSA: How many massages would Mr. Epstein get a day?
Alessi: Before I left, thee a day. I called whoever they told me to call.
AUSA: Did the phone books we discussed have names for massage in them?
Alessi: Yes.
AUSA: Did you see Jane’s name in it?
Alessi: Yes. The books were updated twice a year.
AUSA: What did you do with them, when new ones were made?
Alessi: Just throw them away.
AUSA: I have a physical exhibit, GX 52. May I approach the witness? Do you recognize it? What is it?
Alessi: It is the directory.
AUSA: Did you review it last night?
Alessi: I did.
AUSA: Every page?
Alessi: Yes.
AUSA: How many names?
Alessi: Many. Many. Many.
AUSA: Is this the same you saw when you were that or a later version?
Alessi: A later version.
AUSA: Pull up Exhibit 52a. It is a sealed exhibit.
Judge Nathan: Let’s take a break.
[with jury out, lawyers’ arguments continue. Assistant US Attorney says “We are not offering the full exhibit 52 [the black book]. [Why not?] Now break is taken]
All rise!
Now Alessi back.
AUSA: How often was the directory updated?
Alessi: Twice a year. And the names of new employees were added, and those who left were taken out.
AUSA: Is Sarah Kellen in this version?
Objection – leading.
Judge Nathan: I’ll overrule that.
[Long sidebar, after which Maxwell’s lawyer does the questioning]
Maxwell’s lawyer: As you sit here today, 19 years later, you have no idea where Exhibit 52 has been?
Maxwell’s lawyer: You said the book was two inches thick. But Exhibit 52 is a quarter inch thick, correct?
Alessi: Yes.
Maxwell’s lawyer: The book you were talking about was from New York, right?
Alessi: Yes
Maxwell’s lawyer: And the PostIt(TM) notes weren’t there, right?
Alessi: Right. But it continues:
AUSA: Did you take messages for Mr. Epstein? How?
Alessi: If he didn’t want to talk the call. Or wasn’t there.
Maxwell’s lawyer: There are a number of pages without dates next to the names. Do you know that?
Alessi: I guess so.
Judge Nathan: Exhibits admitted.
AUSA: They are sealed – not to be put on screens, binders only. More more questions:
AUSA: What supplies did you buy for the massages?
Alessi: No oils, I was –
Maxwell’s lawyer: Objection!
AUSA: Did Ms Maxwell give you supplies?
Alessi: Exotic oils for other countries.
AUSA: Was Mr. Epstein’s door open during the massages?
Alessi: Never. Afterward I went in with gloves.
AUSA: Why?
Alessi: To clean up.
AUSA: What did you see after the massages? Towels?
Alessi: Yes. But not all of the massages.
AUSA: Do any incidents stand out in your mind?
Alessi: I found a large dildo.
AUSA Comey: What did you do with it?
Alessi: Wash it up.
AUSA: Where did you put the dildo?
Alessi: In Ms. Maxwell’s bathroom. In a basket.
AUSA: How did you know where to put it?
Alessi: I knew everything going on in the house.
AUSA: What else was in the basket?
Alessi: I saw pornographic tapes.
AUSA: How often did you see the dildo?
Alessi: At least five times.
AUSA: And the other one, the massager, did the ball at the end vibrate?
Alessi: Yes. I would put it at the top of Mr. Epstein’s dresser.
AUSA Comey: What photos were in the house?
Alessi: Photos of Mr Epstein and Ms Maxwell with important people.
AUSA: Like who?
Alessi: Donald Trump. The Pope, I think, Fidel Castro.
AUSA: Were there photographs of naked women?
Alessi: Yes. But those were kept in Ms. Maxwell’s desk.
AUSA: Why did you leave Mr Epstein’s employ?
Alessi: I was sick and tired.
AUSA: Did you sign a non-disclosure agreement?
Alessi: Yes. About both of them.
AUSA: Were you questioned by the police after you took $6300 from Mr. Epstein?
Alessi: Yes.
AUSA: Were you arrested?
Alessi: No.
AUSA: Nothing further.
Maxwell’s lawyers: We’ll start our cross tomorrow [it’s 4:48]
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