7.Kerry Morgan — Cross/Redirect (Part 2)

MR. AGNIFILO: Good afternoon, Ms. Morgan. I'm one of Sean Combs's lawyers. I have a few questions for you, not a ton, you'll be out into the nice afternoon in a little while and you'll have satisfied your subpoena and you'll be on your way.

MR. AGNIFILO: So if I ask you a question that you don't understand or you want me to rephrase it, all you need to do is ask and I will do that. Okay?

MR. AGNIFILO: So you identified a few people today.

MR. AGNIFILO: I'm going to ask to put up something that was just admitted into evidence today. It's 9P-102. It's a photograph. It's already in evidence.

MR. AGNIFILO: Do you recognize the people in that photograph?

MR. AGNIFILO: Do you recognize anybody else?

MR. AGNIFILO: Do you know who Dawn Richard is?

MR. AGNIFILO: So just to recap some of the things you said this morning. For a period of time, a long period of time, you were Cassie's best friend?

MR. AGNIFILO: We can take this picture down. I'm sorry. Let's put it back up for one second. I'm sorry.

MR. AGNIFILO: Which one is Cassie?

MR. AGNIFILO: Okay. And you don't recognize the other two people with her?

MR. AGNIFILO: Okay. We can take it down.

MR. AGNIFILO: You were Cassie's best friend for -- starting in what, 2004 until --

MR. AGNIFILO: 2001 you guys met. 2001 to 2018, right?

MR. AGNIFILO: And you tended to know the other people who were close to Cassie, right?

MR. AGNIFILO: And you don't recognize the two people in that photo?

MR. AGNIFILO: So I have a few questions for you. So you met Cassie in 2001. Where exactly did you guys meet?

MR. AGNIFILO: Yeah, what city --

MR. AGNIFILO: Was she already modeling?

MR. AGNIFILO: And you were modeling, too?

MR. AGNIFILO: You grew up in Buffalo, you said?

MR. AGNIFILO: Came to New York for the vastly improved weather, and now you're in New York and you meet Cassie?

MR. AGNIFILO: I don't need all the details to the extent -- how did you meet her, how did you come to meet Cassie?

MR. AGNIFILO: So modeling was done with Polaroids?

MR. AGNIFILO: So you and Cassie met because you had to wait for the Polaroids to develop?

MR. AGNIFILO: And describe your friendship from that point.

MR. AGNIFILO: So when you met Cassie, she was still in high school?

MR. AGNIFILO: So then you shared an apartment for a time in New York City?

MR. AGNIFILO: And you guys lived downtown?

MR. AGNIFILO: How long a period of time did you guys live together?

MR. AGNIFILO: Do you remember, is that 2004?

MR. AGNIFILO: And then you move uptown and she stays downtown?

MR. AGNIFILO: And she was, from what you could tell from living with her and being her friend, she was doing pretty well financially with her modeling career, correct?

MR. AGNIFILO: I think you said she was making about a quarter million dollars?

MR. AGNIFILO: This is modeling in what context --

MR. AGNIFILO: At some point in time, Cassie started dating someone named Ryan Leslie, am I right?

MR. AGNIFILO: And when did she start dating Mr. Leslie?

MR. AGNIFILO: Did you come to know Mr. Leslie pretty well?

MR. AGNIFILO: Who was he at the time?

MR. AGNIFILO: At that point when she started dating Mr. Leslie, she had not put out any music?

MR. AGNIFILO: How long a period of time, based on living with Cassie, being Cassie's friend, did she date Mr. Leslie, from what you could tell?

MR. AGNIFILO: And only what you know, not what you don't know. Did they seem pretty serious?

MR. AGNIFILO: At one point you met Mr. Combs for the first time?

MR. AGNIFILO: That's you said that's about 2007ish?

MR. AGNIFILO: Do you remember how you met him?

MR. AGNIFILO: After Cassie started dating Mr. Combs, what kind of time would you spend with the two of them?

MR. AGNIFILO: And what sort of -- give us an idea, the best you can, give us an idea --

MR. AGNIFILO: So 2008, just to pick a time period, how often would you say you're seeing Mr. Combs and Cassie in a month?

MR. AGNIFILO: And in part because you had your own social life?

MR. AGNIFILO: And so once a month, twice a month, less?

MR. AGNIFILO: And where would these meetings tend to be? I'm just trying to give the jury a sense of what things were like.

MR. AGNIFILO: You said that through the years, you guys all traveled together?

MR. AGNIFILO: You said you went to Italy?

MR. AGNIFILO: Once or more than once?

MR. AGNIFILO: Do you remember where?

MR. AGNIFILO: And then I think you had said Ibiza?

MR. AGNIFILO: Where else outside of the country?

MR. AGNIFILO: And anything else, any other trips outside the country?

MR. AGNIFILO: And you guys would go to Burning Man here obviously in the country?

MR. AGNIFILO: Tell the jury, what's Burning Man?

MR. AGNIFILO: Is it the same time every year, roughly?

MR. AGNIFILO: How many times would you say that you and Mr. Combs and Cassie went to Burning Man?

MR. AGNIFILO: Did you go with them those three times?

MR. AGNIFILO: And who, other than Mr. Combs and Ms. Ventura, who else would go with you, typically?

MR. AGNIFILO: In the --

MR. AGNIFILO: You stayed in a camp together. Tell us what that was like.

MR. AGNIFILO: Yeah.

MR. AGNIFILO: You're friendly with other people kind of in the general group. Is there someone named Dallas Austin?

MR. AGNIFILO: Who's Dallas?

MR. AGNIFILO: And you know him?

MR. AGNIFILO: And when would you say you first met Dallas?

MR. AGNIFILO: But would it have been before 2010, after 2010?

MR. AGNIFILO: And then Lucas White, do you know who that is?

MR. AGNIFILO: What are the connection of Dallas — we'll start with Dallas — Dallas and Mr. Combs, from what you could see?

MR. AGNIFILO: Yeah, how do they know each other?

MR. AGNIFILO: Tell the jury, who's Kim Porter?

MR. AGNIFILO: Have you ever met her?

MR. AGNIFILO: Do you know how many times, ballpark?

MR. AGNIFILO: Do you know where you would have met her?

MR. AGNIFILO: And I'm not going to ask to delve into this. From your connection with Ms. Ventura and your friendship with Ms. Ventura, could you tell if Kim Porter was a source, from time to time, of jealousy on her part?

MR. AGNIFILO: Cassie. Was Cassie ever jealous of Kim?

MR. AGNIFILO: I'm trying to see if there's more than I'm sure. Is there anything that you saw, because of your friendship with Cassie, that would lead you to that conclusion?

MR. AGNIFILO: Fair to say, this was sort of an ongoing situation?

MR. AGNIFILO: And Lucas White, what was Mr. Combs's connection to Lucas White from what you could see?

MR. AGNIFILO: You said that you guys would go to the studio from time to time, and that would be Ms. Ventura, as well?

MR. AGNIFILO: And was Ms. Ventura, from time to time, going to the studio to work on her own music, from what you could see?

MR. AGNIFILO: How often would you say she went to the studio to work on music? I'm sorry about asking all these general questions. I'm really trying to get an idea of how things were like?

MR. AGNIFILO: Only if you know, do you know who was paying for the studio time?

MR. AGNIFILO: Did she ever tell you whether or not she was paying for the studio time?

MR. AGNIFILO: And the label being Bad Boy?

MR. AGNIFILO: Do you know from time to time if Mr. Combs would put Ms. Ventura together with other artists in the studio?

MR. AGNIFILO: Was your understanding that, many times, these were artists that were further along in their musical career than Ms. Ventura was along in her musical career to kind of help her whatever she was working on?

MR. AGNIFILO: And one of them was someone named Kid Cudi?

MR. AGNIFILO: I think you said Lil Wayne?

MR. AGNIFILO: You didn't?

MR. AGNIFILO: Sorry. Do you know if that's true?

MR. AGNIFILO: Yeah.

MR. AGNIFILO: That's fine. Do you remember any other artists that Ms. Ventura did work with?

MR. AGNIFILO: Do you remember the name of the mixed tape?

MR. AGNIFILO: That came out, ballpark, do you remember when about? Okay. But while she and Mr. Combs were together, romantically together?

MR. AGNIFILO: Do you remember, Mr. Combs was quite jealous in your experience, correct?

MR. AGNIFILO: And fair to say this was a source of great stress to you? Let's start with you. Fair to say?

MR. AGNIFILO: Yes.

MR. AGNIFILO: Because he would be jealous and he would act up. Is that a fair way to put it?

MR. AGNIFILO: But you saw this, you saw the jealousy playing out, correct?

MR. AGNIFILO: Because you were Cassie's best friend?

MR. AGNIFILO: And he was jealous, for instance, one day that he thought that Cassie had danced with Chris Brown, correct? Do you remember that?

MR. AGNIFILO: Let me see if I can show you something. That's a very specific thing.

MR. AGNIFILO: It's B-329.

MR. AGNIFILO: Oh, I think you might have it in your folder. See that book next to you? We are not nearly going to go through everything in that book, so don't worry about that. But if there's something there that's a tab for B-329, here's what I'm going to ask you to do: I'm going to ask you to take a look at it.

MR. AGNIFILO: Do me a favor, there's a couple of text sections there, just read them to yourself. When you've read them, just look back up at me if you could. Did you read it? Okay. Do you remember something about dancing with Chris Brown?

MR. AGNIFILO: That's fine. Fair enough. Do you remember Cassie complaining to you in a text that Combs is angry because Combs believes that she was dancing with Chris Brown?

MR. AGNIFILO: And at one point, Combs was jealous, was he not, of the actor Michael B. Jordan. Do you remember that?

MR. AGNIFILO: And what do you remember about that? Let me ask you what you remember and then I'll ask you some specific questions.

MR. AGNIFILO: Mr. Combs wasn't with her?

MR. AGNIFILO: Let's take a step back and thank you for that. So Ms. Ventura goes to South Africa to film a movie. Remind us again what movie that was, if you remember?

MR. AGNIFILO: And how long was she in South Africa, ballpark, about?

MR. AGNIFILO: And during this period of time, it was your belief that Combs and Ms. Ventura were not together?

MR. AGNIFILO: And in fact, didn't she say something along the lines of, she was -- I'm going to use the wrong word because I'm of a generation where I'm using wrong words, like blocking everybody, right, she was blocking everyone?

MR. AGNIFILO: Yeah, all of Mr. Combs's people.

MR. AGNIFILO: Let me ask a better question and one that's probably more educated.

MR. AGNIFILO: That's fine.

MR. AGNIFILO: Do you remember being with Ms. Ventura and Ms. Ventura saying, I'm blocking Combs --

MR. AGNIFILO: I'm not asking for the truth, I'm just trying to figure out --

MR. AGNIFILO: So how long were you with Ms. Ventura in South Africa?

MR. AGNIFILO: And for another period --

MR. AGNIFILO: Give me one second, Judge. Your Honor, may I approach the witness?

MR. AGNIFILO: I'm showing you a photograph, and the person in the middle we're going to call Mia.

MR. AGNIFILO: Okay. I'll take that from you. So for a period of time, Mia was in South Africa, as well, correct?

MR. AGNIFILO: And were you and Mia there at the same time or at different times?

MR. AGNIFILO: For the whole time?

MR. AGNIFILO: Were you there on the front end or the back end or in the middle?

MR. AGNIFILO: And the way we got to this subject, as you said, during this period of time, there was some relationship of some nature between Ms. Ventura and Michael B. Jordan?

MR. AGNIFILO: Very, very succinctly, what was the nature of that?

MR. AGNIFILO: Understood. And at some point you were aware, were you not, that Mr. Combs expressed, in your presence, jealousy over this situation?

MR. AGNIFILO: Was it only things that Ms. Ventura would tell you?

MR. AGNIFILO: But do you remember this being an issue at some point?

MR. AGNIFILO: Tell the jury what you remember.

MR. AGNIFILO: Ms. Ventura was trying to leave Mr. Combs?

MR. AGNIFILO: Now while you and Ms. Ventura were in South Africa -- and I'm not going to belabor this point -- you guys were using some controlled substances, some drugs, right?

MR. AGNIFILO: Not at all?

MR. AGNIFILO: Was Ms. Ventura using anything, from what you could see?

MR. AGNIFILO: I understand. Did you come to learn that there was a woman in Mr. Combs's life named Gina?

MR. AGNIFILO: And fair to say that Gina was a source of jealousy and worry to Ms. Ventura?

MR. AGNIFILO: Thank you. That's a great way to put it. Tell the jury why Gina was a big problem.

MR. AGNIFILO: I need to clarify one thing. You called her a little girl. She was a grown adult woman, right?

MR. AGNIFILO: Why do you say that?

MR. AGNIFILO: Do you know how old she was at the time?

MR. AGNIFILO: She was --

MR. AGNIFILO: So I'm trying to understand, she was acting like a little girl, I want to understand very briefly what you mean.

MR. AGNIFILO: That's fine. Only what you know. But what you do know is that Gina was a problem?

MR. AGNIFILO: And she was a problem because this was all hurtful to Ms. Ventura?

MR. AGNIFILO: Ms. Ventura was hurt by this?

MR. AGNIFILO: Let's just --

MR. AGNIFILO: That's okay. And it was a persistent problem, it lasted for years, and years, and years, and years?

MR. AGNIFILO: When you said she wouldn't go away, what you're saying, tell me if this is right, is that Mr. Combs was with Gina romantically for many, many years?

MR. AGNIFILO: And during the same time, he was also with Cassie?

MR. AGNIFILO: And that Mr. Combs was cheating on Cassie was a source of a great deal of conversation between you and Cassie while you're in South Africa and at other times?

MR. AGNIFILO: About Mr. Combs?

MR. AGNIFILO: And then she comes back from South Africa when, in the late fall of 2015; does that sound right?

MR. AGNIFILO: And your friendship continued?

MR. AGNIFILO: In the latter part of 2015, do you remember where you were living? Not the exact address.

MR. AGNIFILO: Do you remember where Ms. Ventura was living?

MR. AGNIFILO: Only if you remember.

MR. AGNIFILO: At some point she moved from New York to LA; am I right?

MR. AGNIFILO: Do you remember, ballpark, when that was?

MR. AGNIFILO: Now, in connection, were there times when Ms. Ventura would ask you to sort of be cover in terms of, like, don't tell Mr. Combs where I am type of thing?

MR. AGNIFILO: Do me a favor, I think 1607 and 1608 are in your binder. Look at 1607 first, just read it to yourself, and if you can't find it, let me know.

MR. AGNIFILO: Now read 1608, also.

MR. AGNIFILO: Do you remember a time when you and Ms. Ventura were talking and you were essentially being asked to provide like a back story if Mr. Combs were to call looking for her?

MR. AGNIFILO: That's fine. Do you recall that happening ever?

MR. AGNIFILO: I mean --

MR. AGNIFILO: That's alright. When Ms. Ventura came back from South Africa, to your knowledge — I'm going to keep it very general purpose — was there any romantic type of relationship to your knowledge that she had with Michael B. Jordan?

MR. AGNIFILO: That's fine. I want to talk for a second about this situation where Mr. Combs had a hammer on the wooden door, Ms. Ventura's wooden apartment door. So just a few questions about that. So you and Ms. Ventura were at her apartment on Willshire Boulevard in Comstock?

MR. AGNIFILO: And you hear banging on the apartment door?

MR. AGNIFILO: And other than you and Ms. Ventura, are anyone else in the apartment?

MR. AGNIFILO: It's just the two of you?

MR. AGNIFILO: And you said the banging was very, very loud?

MR. AGNIFILO: Mr. Combs, you're saying you saw him through the peephole?

MR. AGNIFILO: And he was banging the door with a hammer?

MR. AGNIFILO: Wooden door I think you said on direct?

MR. AGNIFILO: Fair enough. Did anyone, and only if they did, did anyone take any pictures of the door, do you know?

MR. AGNIFILO: And no one did, from what you can see?

MR. AGNIFILO: I'm going to ask about them in a second. And you did not call the police, right?

MR. AGNIFILO: And you didn't see Ms. Ventura call the police?

MR. AGNIFILO: And so the police show up, right, Los Angeles police department?

MR. AGNIFILO: Three hours later, right on time. Do you remember, is it one officer or more than one officer?

MR. AGNIFILO: Two. Men or women?

MR. AGNIFILO: And the police officers don't say anything to indicate what prompted them to come there, correct?

MR. AGNIFILO: Let me ask a better question. They didn't say a particular someone had called them, someone specific had called them?

MR. AGNIFILO: What they did indicate to you is they were there because of the banging on the door?

MR. AGNIFILO: And at the time, were there any injuries to Ms. Ventura that were visible that you could see?

MR. AGNIFILO: Where?

MR. AGNIFILO: And was it noticeable, could one see it?

MR. AGNIFILO: Now, tell me, when the police get there, what do the police do, what happens?

MR. AGNIFILO: What did the officers say to you, other than asking for your ID?

MR. AGNIFILO: And did the police, from what you could see, did the police approach Ms. Ventura and speak to her?

MR. AGNIFILO: And from what you could see, how far away from Ms. Ventura were the police when they were speaking to her?

MR. AGNIFILO: So Ms. Ventura is sitting on the couch, the two police officers are right in front of her?

MR. AGNIFILO: Is this daylight or nighttime?

MR. AGNIFILO: Light in the apartment is normal lighting like this?

MR. AGNIFILO: So we have lighting like this, the police are what, five feet from Ms. Ventura?

MR. AGNIFILO: Is she doing anything to obstruct her face?

MR. AGNIFILO: She had a hoodie on, but the hoodie wasn't covering her eye?

MR. AGNIFILO: So the two police officers, in lighting just like this lighting, are five or so feet away from Ms. Ventura, how long a period of time would you say they were speaking to Ms. Ventura from that distance away?

MR. AGNIFILO: But I mean a couple of minutes, right?

MR. AGNIFILO: And Ms. Ventura is sitting on the couch, they're five feet away, speaking to her, does either police officer say anything or do anything that lead you to conclude that they see she has an injury to her eye?

MR. AGNIFILO: What did she say?

MR. AGNIFILO: And you say that they asked her for her license?

MR. AGNIFILO: And what did she say?

MR. AGNIFILO: Did the police officers in your presence ask whose apartment it was?

MR. AGNIFILO: And it was whose apartment?

MR. AGNIFILO: Did the police do anything to learn Cassie's identification, other than asking for her license?

MR. AGNIFILO: Ultimately, Ms. Ventura did not give them a driver's license?

MR. AGNIFILO: Or any type of ID that you could see?

MR. AGNIFILO: And from what you could also see, the police didn't do anything else to determine her identity?

MR. AGNIFILO: So you never saw anything that would lead you to conclude that the police learned her identity, either because Cassie told her or gave them some sort of documentation?

MR. AGNIFILO: How long would you say the police were in the apartment altogether?

MR. AGNIFILO: Really, it took them three hours to come?

MR. AGNIFILO: I think we can pull it up, it was just admitted into evidence as Government Exhibit C-3644-A. I think it's the card of one of the officers. It's already in evidence.

MR. AGNIFILO: Can you see that okay?

MR. AGNIFILO: So this person, do you remember there being a sergeant -- I know it's a long time ago. I apologize. Do you remember one of them being a sergeant named Hall?

MR. AGNIFILO: Got it. And this is one of the two officers, left their card?

MR. AGNIFILO: When the officer left the card, did the officer say anything that you could hear, here's why I'm leaving the card?

MR. AGNIFILO: And you didn't say anything to the police about -- well, let me back up. Did you tell the police what happened with the hammer?

MR. AGNIFILO: You didn't hear Ms. Ventura tell the police what happened with the hammer?

MR. AGNIFILO: Did the police do or say anything to indicate that they saw any damage to the wooden door?

MR. AGNIFILO: How long would you say the police were in the apartment in total? If you answered that, I've already forgot it.

MR. AGNIFILO: They leave and this incident comes to an end?

MR. AGNIFILO: We can pull it up if we need to, but I think we just looked at it this morning. There was text communication between and you Kristina Khorram, right?

MR. AGNIFILO: The person we call KK.

MR. AGNIFILO: Tell the jury a little bit about KK. Who's KK?

MR. AGNIFILO: Did you have your own relationship with KK?

MR. AGNIFILO: And tell us about that.

MR. AGNIFILO: Yeah.

MR. AGNIFILO: Understood. You said a minute ago that she's a nice girl. Just tell us more.

MR. AGNIFILO: You also talked about someone, a D-Roc?

MR. AGNIFILO: How well do you know D-Roc?

MR. AGNIFILO: You haven't seen a lot of these people.

MR. AGNIFILO: Tell me about D-Roc, what's your relationship with D-Roc?

MR. AGNIFILO: And so you would consider him a friend?

MR. AGNIFILO: And you considered KK a friend or no?

MR. AGNIFILO: Who else in the group would you consider your friends?

MR. AGNIFILO: Derek?

MR. AGNIFILO: The person who was in South Africa who was a friend?

MR. AGNIFILO: We're calling her Mia.

MR. AGNIFILO: Tell me about Mia.

MR. AGNIFILO: She could do it?

MR. AGNIFILO: Were there issues, from your experience, with her drinking from time to time?

MR. AGNIFILO: I'll go on.

MR. AGNIFILO: How well did you know her? How would you characterize your relationship with Mia?

MR. AGNIFILO: And she was close with Cassie just like you were close with Cassie?

MR. AGNIFILO: You were Cassie's best friend, that's how you see this, right?

MR. AGNIFILO: And I'm not saying anyone sees it differently, I'm just asking how you see it.

MR. AGNIFILO: Let me ask, I really want to understand this -- and we're going to get to this in a minute. In 2018, Mr. Combs comes to Cassie's apartment, you're there, you say he grabs you by the neck and he throws a wooden hanger at you?

MR. AGNIFILO: Cassie's house. And he does these things, right?

MR. AGNIFILO: And that spelled the end of your relationship with Cassie?

MR. AGNIFILO: And I want to understand this better, because by this point, you guys are best friends for 17 years?

MR. AGNIFILO: Right, 2001 to 2018, right? Okay. Do me a favor, if you don't say yes, he'll hit me.

MR. AGNIFILO: For 17 years, and you haven't spoken to her since?

MR. AGNIFILO: But she's married to another man about to have her third baby, she's not with Mr. Combs and --

MR. AGNIFILO: Let me do it again. I'm trying to understand this. At the sake of being Captain Obvious, it's May 2025?

MR. AGNIFILO: You have not spoken to Cassie in what, almost seven years?

MR. AGNIFILO: In that period of time, she left Sean Combs six and a half years ago?

MR. AGNIFILO: She's moved on with her life completely, right?

MR. AGNIFILO: Do you know, do you know if she's moved on with her life?

MR. AGNIFILO: Let me ask another question. How come you haven't rekindled?

MR. AGNIFILO: It all comes back to what you said on direct, tell me if I'm right, where she said to you that you're overreacting about the wooden hanger incident?

MR. AGNIFILO: And that, that ended a 17-year best friendship, just so I understand?

MR. AGNIFILO: But she didn't do it, right?

MR. AGNIFILO: Now, you reached a settlement agreement with her, right?

MR. AGNIFILO: Not with Mr. Combs?

MR. AGNIFILO: But we're not talking for the moment where the money is coming from. You reached a settlement agreement with Ms. Ventura?

MR. AGNIFILO: And I just want to understand, what do you think that she did?

MR. AGNIFILO: Yeah.

MR. AGNIFILO: You had a lawyer?

MR. AGNIFILO: I'm really just trying to understand it better. So you had a lawyer who you didn't use, right?

MR. AGNIFILO: And you made a demand of money to Cassie, correct?

MR. AGNIFILO: To who?

MR. AGNIFILO: Let me do it this way: tell the jury how it happened.

MR. AGNIFILO: And where were you and Cassie when you had this conversation?

MR. AGNIFILO: Where, what sort of place?

MR. AGNIFILO: So you and Cassie are in a pizza place?

MR. AGNIFILO: And you and Cassie are talking. Did you agree on a figure?

MR. AGNIFILO: She gave you a figure and you accepted it?

MR. AGNIFILO: Was it $50,000 or $30,000?

MR. AGNIFILO: You're sure?

MR. AGNIFILO: And it was just the two of you there?

MR. AGNIFILO: Mr. Combs wasn't there?

MR. AGNIFILO: No lawyers were there?

MR. AGNIFILO: Which is why it probably got done. Withdrawn. So you guys are having a conversation over pizza and she agrees that she's going to give you this money?

MR. AGNIFILO: And you accepted it?

MR. AGNIFILO: And you still never became friends again?

MR. AGNIFILO: I understand.

MR. AGNIFILO: Was that the last time you spoke with her?

MR. AGNIFILO: So in the pizza place talking about money is the last time you spoke to her?

MR. AGNIFILO: I want to show you a couple of photographs.

MR. AGNIFILO: First I want to look at defense exhibit for identification only 1620. It's going to be shown to the witness and the parties, but not yet the jury.

MR. AGNIFILO: You can see that's a photograph, right?

MR. AGNIFILO: Do you recognize all the three people in it?

MR. AGNIFILO: One of them is yourself?

MR. AGNIFILO: We offer 1620, your Honor.

MR. AGNIFILO: So now the jury can see it.

MR. AGNIFILO: There's you repping the Snow City. Who's in the middle?

MR. AGNIFILO: Who's the third person?

MR. AGNIFILO: Tell us, who's Bana?

MR. AGNIFILO: Let me take a step back. Mr. Combs and Cassie and yourself all did drugs together and then separately, correct?

MR. AGNIFILO: Do you remember a time when Mr. Combs was trying to get -- from what you could see, was trying to get Cassie to do less drugs?

MR. AGNIFILO: Do you remember about when that was?

MR. AGNIFILO: But was it for a period of time, more than a couple of days, a couple of weeks?

MR. AGNIFILO: Tell us what you remember about that.

MR. AGNIFILO: What is it?

MR. AGNIFILO: In addition to sending her to Mexico with Mia, do you remember being present for conversations -- from Mr. Combs. Withdrawn. Mr. Combs saying things in your presence along the lines of, Cassie, you need to do less drugs?

MR. AGNIFILO: Do you remember, the third person in this photo, Bana, from time to time, is it fair to say Bana would bring different drugs to you and Ms. Ventura?

MR. AGNIFILO: And do you recall that being a source of displeasure on the part of Sean Combs that he would say, I don't want Bana bringing drugs anymore?

MR. AGNIFILO: We're going to look at another photograph for identification only. 1621, Defendant's Exhibit 1621.

MR. AGNIFILO: Can you see that photo?

MR. AGNIFILO: And can you see that you're in it yourself?

MR. AGNIFILO: We offer it, your Honor.

MR. AGNIFILO: Do you recognize some of the people in the photo?

MR. AGNIFILO: Can we start with the person in the LA Dodgers hat there on the left side?

MR. AGNIFILO: Who's Elie?

MR. AGNIFILO: What does that involve, in your experience, what does it mean to be a manager?

MR. AGNIFILO: Who's above Elie with another baseball hat?

MR. AGNIFILO: Who is Rob Holiday?

MR. AGNIFILO: Can you see, you only see half of his face to Rob Holiday's -- over his left shoulder?

MR. AGNIFILO: And woman to the left of Rob?

MR. AGNIFILO: The top.

MR. AGNIFILO: Below that.

MR. AGNIFILO: Who is Keke Palmer?

MR. AGNIFILO: That is fine. Keep going over. Woman in the back there to the left?

MR. AGNIFILO: A man with the short beard there on the right?

MR. AGNIFILO: And who's right next to Diontae?

MR. AGNIFILO: And below Diontae, who's that woman?

MR. AGNIFILO: Fair to say, there was a lot of chaos with being in Combs's circle, correct?

MR. AGNIFILO: But from time to time you guys had a lot of fun?

MR. AGNIFILO: And you had a lot of fun a lot of the time, right?

MR. AGNIFILO: It was exciting, was it?

MR. AGNIFILO: And sometimes it was exciting for all the wrong reasons, right?

MR. AGNIFILO: But sometimes it was exciting for all the best reasons, right?

MR. AGNIFILO: And you all loved each other?

MR. AGNIFILO: And fair to say the people in this photo love each other?

MR. AGNIFILO: But you're the only one --

MR. AGNIFILO: But you loved some of them?

MR. AGNIFILO: Is that the right word for it, love?

MR. AGNIFILO: Can we also, for identification, look at 1602.

MR. AGNIFILO: I'm showing you photograph 1602, you're smiling. Do you recognize yourself in it?

MR. AGNIFILO: Other people are in it, too?

MR. AGNIFILO: I'm sorry. I have to ask to admit it into evidence.

MR. AGNIFILO: We offer 1602, your Honor.

MR. AGNIFILO: We're going to show it to the jury.

MR. AGNIFILO: Tell us who everybody is.

MR. AGNIFILO: Holding that umbrella?

MR. AGNIFILO: Where are you, can you tell?

MR. AGNIFILO: This is one of the three times you went to Burning Man with some of these folks?

MR. AGNIFILO: And that was fun?

MR. AGNIFILO: It was fun every time you went to Burning Man?

MR. AGNIFILO: And a lot of the places you guys went was fun?

MR. AGNIFILO: I'm going to ask you to look --

MR. AGNIFILO: We're going to take the pictures down for the moment.

MR. AGNIFILO: We're going to look in your binder at 1612.

MR. AGNIFILO: For the parties and the Court, we can pull up 1612, not for the jury yet.

MR. AGNIFILO: You can look on the screen or in the book, whatever is easier for you. In 2016, do you recall sending -- I don't know if you'd call it a poem or a passage to Sean Combs?

MR. AGNIFILO: Sure. Do you remember sending -- let me back up for a second. There were times when you thought that Ms. Ventura should leave Mr. Combs, right?

MR. AGNIFILO: And there were times when you thought that they were deeply in love and maybe should try to work it out?

MR. AGNIFILO: And you thought both things maybe in the same day, right?

MR. AGNIFILO: In the same week, in the same month?

MR. AGNIFILO: From your perspective, they were very much in love, correct?

MR. AGNIFILO: From your perspective, Ms. Ventura very much loved Mr. Combs, correct?

MR. AGNIFILO: And from your perspective, he very much loved her also, right?

MR. AGNIFILO: We'll talk about him first. From your perspective, he was a flawed person, correct?

MR. AGNIFILO: And did you come to think that he was doing things to not take good care of himself?

MR. AGNIFILO: Let me ask a better question. Did you try to help him be a better person from time to time?

MR. AGNIFILO: And did you send him this message with that in mind, trying to help him be a better person?

MR. AGNIFILO: It's not. Let me back up.

MR. AGNIFILO: Do you recognize your cellphone number on the top-left?

MR. AGNIFILO: Do you recognize FB an abbreviation for Frank Black, which is Mr. Combs?

MR. AGNIFILO: Your Honor, we offer it.

MR. AGNIFILO: I've never known a poem offered for its truth and I think it's in line with what we're talking about.

MR. AGNIFILO: It's 2016. She has seen Sean Combs do some terrible things. He was violent with Cassie, he's been jealous, he's been difficult, and here she is in 2016 sending him something as a pure gesture of love to make him be a better person, which she already said she tries to do, and it's important for that, that this is -- we get to tell the story of a relationship of friends rooting for them at times and telling them at times that they should break it up, and we embrace it all, and this is part of that narrative.

MS. GERAGOS: For relevance, your Honor. Tomorrow, Ms. Ventura's mom is going to testify about a time she called the police on Mr. Combs, this is three days after that event. And so it's also relevant.

MR. AGNIFILO: I don't think we need 803.3. It's not offered for the truth. I don't need a hearsay exception. It's not hearsay.

MR. AGNIFILO: Your Honor, we offer 1612.

MR. AGNIFILO: On the left side, we see FB, that's Frank Black, that's Sean Combs, correct? Feel free to read it.

MR. AGNIFILO: So we have FB on the left side saying, hey, I never really asked you to call me, but I need you to call me to ask you about Cass birthday. I won't put you in an effed up position. Do you see that?

MR. AGNIFILO: When is Ms. Ventura's birthday, do you know?

MR. AGNIFILO: So this is a week before her birthday?

MR. AGNIFILO: Then he goes on to say, even if you can't just say that, it's a five-minute convo about her birthday. This is I think what you said on direct examination, is sometimes he reaches out, and then he reaches out, and then he reaches out, and he's kind of doing that here?

MR. AGNIFILO: Then you write back, K, 2 min, two minutes, right, and he says thanks. And then a few minutes later -- a few seconds later, actually, you send what's on the other side.

MR. AGNIFILO: Right. I'm sorry. So somehow he sends you a message without any content?

MR. AGNIFILO: And then you send this back, right?

MR. AGNIFILO: Do you recognize this?

MR. AGNIFILO: Do you know who Louise Hay is?

MR. AGNIFILO: Does that sound right?

MR. AGNIFILO: Tell me if this is right: Louise Hay has written books about affirmation and --

MR. AGNIFILO: It's a question.

MR. AGNIFILO: So the question is: do you know if Louise Hay is an author of self-affirmation and self-love books?

MR. AGNIFILO: And you decide to send this to Mr. Combs, correct?

MR. AGNIFILO: And do you know why you're sending this?

MR. AGNIFILO: If we look at it, it's all about loving one self, correct?

MR. AGNIFILO: Did you believe Mr. Combs did not love himself?

MR. AGNIFILO: Is this, is it fair to say — and I'm guided by you — that you're sending him this here, A, to help him?

MR. AGNIFILO: To give him words of encouragement?

MR. AGNIFILO: To give him words of encouragement, right?

MR. AGNIFILO: OK. Do you remember giving him words of encouragement at other times?

MR. AGNIFILO: OK. But you said a few minutes ago, there were times when you thought that he and Cassie should try to stay together and work things out, correct?

MR. AGNIFILO: OK. Sometimes yes and then sometimes no?

MR. AGNIFILO: All right. I'm going to show you a few more photos and then we really are almost done. Before we do that, I want to talk for a second about the incident where he came into Cassie's apartment and put his hands on your neck and threw the --

MR. AGNIFILO: -- the wooden hanger. I'm going to do this very quickly. I apologize for asking about it.

MR. AGNIFILO: I'm sorry to ask this question. Were you and Ms. Ventura, were you using any drugs at the time?

MR. AGNIFILO: OK. Do you remember there being any drugs on the table?

MR. AGNIFILO: You don't remember?

MR. AGNIFILO: OK. And you said -- I know, just to summarize it, not the exact words -- when he came in, he said something. Tell us generally what he said.

MR. AGNIFILO: And at the time, did you know the answer to that question?

MR. AGNIFILO: OK. But it turns out she was cheating on him with somebody?

MR. AGNIFILO: Right?

MR. AGNIFILO: OK. And at the time, at the moment, you didn't know who it was?

MR. AGNIFILO: OK. Now, you said that you got a concussion?

MR. AGNIFILO: OK. You have to answer yes or no.

MR. AGNIFILO: OK. Now, I just have a couple of questions around a few details. I apologize. So you said you went to an urgent care, correct?

MR. AGNIFILO: You didn't go to the hospital?

MR. AGNIFILO: OK. Do you remember when you first told the government about this, back on December 7, 2023, you said you went to the hospital? Do you remember that? Only if you remember.

MR. AGNIFILO: OK. Do you remember saying, when you first spoke to the government on December 7, 2023, that it was bleed -- it was bleeding?

MR. AGNIFILO: No?

MR. AGNIFILO: All right. Let's just pull up for the witness, if we could, 3513-001 at page five.

MR. AGNIFILO: So this is just for you to look at. Just take a look at it, and I'm going to ask you a couple questions. I think it's on page five. I think it's the second, the last full -- no, the second to last full paragraph.

MR. AGNIFILO: No, the one below that.

MR. AGNIFILO: Two, just down. Read that to yourself and look at me when you're done.

MR. AGNIFILO: OK. So, the only question is, do you remember telling the government that you went to a friend's house and then to the hospital to treat your wounds? Do you remember saying that?

MR. AGNIFILO: You remember saying that?

MR. AGNIFILO: No, I'm not saying they are. I'm just trying to understand kind of what happened. So you remember telling them hospital?

MR. AGNIFILO: OK. Fine. Let's pull it back up again and I want to ask about the next thing, too.

MR. AGNIFILO: OK. Do you remember telling the government that the hospital staff told you they would call the Los Angeles Police Department?