MS. COMEY: Good afternoon, Mr. Nash. I would like to follow up on a topic we were touching on before the break.
So before the break you testified about Ms. Ventura's recording of music; do you remember that?
DEONTE NASH: Yes, ma'am.
MS. COMEY: And I think earlier in your testimony you testified that you had personally heard Mr. Combs threaten not to put out some of Ms. Ventura's music; did I hear that right?
DEONTE NASH: Yes.
MS. COMEY: Could you please tell the jury in what context you heard Mr. Combs threaten not to put out Ms. Ventura's music?
DEONTE NASH: He told her that one time if she keep -- if she keeps having a smart ass mouth, her little mix tape won't be coming out.
MS. COMEY: Do you remember about when that was?
DEONTE NASH: It had to be 2012, '13.
MS. COMEY: And do you remember what Ms. Ventura was doing before Mr. Combs made that comment?
DEONTE NASH: I think she just responded to him in a normal fashion.
MS. COMEY: In a normal fashion.
Do you remember what Mr. Combs' tone was when he made that threat to her?
DEONTE NASH: Pretty regular.
MS. COMEY: Calm?
DEONTE NASH: Calm.
MS. COMEY: I want to switch topics now. Approximately how many times in person have you witnessed Mr. Combs be violent with Ms. Ventura?
DEONTE NASH: Quite a few, but three that really stand out.
MS. COMEY: So do some of those stand out more in your mind than others?
DEONTE NASH: Yes.
MS. COMEY: I want to talk about some of those.
MS. COMEY: First, I would like to pull up what's in evidence as a sealed exhibit, please. And that is sealed Exhibit 2A-404, just for the jury, the witness and the Court, please.
Is that on your screen?
THE COURT: It's not on the screen yet.
MS. COMEY: Let me know when it's on your screen, please, Mr. Nash.
DEONTE NASH: It's there.
MS. COMEY: Okay. Without saying her name, would you please tell us just yes or no if you recognize the person in that photograph?
DEONTE NASH: Yes.
MS. COMEY: Okay. I'm going to call that person Mia, and I would ask that you do the same, please. Okay?
DEONTE NASH: Yes.
MS. COMEY: Okay.
MS. COMEY: We can take that down. Thank you so much. And we can turn on the public screens, Mr. Deputy. Thank you.
MS. COMEY: How many times, if any, was Mia present with you when you witnessed Mr. Combs be violent with Cassie?
DEONTE NASH: One.
MS. COMEY: About what year was this?
DEONTE NASH: Maybe 2013, '14.
MS. COMEY: And where were you before the violence started?
DEONTE NASH: At Cassie's house.
MS. COMEY: Which home of Cassie's was this?
DEONTE NASH: 818 Doheny.
MS. COMEY: And is that in Los Angeles?
DEONTE NASH: Yes.
MS. COMEY: Is that an apartment or a house?
DEONTE NASH: Apartment.
MS. COMEY: What were you and Mia helping Cassie get ready for before the violence started?
DEONTE NASH: We were packing Cassie for the OVO Fest in Canada.
MS. COMEY: What is the OVO fest in Canada?
DEONTE NASH: Drake's music festival.
MS. COMEY: Right before the violence started, where was Cassie in the apartment?
DEONTE NASH: On the couch sleep.
MS. COMEY: She was asleep?
DEONTE NASH: Yes.
MS. COMEY: Where were you?
DEONTE NASH: Between the living room where she was sleeping and her second bedroom, which was where her closet was, packing.
MS. COMEY: And do you remember where Mia was?
DEONTE NASH: No.
MS. COMEY: Who came to the door?
DEONTE NASH: I did.
MS. COMEY: Did you hear a knock at the door?
DEONTE NASH: Yes.
MS. COMEY: What did you do in response?
DEONTE NASH: I opened it.
MS. COMEY: Who did you see outside the apartment door?
DEONTE NASH: Puff.
MS. COMEY: What did Mr. Combs say when you opened the apartment door for him?
DEONTE NASH: Bitch, didn't I tell you to answer the phone.
MS. COMEY: Who did you understand he was speaking to when he said bitch, didn't I tell you to answer the phone?
DEONTE NASH: Cassie.
MS. COMEY: What did you see Mr. Combs do after he said that?
DEONTE NASH: Grab her by the hair and pull her off of the couch and start hitting her.
MS. COMEY: When you say grab her by the hair, who did Mr. Combs grab by the hair?
DEONTE NASH: Cassie.
MS. COMEY: And after Mr. Combs grabbed Cassie by the hair, what did he do next?
DEONTE NASH: He began to hit her.
MS. COMEY: Could you tell whether it was with an open or closed fist?
DEONTE NASH: Not really, no.
MS. COMEY: Could you tell how hard he was hitting her?
MR. DONALDSON: Objection.
THE COURT: Overruled.
MS. COMEY: Could you tell how hard he was hitting her?
DEONTE NASH: Pretty hard.
MS. COMEY: What was Mr. Combs saying as he pulled Cassie by the hair off the couch and hit her?
DEONTE NASH: I just remember y'all going to stop fucking with me.
MS. COMEY: What was Mr. Combs' tone and demeanor?
DEONTE NASH: He was in a rage.
MS. COMEY: Where did you, Mia, and Cassie go after Mr. Combs -- immediately after Mr. Combs started hitting Cassie?
DEONTE NASH: We ran to her bedroom.
MS. COMEY: To Cassie's bedroom?
DEONTE NASH: Cassie's bedroom, yes.
MS. COMEY: What did you, Mia, and Cassie attempt to do in her bedroom?
DEONTE NASH: Try to close the door.
MS. COMEY: What happened when you, Mia, and Cassie tried to close the bedroom door?
DEONTE NASH: Puff pushed it open.
MS. COMEY: After Mr. Combs pushed the bedroom door open, what did you see him do next?
DEONTE NASH: He continued to attack Cassie.
MS. COMEY: And how was he attacking Cassie?
DEONTE NASH: With his fists and kicking her.
MS. COMEY: And what parts of Cassie's body did you see him kick and hit?
DEONTE NASH: I mean, it was so fast.
MS. COMEY: But did you see him --
DEONTE NASH: Yes.
MS. COMEY: -- make contact with her body?
DEONTE NASH: Yes, he made contact, yes.
MS. COMEY: What did you do to try to help Cassie?
DEONTE NASH: I jumped on Puff's back.
MS. COMEY: How did Mr. Combs react when you jumped on his back?
DEONTE NASH: He threw me off.
MS. COMEY: Where did you land?
DEONTE NASH: On the floor.
MS. COMEY: Were you injured?
DEONTE NASH: I was a little sore.
MS. COMEY: What did Mia do to try to help Cassie?
DEONTE NASH: Jump on his back as well.
MS. COMEY: When you say his back, whose back?
DEONTE NASH: Puff.
MS. COMEY: How did Mr. Combs react when Mia jumped on Mr. Combs' back?
DEONTE NASH: She was thrown off as well.
MS. COMEY: What did Mr. Combs do after throwing you and Mia off of his back?
DEONTE NASH: Continued to hit Cassie until her head hit the edge of the bed frame.
MS. COMEY: What did you see happen after Cassie's head hit the edge of the bed frame?
DEONTE NASH: He still continued to hit her for, you know, a short time, and when he noticed the blood, he just panicked.
MS. COMEY: So what blood did you see after Cassie's head hit the bed frame?
DEONTE NASH: Blood coming from her head.
MS. COMEY: How much blood did you see coming from Cassie's head?
DEONTE NASH: A lot.
MS. COMEY: And did Mr. Combs stop hitting Cassie immediately after her head hit the bed?
DEONTE NASH: No.
MS. COMEY: For about how much longer did he continue to hit her as she was bleeding from the head?
DEONTE NASH: A couple of seconds.
MS. COMEY: After that, at that point, were you still in the room?
DEONTE NASH: Yes.
MS. COMEY: And where was Mia?
DEONTE NASH: Getting towels.
MS. COMEY: And where -- what were the towels for?
DEONTE NASH: Cassie's head.
MS. COMEY: And where was Cassie?
DEONTE NASH: She went into the second bathroom.
MS. COMEY: As you all were leaving the bedroom, what if anything did Mr. Combs say to you, Mia, and Cassie?
DEONTE NASH: Look what y'all made me do.
MS. COMEY: What if any phone calls did you try to make after seeing all the blood from Cassie's head?
DEONTE NASH: I tried to call 9-1-1.
MS. COMEY: What happened when you tried to call 9-1-1?
DEONTE NASH: I was immediately told to hang up.
MS. COMEY: Do you remember who told you to hang up?
DEONTE NASH: No.
MS. COMEY: As you sit here today, can you remember?
DEONTE NASH: No.
MS. COMEY: Did you hang up?
DEONTE NASH: Yes.
MS. COMEY: So did the call connect?
DEONTE NASH: No.
MS. COMEY: What if anything did Mr. Combs say about where Cassie was going to go next?
DEONTE NASH: The plastic surgeon.
MS. COMEY: Who did Mr. Combs say was going to go to the plastic surgeon with Cassie?
DEONTE NASH: D-Roc.
MS. COMEY: Who is D-Roc?
DEONTE NASH: A friend of his, his security.
MS. COMEY: Whose security?
DEONTE NASH: Puff.
MS. COMEY: Can we please pull up what's in evidence as Government Exhibit 2A-202.
MS. COMEY: Do you recognize the person in this photograph?
DEONTE NASH: Yes.
MS. COMEY: Who is that?
DEONTE NASH: D-Roc.
MS. COMEY: Do you know him by any other names?
DEONTE NASH: D-Roc is fine.
MS. COMEY: And do you know what his role was for Mr. Combs at the time that Cassie had this head injury?
DEONTE NASH: Security.
MS. COMEY: We can take that down. Thank you.
MS. COMEY: After that incident, when was the next time that you saw Cassie, either over FaceTime or in person?
DEONTE NASH: The next day.
MS. COMEY: And how did you see her the next day?
DEONTE NASH: FaceTime or something like that.
MS. COMEY: And when you saw her, what if any injuries did you see?
DEONTE NASH: She had a -- stitches on her forehead. She had a gash on her forehead.
MS. COMEY: And you made a gesture, was it above her eyebrow?
DEONTE NASH: It was like in the eyebrow.
MS. COMEY: I want to talk about another time you witnessed violence.
Was there a time when you and Cassie were cooking in her apartment before Mr. Combs became violent?
MR. DONALDSON: Objection, Judge. Form of question. I'm sorry. Objection. Sorry.
THE COURT: Rephrase the question.
MR. DONALDSON: Sorry, Judge. Sorry.
BY MS. COMEY:
MS. COMEY: I want to direct your attention to a night when you were cooking with Cassie in her apartment.
Does that ring a bell?
DEONTE NASH: Yes.
MS. COMEY: About what year are we talking about?
DEONTE NASH: '13, '14.
MS. COMEY: 2013 or 2014?
DEONTE NASH: Yes.
MS. COMEY: What apartment were you and Cassie in?
DEONTE NASH: 818 Doheny.
MS. COMEY: The same apartment that you just talked about?
DEONTE NASH: Yes.
MS. COMEY: And this incident that we're about to talk about, was it before or after Cassie cut her head open on the bed frame?
DEONTE NASH: After.
MS. COMEY: So who was at the apartment this evening?
DEONTE NASH: Just me and Cassie.
MS. COMEY: And who came over?
DEONTE NASH: Puff.
MS. COMEY: About what time of day do you remember Mr. Combs coming over to the apartment?
DEONTE NASH: Nighttime.
MS. COMEY: And what do you remember Mr. Combs saying when he first came over to the apartment?
DEONTE NASH: He just said, hey, and that he wanted to talk to Cassie for a minute.
MS. COMEY: And where did he and Cassie go?
DEONTE NASH: To her bedroom.
MS. COMEY: And what happened after they went into the bedroom?
DEONTE NASH: He grabbed her as they were walking out, he grabbed her like by her hair and the back of her shirt and starting pushing her out, and he was like, I don't give a fuck, you going to get the fuck up out of my house, y'all going to get the fuck up out of my house.
MS. COMEY: So a few follow-up questions.
First, when Mr. Combs referred to "my house," what did you understand he was referring to?
MR. DONALDSON: Objection.
THE COURT: Overruled.
DEONTE NASH: Cassie's --
MS. COMEY: You got to wait for the judge.
THE COURT: I said overruled.
MS. COMEY: So sorry, your Honor.
THE COURT: That's okay. Far away from the mic.
MS. COMEY: What did you understand he meant when he was referring to "my house?"
DEONTE NASH: Cassie's house.
MS. COMEY: And had you heard how this argument had started in the bedroom?
DEONTE NASH: No.
MS. COMEY: And what did you see Mr. Combs doing to Cassie as he was saying get out of my house?
DEONTE NASH: Grabbing her by the hair and the back of her shirt or jacket and was pushing her out the house.
MS. COMEY: And where did Mr. Combs ultimately push Ms. Ventura?
DEONTE NASH: Halfway out of the door.
MS. COMEY: And after he pushed her there, what did he do to you?
DEONTE NASH: He began to do the same to me. And then he told me to go downstairs and she'll be right down.
MS. COMEY: You said he did the same to you. What did Mr. Combs do to you?
DEONTE NASH: Well, he was more so popping me in the back of the head, because I don't have hair. And grabbing me by my shirt and pushing --
MS. COMEY: When you said he was popping you in the back of your head, what was he doing to your head?
DEONTE NASH: Like a, you know, slap. You pop somebody in the head.
MS. COMEY: Slapping you with his hand?
DEONTE NASH: Yes. Yes.
MS. COMEY: Where did you go after Mr. Combs pushed you and Cassie out of the apartment?
DEONTE NASH: To get my car from valet.
MS. COMEY: So did you go downstairs?
DEONTE NASH: Downstairs, yes.
MS. COMEY: And who did you see when you went downstairs?
DEONTE NASH: Security.
MS. COMEY: Whose security?
DEONTE NASH: Puff.
MS. COMEY: Do you remember who from security?
DEONTE NASH: No.
MS. COMEY: What did security say to you when you got downstairs?
MR. DONALDSON: Objection.
MS. COMEY: I can rephrase, your Honor.
THE COURT: Okay.
MS. COMEY: What if any instructions did security give you when you got downstairs?
MR. DONALDSON: Same objection.
THE COURT: That's overruled.
DEONTE NASH: That I needed to wait for her to -- Puff to come down.
MS. COMEY: So what did you do?
DEONTE NASH: I was blocked in, so I waited.
MS. COMEY: What was blocking you in?
DEONTE NASH: Security.
MS. COMEY: Security's cars?
DEONTE NASH: No. Security.
MS. COMEY: Oh, just security --
DEONTE NASH: Yes.
MS. COMEY: And then what happened next?
DEONTE NASH: They came down.
MS. COMEY: When you say "they," what do you mean?
DEONTE NASH: When Puff and Cassie came down, when they came down, Cassie got in my car. Puff began to berate us both. And he finally let us go --
MS. COMEY: Let me pause you there. You said Mr. Combs began to berate you both. Who was he berating?
DEONTE NASH: Cassie and I.
MS. COMEY: And what was Mr. Combs saying as far as you can remember?
DEONTE NASH: We not going to be playing with him. We can just take our broke ass and ride into the sunset.
MS. COMEY: Where did you and Cassie go next?
DEONTE NASH: We drove off. And as we drove off, we got a phone call to pull over --
MR. DONALDSON: Objection.
MS. COMEY: I can ask another question, your Honor.
THE COURT: Let's have a new question.
MS. COMEY: Yep.
MS. COMEY: After you drove, what -- drove away from the building, what if any phone calls did you and Cassie receive?
DEONTE NASH: Phone call from Puff.
MS. COMEY: What did Puff say?
DEONTE NASH: For us to pull over.
MS. COMEY: And what did you do?
DEONTE NASH: Pulled over.
MS. COMEY: What happened after you pulled over?
DEONTE NASH: He came to the window and began to talk to Cassie.
MS. COMEY: Who came to the window?
DEONTE NASH: Puff.
MS. COMEY: What did you hear Mr. Combs say when he came up to the car window?
DEONTE NASH: That she fucked up. And that he was going to put her sex tapes on the internet. He was going to release them on schedule. And that he was going to first start by sending them to her parents' jobs, and he was going to get them fired, and that her brother was a bitch, and that Puff was the only one that -- that protected her.
MS. COMEY: How did Cassie react to Mr. Combs saying all of these things to her?
DEONTE NASH: She was in tears.
MS. COMEY: What was Mr. Combs' tone when he said these things to Cassie?
DEONTE NASH: He was pretty in between.
MS. COMEY: In between what?
DEONTE NASH: Angry, but he wasn't shouting.
MS. COMEY: After Mr. Combs finished saying all of those things, what did you and Ms. Ventura do next?
DEONTE NASH: We drove off.
MS. COMEY: And where did you ultimately drive to?
DEONTE NASH: To my house.
MS. COMEY: As you were driving away, what was Cassie's demeanor?
DEONTE NASH: She was in tears.
MS. COMEY: What did you say to try to comfort her?
MR. DONALDSON: Objection. Objection.
THE COURT: Overruled.
DEONTE NASH: I told her, I said, well, girl if he wants to release the -- release the sex tapes, then let him because he's on them too.
MS. COMEY: What did you mean when you said he's on them too?
DEONTE NASH: That Puff was on them too.
MS. COMEY: On the videos?
DEONTE NASH: Yes.
MS. COMEY: How did Cassie respond when you said that Puff was on the videos too?
DEONTE NASH: She said that she -- that he wasn't on the videos, that it was him taping her with other guys.
MS. COMEY: And did she say what she was doing with those other guys?
DEONTE NASH: Yeah, having sex with the other guys.
MS. COMEY: What did she say about whether, in that moment, in 2013, 2014, she wanted to have sex with other guys?
MR. DONALDSON: Objection.
THE COURT: That's overruled.
DEONTE NASH: That she didn't want to.
MS. COMEY: And what did she say about why she was in that moment?
DEONTE NASH: Because Puff wanted her to.
MS. COMEY: After you got back to your house, who if anyone called you and Cassie?
DEONTE NASH: Puff and Derek Roche.
MS. COMEY: What do you remember about those phone calls?
DEONTE NASH: Derek Roche called me and told me that he had given Puff my address and that Puff was on the way.
MR. DONALDSON: Objection.
MS. COMEY: It's not offered for the truth, your Honor, just impact on the listener.
THE COURT: That's overruled.
MS. COMEY: How did you and Cassie react when Derek told you that Puff was on the way?
DEONTE NASH: We panicked.
MS. COMEY: And then what did you do?
DEONTE NASH: I drove her to Sunset Boulevard so she can catch a yellow taxi.
MS. COMEY: Why did you drive Ms. Ventura to Sunset Boulevard to get a taxi?
DEONTE NASH: Uber wasn't really a thing then.
MS. COMEY: What did Cassie tell you she was going to do when she got into the taxi?
DEONTE NASH: She would call me when she got to where she was.
MS. COMEY: Did she tell you where she was going at that point or no?
DEONTE NASH: No. No.
MS. COMEY: What did you do after dropping Cassie off to get a taxi?
DEONTE NASH: I went back home.
MS. COMEY: What happened when you went back home?
DEONTE NASH: Puff came to my house with Derek Roche and D-Roc.
MS. COMEY: What happened when Mr. Combs, D-Roc, and Derek Roche came to your house?
DEONTE NASH: Puff came in and he was like where the fuck is she. He started looking all around my house. In the closets, he went in the oven, I don't know why he looked in the oven. And he asked me where she was.
MS. COMEY: Who did you understand he was referring to when Mr. Combs said where is she?
DEONTE NASH: Cassie.
MS. COMEY: After Mr. Combs looked around your house, what happened next?
DEONTE NASH: He then took my phone and my car keys.
MS. COMEY: And as Mr. Combs took your phone, what if any phone calls came into your phone?
DEONTE NASH: Cassie called.
MS. COMEY: And what happened when Cassie called your phone?
DEONTE NASH: When he saw the number, he --
MR. DONALDSON: Objection.
THE COURT: Can you rephrase the question.
MS. COMEY: Yes, your Honor.
MS. COMEY: Could you tell what phone number or what ID came up on your phone?
DEONTE NASH: The Le Montrose.
MS. COMEY: And what's the Le Montrose?
DEONTE NASH: A hotel in the West Hollywood.
MS. COMEY: And were you able to see the Le Montrose come up on the screen of your phone?
DEONTE NASH: Yes.
MS. COMEY: As Mr. Combs was holding it?
DEONTE NASH: Yes.
MS. COMEY: And after that came up on the screen of your phone, what did Mr. Combs say?
DEONTE NASH: He said, oh, she at the Le Montrose, let's go.
MS. COMEY: So then what did Mr. Combs tell you to do?
DEONTE NASH: He told me to get in the car and they will follow me to the Le Montrose so I can get her to come down.
MS. COMEY: And who did you understand would be following you?
DEONTE NASH: Puff and security.
MR. DONALDSON: Objection.
THE COURT: That's overruled.
MS. COMEY: Who from security?
DEONTE NASH: D-Roc.
MS. COMEY: So what did you do?
DEONTE NASH: I hopped in a car and drove to the Le Montrose.
MS. COMEY: And as you drove, where was your phone?
DEONTE NASH: With Mr. Combs.
MS. COMEY: Where did you drive to?
DEONTE NASH: Le Montrose.
MS. COMEY: What happened after you got to the Le Montrose?
DEONTE NASH: When I walked up, he kind of like stopped before he went in and he told me that since -- because we got shipments there a lot, I knew the people so --
MR. DONALDSON: Objection. Objection.
MS. COMEY: Let me break it down if that's okay, your Honor.
THE COURT: It's okay.
MS. COMEY: Thank you, your Honor.
MS. COMEY: So, first, who was talking to you?
DEONTE NASH: Puff.
MS. COMEY: And backing up, before this day, what if any connection did you personally have to the Le Montrose?
DEONTE NASH: We always got packages there, and most of the staff stayed there.
MS. COMEY: Most of the staff meaning whose staff?
DEONTE NASH: Bad Boy staff.
MS. COMEY: So what did Mr. Combs say to you outside of the Le Montrose?
DEONTE NASH: Since I want to be all chummy chummy with those bitches, go upstairs and get Cassie.
MS. COMEY: How did you respond?
DEONTE NASH: I told him that if he gave me my phone back -- I told him that he needed to give me my phone back because she would think it was weird that I didn't have my phone.
MS. COMEY: And what did Mr. Combs do in response?
DEONTE NASH: He gave it back.
MS. COMEY: And then where did you go?
DEONTE NASH: Upstairs to her room.
MS. COMEY: When you went inside the Le Montrose, who came with you?
DEONTE NASH: D-Roc, and Toni Bias Fletcher showed up some kind of way.
MS. COMEY: Who is Toni Bias Fletcher?
DEONTE NASH: Puff's old chief of staff.
MS. COMEY: Can we please pull up what's in evidence as Government Exhibit 2A-305.
MS. COMEY: Do you recognize the person in that photograph?
DEONTE NASH: Yes.
MS. COMEY: Who is that?
DEONTE NASH: Toni Bias Fletcher.
ms.com: We can take that down. Thank you.
MS. COMEY: How did you and Toni and D-Roc know which room to go to?
DEONTE NASH: The people at the front desk told me.
MS. COMEY: And then where did you go?
DEONTE NASH: To Cassie's room.
MS. COMEY: And what happened when you got to Cassie's room?
DEONTE NASH: I opened the door and turned on the light.
MS. COMEY: And what happened when you turned on the light to Cassie's room?
DEONTE NASH: She jumped up.
MS. COMEY: Who jumped up?
DEONTE NASH: Cassie.
MS. COMEY: And how was her demeanor based on her appearance -- withdrawn.
Based on your observations of her appearance, what did her demeanor appear to be when she jumped up?
DEONTE NASH: She was frightened.
MS. COMEY: What did you and D-Roc and Toni say to Cassie?
DEONTE NASH: That Puff was downstairs looking for her.
MS. COMEY: How did Cassie react when she heard that?
DEONTE NASH: She said, oh, no. And then she went towards the balcony. She said she was going to go over the balcony.
MR. DONALDSON: Objection. Objection, your Honor.
THE COURT: That's sustained. The jury should disregard the witness's last answer.
Ms. Comey, you can ask a different question or rephrase.
MS. COMEY: Did Cassie make any statements about what her intent was to do in the immediate future?
MR. DONALDSON: Objection.
THE COURT: That's overruled.
MS. COMEY: Did he make any statements about what her intent was to do in the immediate future?
DEONTE NASH: Yes. She said that she was going to climb over the balcony.
MS. COMEY: How high up was the balcony?
DEONTE NASH: It wasn't the first floor.
MS. COMEY: Do you remember what floor it was on?
DEONTE NASH: No.
MS. COMEY: How did you and D-Roc and Toni react when Cassie said she was going to go over the balcony?
DEONTE NASH: We told her no and that we would sneak her out the side.
MS. COMEY: So then where did Cassie go?
DEONTE NASH: I assume out the side.
MS. COMEY: Where did you go?
DEONTE NASH: Back through the front.
MS. COMEY: Now, when you say out the side, what do you mean by the side of the Le Montrose?
DEONTE NASH: The side of the hotel I guess.
MS. COMEY: And then where did you go?
DEONTE NASH: I went back to the front of the hotel.
MS. COMEY: And who did you see when you went back to the front of the hotel?
DEONTE NASH: Puff and some other security guards.
MS. COMEY: Whose security guards did you see?
DEONTE NASH: Puff's.
MS. COMEY: About how many of Mr. Combs' security guards did you see outside of the Le Montrose?
DEONTE NASH: Maybe four or five.
MS. COMEY: And what if any vehicles did you see with Mr. Combs and his security staff?
DEONTE NASH: An SUV and I don't remember the other one.
MS. COMEY: Do you remember what color SUV?
DEONTE NASH: No. I mean, I'm sure -- no.
MS. COMEY: What if any conversation did you and Mr. Combs have when you went outside?
DEONTE NASH: I told him that she -- she had left the room and he told me that I played him.
MS. COMEY: What happened next?
DEONTE NASH: As he was talking, I just hopped in the car and drove off.
MS. COMEY: Where were you driving to?
DEONTE NASH: I was going to drive home.
MS. COMEY: And what happened?
DEONTE NASH: I noticed that a car was following me.
MS. COMEY: Did you recognize the car?
DEONTE NASH: Yes.
MS. COMEY: From where?
DEONTE NASH: One of the same cars that was outside of the Le Montrose.
MS. COMEY: And who had been in or next to those car -- one of those cars outside of the Le Montrose?
MR. DONALDSON: Objection.
THE COURT: Overruled.
DEONTE NASH: Puff and security.
MS. COMEY: What did you do when you saw this car that you recognized driving behind you?
DEONTE NASH: I turned off my lights and drove really fast until I -- until I lost them.
MS. COMEY: And then where did you go?
DEONTE NASH: To the Universal Sheraton.
MS. COMEY: Why did you go to a hotel?
DEONTE NASH: Because I didn't think my home was safe to go to that night.
MS. COMEY: When did you go back to your home?
DEONTE NASH: The next morning.
MS. COMEY: And what did you find when you went back to your home?
DEONTE NASH: My backpack was stolen.
MS. COMEY: What had been in that backpack?
DEONTE NASH: My identification, thousand dollars cash, and my iPad.
MS. COMEY: Why did you have a thousand dollars cash in your backpack?
MR. DONALDSON: Objection.
THE COURT: It's overruled.
DEONTE NASH: Generally when Puff would --
MR. DONALDSON: Object -- A. -- go be irate, I kept $500 for a deposit for the hotel and $500 for the room so that I didn't have to put my name on a hotel room.
MR. DONALDSON: Objection.
MS. COMEY: Why didn't you want to put your name --
THE COURT: Hold on. When the question is being asked, if you object, then I have no idea what the objection is or what the question is.
So let's get the question, and then, Mr. Donaldson, I'll give you a chance for the objection.
MR. DONALDSON: Judge, just for the record I was actually objecting to the prior answer that he started with generally. I didn't want to interrupt his answer.
THE COURT: That's overruled.
Ms. Comey, can we get a new question.
MS. COMEY: Yes, your Honor. Thank you.
MS. COMEY: Why, Mr. Nash, did you not want to put your name on a hotel where you were staying?
DEONTE NASH: Because I didn't want Puff to find me.
MS. COMEY: Switching topics a bit.
How many times, if any, do you remember seeing Mr. Combs slap Cassie across the face?
DEONTE NASH: Once.
MS. COMEY: Where was this?
DEONTE NASH: Outside in the parking lot at a studio.
MS. COMEY: At which studio?
DEONTE NASH: I just remember it was in like North Hollywood.
MS. COMEY: And who do you remember being in the studio parking lot?
DEONTE NASH: It was quite a few people.
MS. COMEY: About what year was this?
DEONTE NASH: 2015.
MS. COMEY: And what did you see happen?
DEONTE NASH: I just heard commotion, and I looked over, and by the time I looked over, he slapped her.
MS. COMEY: Who slapped who?
DEONTE NASH: Puff slapped Cassie.
MS. COMEY: Where?
DEONTE NASH: In her face.
MS. COMEY: What did Mr. Combs say as he slapped Cassie in the face?
DEONTE NASH: Get this bitch out of here.
MS. COMEY: What did you do in response?
DEONTE NASH: Got her out of there.
MS. COMEY: And how did Cassie react to being slapped in the face?
DEONTE NASH: She was in tears.
MS. COMEY: During Cassie's relationship with Mr. Combs, what if any movies are you aware of that she appeared in?
DEONTE NASH: Step Up 3, The Perfect Match, and Honey 3.
MS. COMEY: I want to talk about The Perfect Match. Do you remember about when the premiere of that movie was?
DEONTE NASH: 2015, '16.
MS. COMEY: Are you estimating?
DEONTE NASH: Yes.
MS. COMEY: Who helped her get ready for that premiere?
DEONTE NASH: Derek Roche and I think Rokael, the makeup artist.
MS. COMEY: And who if anyone did you FaceTime with while Cassie was getting ready for that premiere?
DEONTE NASH: Derek.
MS. COMEY: And when Derek FaceTimed with you, did you talk with Cassie?
DEONTE NASH: Yes.
MS. COMEY: And when you saw Cassie's face over FaceTime, what did you see?
DEONTE NASH: That she had a black eye.
MS. COMEY: When was the next time you saw Cassie in person after seeing that black eye over FaceTime?
DEONTE NASH: At the premiere.
MS. COMEY: When you saw Cassie at the premiere, what if any injuries could you see on her face?
DEONTE NASH: I could see the black eye under the makeup.
MS. COMEY: But was there makeup covering it?
DEONTE NASH: Yes.
MR. DONALDSON: Objection.
THE COURT: Overruled.
MS. COMEY: How much makeup?
DEONTE NASH: A lot.
MS. COMEY: While you were at the premiere, what if any interactions did you observe between Mr. Combs and Cassie?
DEONTE NASH: He just kept pulling her next to him any time she would try to, you know, have a conversation with someone. And then I notice him grabbing at her side and she would, like, jump.
MR. DONALDSON: Objection, your Honor. Objection. Move to strike.
THE COURT: Overruled.
BY MS. COMEY:
MS. COMEY: Now, Mr. Nash, other than what we've already talked about, how often do you remember seeing bruises on Cassie during her relationship with Mr. Combs?
DEONTE NASH: Quite often.
MS. COMEY: Where do you remember seeing bruises on Cassie's body?
DEONTE NASH: Legs, arms, and neck.
MS. COMEY: And other than the premiere and the incident where Cassie hit her head on the bed frame, how many other times do you remember seeing bruising on Cassie's face either in person or over FaceTime?
DEONTE NASH: Twice.
MS. COMEY: When are those times?
DEONTE NASH: One time was just a random time, I think he slapped her. And the other time was after a Las Vegas trip.
MS. COMEY: All right, I want to talk about just your interactions with Cassie and your observations with her, not anything anyone told you about that. Okay?
DEONTE NASH: Mm-hmm.
MS. COMEY: So about what year was this?
DEONTE NASH: 2015 maybe.
MS. COMEY: And are you estimating?
DEONTE NASH: Yeah.
MS. COMEY: And how did you come to first see injuries on Cassie's face?
DEONTE NASH: She FaceTimed me.
MS. COMEY: From where?
DEONTE NASH: From --
MS. COMEY: From what city?
DEONTE NASH: From Vegas -- no, I don't think they were in Vegas. But she FaceTimed me.
MS. COMEY: Well, did this have any connection to a Vegas trip or no?
DEONTE NASH: Yes. This was a Vegas trip.
MS. COMEY: And what injuries did you see on Cassie's face when she FaceTimed you?
DEONTE NASH: I saw bruising on her face.
MS. COMEY: Could you describe it, please?
DEONTE NASH: She had two black eyes that time.
MS. COMEY: How did those injuries compare to the other injuries you'd seen her with?
DEONTE NASH: It was pretty bad.
MS. COMEY: Now, how many times, Mr. Nash, has Mr. Combs been physically violent with you?
DEONTE NASH: A few.
MS. COMEY: Do some stand out more in your mind than others?
DEONTE NASH: Yes.
MS. COMEY: Was one of those times that stands out at a music video shoot?
MR. DONALDSON: Objection, Judge.
THE COURT: It's overruled.
DEONTE NASH: Yes.
MS. COMEY: About what year was this?
DEONTE NASH: 2013.
MS. COMEY: Are you estimating?
DEONTE NASH: About.
MS. COMEY: Whose music video was being shot that day?
DEONTE NASH: Cassie's.
MS. COMEY: Where were you right before the violence started?
DEONTE NASH: Outside smoking a cigarette.
MS. COMEY: Was anyone with you?
DEONTE NASH: No.
MS. COMEY: What were you standing by?
DEONTE NASH: A car.
MS. COMEY: Was it parked?
DEONTE NASH: Yes.
MS. COMEY: What happened as you were outside smoking a cigarette by a car?
DEONTE NASH: Puff came around and threw me on the car and started choking me out.
MS. COMEY: What did Mr. Combs say as he choked you on the car?
DEONTE NASH: I thought I told y'all about going out, y'all wilin.
MS. COMEY: Who did you understand Mr. Combs was referring to when he said y'all?
DEONTE NASH: Cassie and I.
MS. COMEY: And at that point what had Mr. Combs said to you in the past about whether you and Cassie could go out without his permission?
DEONTE NASH: After the Rita thing, that's basically -- he said that we couldn't.
MS. COMEY: That you couldn't what?
DEONTE NASH: That we couldn't go out. Because every time I wanted to go out, she wanted to go out.
MS. COMEY: Now, Mr. Nash, stepping back, did you report any of the violence you've described today to the police?
Did you file a report?
DEONTE NASH: No.
MS. COMEY: To the police?
DEONTE NASH: No.
MS. COMEY: Why not?
DEONTE NASH: Out of fear.
MS. COMEY: What were you afraid of?
DEONTE NASH: Of retaliation from Puff.
MS. COMEY: What kind of retaliation were you afraid of?
MR. DONALDSON: Objection.
THE COURT: Sustained.
MS. COMEY: Who on Mr. Combs' staff did you talk to about the violence you observed Mr. Combs inflict on Cassie?
DEONTE NASH: Derek and Kristina.
MS. COMEY: Who is Kristina?
DEONTE NASH: Puff's assistant.
MS. COMEY: Can we please pull up what's in evidence as Government Exhibit 2A-301.
MS. COMEY: Do you recognize this person?
DEONTE NASH: Yes.
MS. COMEY: Who is that?
DEONTE NASH: Kristina.
MS. COMEY: Do you know her last name?
DEONTE NASH: Khorram.
MS. COMEY: Do you know her by any nicknames?
DEONTE NASH: K.K.
MS. COMEY: We can take that down. Thank you.
MS. COMEY: How did Kristina respond when you told her about violence you observed between Mr. Combs and Cassie?
DEONTE NASH: That she would talk to him.
MR. DONALDSON: Objection.
THE COURT: That's overruled.
MS. COMEY: And did the violence stop after she said that?
DEONTE NASH: No.
MS. COMEY: During your friendship with Cassie, approximately how many times did you help Cassie hide from Mr. Combs?
DEONTE NASH: Too many to count.
MS. COMEY: About how often?
DEONTE NASH: Pretty often.
MS. COMEY: Do those instances run together in your mind?
MR. DONALDSON: Objection.
THE COURT: That's overruled.
DEONTE NASH: Yes.
MS. COMEY: Where are some of the places you remember going with Cassie to hide?
DEONTE NASH: Hotels. Shutters, The London, and a couple of other places.
MS. COMEY: What sorts of things do you remember seeing and hearing Mr. Combs say and do before you and Cassie ran away to hide?
MR. DONALDSON: Objection, your Honor.
THE COURT: That needs to be rephrased.
MS. COMEY: What caused you and Cassie to hide from Mr. Combs?
MR. DONALDSON: Objection, your Honor.
THE COURT: Can we get some specificity on what you're talking about.
MS. COMEY: Sure.
MS. COMEY: So you talked about hiding in hotels; is that right, Mr. Nash?
DEONTE NASH: Yes.
MS. COMEY: Can you explain to us why you and Cassie went to hotels to hide?
MR. DONALDSON: Objection, your Honor.
THE COURT: Grounds?
MR. DONALDSON: Form of the question, your Honor.
THE COURT: Overruled.
DEONTE NASH: Repeat the question, please.
MS. COMEY: Can you explain to us why you and Cassie would go to hotels to hide from Mr. Combs?
DEONTE NASH: Because we didn't want him to come back to the house and attack us.
MS. COMEY: And before you went to these hotels, what if any conversations do you remember having with Mr. Combs or hearing Cassie have with Mr. Combs?
DEONTE NASH: I can't even remember.
MS. COMEY: On the occasions when you helped Cassie hide from Mr. Combs, what ended up happening each time?
DEONTE NASH: He would blow everyone's phone up and threaten everybody until --
MS. COMEY: Let me pause you there. You said he would blow everyone's phone up. Who's the "he?"
DEONTE NASH: Puff.
MS. COMEY: And when you say "blow everyone's phone up," what do you mean?
DEONTE NASH: He would call incessantly.
MS. COMEY: Who did you see him call incessantly?
DEONTE NASH: Me and Cassie.
MS. COMEY: And who else during those same periods called you and Cassie?
DEONTE NASH: Kristina.
MS. COMEY: Kristina Khorram?
DEONTE NASH: Yes.
MS. COMEY: Did you answer any of those calls?
DEONTE NASH: Yes.
MS. COMEY: When you answered Mr. Combs' calls, what did he say?
DEONTE NASH: He would just say we needed to get back to the house. She needs to get back to the house and --
MS. COMEY: And what do you remember his tone being?
DEONTE NASH: Sometimes angry. Sometimes he would soften up.
MS. COMEY: And what do you remember Kristina saying when you answered her calls?
DEONTE NASH: That she was going to help with the situation, that he's calmed down, that we should come back to the house.
MS. COMEY: And after you heard that Mr. Combs had calmed down, what did you and Cassie do each time after going to a hotel?
DEONTE NASH: I would -- she would just go back -- she would go back to her house.
MS. COMEY: During Ms. Ventura's relationship with Mr. Combs, about how often did she tell you that she was going to a hotel with Mr. Combs?
DEONTE NASH: Quite often.
MS. COMEY: Can you give us an estimate, weekly, monthly, yearly?
DEONTE NASH: Weekly.
MS. COMEY: And each time that she told you she was going to a hotel with Mr. Combs, what if anything did you see her packing?
DEONTE NASH: A black duffle bag.
MS. COMEY: Did you see what she put in the duffle bag?
DEONTE NASH: Sex toys.
MS. COMEY: And what, on each of those occasions, what if anything did Cassie say to you about whether she wanted in those moments to go to those hotels with Mr. Combs?
MR. DONALDSON: Objection.
THE COURT: Overruled.
DEONTE NASH: She said she didn't want to.
MS. COMEY: And in those moments, what did she tell you about why she was going?
MR. DONALDSON: Objection.
THE COURT: Overruled.
DEONTE NASH: Because he wanted her to.
MS. COMEY: How long would Cassie usually be gone when she went to these hotels with Mr. Combs?
DEONTE NASH: Maybe, maybe a day or more.
MS. COMEY: And did you ever see her when she came back from these hotel stays?
DEONTE NASH: Most times, yes.
MS. COMEY: And what did you observe about her demeanor when she came back?
DEONTE NASH: That she would be tired.
MS. COMEY: During Cassie's relationship with Mr. Combs, what if any drugs did you see her take?
DEONTE NASH: Prescription pills and cocaine, Molly.
MS. COMEY: What if any of those drugs did you understand she became addicted to?
DEONTE NASH: The prescription drugs.
MS. COMEY: I want to talk now about Cassie's 29th birthday. Okay?
DEONTE NASH: Mm-hmm.
MS. COMEY: What conversations, if any, do you remember having with Mr. Combs ahead of Cassie's 29th birthday?
DEONTE NASH: Should he surprise her for her birthday.
MS. COMEY: Is that what he asked you?
DEONTE NASH: Yes.
MS. COMEY: How did you respond?
DEONTE NASH: I told him if you want to.
MS. COMEY: Now, why did you tell Mr. Combs to come if he wanted to if you'd seen him do all of this violence to Cassie?
DEONTE NASH: Girl, I was not about to tell him he couldn't come, give that girl a party.
MS. COMEY: Where was Cassie's 29th birthday?
DEONTE NASH: At the Cavatina.
MS. COMEY: What's the Cavatina?
DEONTE NASH: A restaurant in Los Angeles.
MS. COMEY: What do you remember happening at the birthday party there?
DEONTE NASH: As they were leaving, Puff was telling Cassie, fuck you, I do all this -- I'll do everything for you and you just can't do this one thing for me.
MS. COMEY: Did you end up speaking with Cassie at the Cavatina about Mr. Combs?
DEONTE NASH: Yes.
MS. COMEY: Were you two alone?
DEONTE NASH: It was -- it was a couple people around.
MS. COMEY: What do you remember Cassie saying to you at the Cavatina?
DEONTE NASH: I asked her about Puff. I was like girl, what is she over there doing, what is she talking about. And Cassie said, girl, she's just mad because I don't want to go to the hotel and freak-off with him.
MS. COMEY: Now, before that moment, had you heard the words freak-off come out of Cassie's mouth before to the best of your memory?
DEONTE NASH: Yeah. But it's not like freak-off. It was just like freak-off. You know what I mean?
MS. COMEY: Like the verb?
DEONTE NASH: Yeah.
MS. COMEY: And at the Cavatina, what did Cassie say about whether she wanted to go to the hotel?
MR. DONALDSON: Objection.
DEONTE NASH: That she didn't want --
MS. COMEY: No you got to wait.
THE COURT: Overruled.
MS. COMEY: What did say about in that moment whether she wanted to go to the hotel?
DEONTE NASH: That she didn't want to. She wanted to enjoy her birthday.
MS. COMEY: After the Cavatina, where did you go next?
DEONTE NASH: To the Blind Dragon.
MS. COMEY: What's the Blind Dragon?
DEONTE NASH: A karaoke club.
MS. COMEY: Who else do you remember going to the Blind Dragon?
DEONTE NASH: Some friends.
MS. COMEY: Did you see Cassie or Mr. Combs there?
DEONTE NASH: Yes, they came -- they followed behind.
MS. COMEY: What if any interactions did you see between Cassie and Mr. Combs at the Blind Dragon?
DEONTE NASH: He just had her in the corner. He was like pointing in her face.
MS. COMEY: What was his demeanor when Mr. Combs was pointing in Cassie's face?
DEONTE NASH: Stern.
MS. COMEY: Sorry?
DEONTE NASH: Stern.
MS. COMEY: Could you hear what he was saying?
DEONTE NASH: No.
MS. COMEY: Did you have any conversations with Cassie at the Blind Dragon or no?
DEONTE NASH: No.
MS. COMEY: Where did you go after the Blind Dragon?
DEONTE NASH: To Cassie's house.
MS. COMEY: Who else do you remember going to Cassie's house after the Blind Dragon?
DEONTE NASH: Bana and another girl.
MS. COMEY: Who is Bana?
DEONTE NASH: A friend of ours.
MS. COMEY: When you say friend of ours, who is ours?
DEONTE NASH: Cassie and I.
MS. COMEY: Can we Please pull up what is in evidence as Government Exhibit 2A-407.
MS. COMEY: Do you recognize the person in this photograph?
DEONTE NASH: Yes.
MS. COMEY: Who's that?
DEONTE NASH: Bana.
MS. COMEY: Do you know her by any other names?
DEONTE NASH: Bryana.
MS. COMEY: We can take that down. Thank you.
MS. COMEY: Now, which, which of Cassie's homes -- which home did you go to?
DEONTE NASH: 875 Comstock.
MS. COMEY: Comstock?
DEONTE NASH: Yes.
MS. COMEY: And is that in Los Angeles?
DEONTE NASH: Yes.
MS. COMEY: What floor was that on?
DEONTE NASH: I want to say -- that might have been 17A.
MS. COMEY: The 17th floor you think?
DEONTE NASH: Yeah.
MS. COMEY: Okay. What do you remember happening when that small group of people went to Cassie's home after the Blind Dragon?
DEONTE NASH: I -- Puff and Cassie came in.
MS. COMEY: And what do you remember Mr. Combs saying?
DEONTE NASH: Y'all girl going to get some dick tonight.
MS. COMEY: Who did Mr. Combs say that to?
DEONTE NASH: Me, Bana, and the other girl that was there.
MS. COMEY: And what did you see Cassie do next?
DEONTE NASH: She went to her room to pack her black bag.
MS. COMEY: And did you see what she was packing?
DEONTE NASH: Yes.
MS. COMEY: What was she packing?
DEONTE NASH: Like sex toys and stuff and money.
MS. COMEY: And what did Cassie say to you as she was packing up that bag?
MR. DONALDSON: Objection.
THE COURT: Overruled.
DEONTE NASH: That she didn't want to go there and should she take all this money because she had a wad of cash.
MS. COMEY: So, first, when she said she didn't want to go there, what did you understand the "there" was?
DEONTE NASH: With Puff.
MS. COMEY: To where with Puff?
DEONTE NASH: She didn't want to go -- she didn't want to go with him.
MS. COMEY: And what did you say about the money?
DEONTE NASH: I told her to put -- leave some behind because he always makes her spend all her money.
MS. COMEY: And what if anything did Cassie say to you about where she and Puff were about to go?
DEONTE NASH: To the hotel.
MS. COMEY: And what if anything did Cassie say to you about, in that moment, why she was going if she did not want to?
MR. DONALDSON: Objection.
THE COURT: That needs to be rephrased.
MS. COMEY: What if anything did Cassie say to you in that moment in her bedroom on her 29th birthday about why she was going to a hotel with Mr. Combs?
DEONTE NASH: Because --
MR. DONALDSON: Objection.
THE COURT: That's overruled. A. Because he was making her do that shit.
MS. COMEY: What did you see happen next?
DEONTE NASH: They ended up leaving the house.
MS. COMEY: When you say "they" who do you mean?
DEONTE NASH: Puff and Cassie.
MS. COMEY: When did you next see them after they left the apartment?
DEONTE NASH: I looked over the balcony and they were driving off in a golf cart.
MS. COMEY: Now, stepping back a bit, could you tell whether Cassie was under the influence of any substances this night?
DEONTE NASH: Oh, yeah.
MS. COMEY: Could you tell us about that?
DEONTE NASH: She was super high.
MS. COMEY: How could you tell?
DEONTE NASH: I mean, I know her demeanor.
MS. COMEY: And could you tell anything about whether Mr. Combs was under the influence of anything that night?
DEONTE NASH: Yes.
MS. COMEY: Tell us about that?
DEONTE NASH: He was high.
MS. COMEY: Based on his demeanor and his appearance and based on Cassie's appearance and demeanor, could you tell who was more intoxicated than the other?
MR. DONALDSON: Objection.
THE COURT: You can answer that yes or no if you can.
DEONTE NASH: Yes.
MS. COMEY: Who was more intoxicated based on your observations?
DEONTE NASH: Cassie.
MS. COMEY: Who did you see driving the golf cart?
DEONTE NASH: Puff.
MS. COMEY: And who was in the golf cart with Mr. Combs?
DEONTE NASH: Cassie.
MS. COMEY: And where were you when you saw the golf cart driving away?
DEONTE NASH: Looking off of the balcony.
MS. COMEY: Who else was with you on the balcony?
DEONTE NASH: I don't know.
MS. COMEY: I just want to ask you about one other event, Mr. Nash.
DEONTE NASH: Mm-hmm.
MS. COMEY: I want to direct your attention to New Years Eve in approximately 2017. Okay?
DEONTE NASH: Yes.
MS. COMEY: Do you remember where you were then?
DEONTE NASH: Vegas.
MS. COMEY: Who else do you remember being in Vegas for that New Years?
DEONTE NASH: Puff, Cassie, and the rest of the staff.
MS. COMEY: Whose staff?
DEONTE NASH: Puff.
MS. COMEY: Where were Mr. Combs, Cassie, you, and the rest of the staff staying?
DEONTE NASH: I forget the hotel.
MS. COMEY: But at a hotel?
DEONTE NASH: Yes.
MS. COMEY: And were you all on different floors or the same floor?
DEONTE NASH: Same.
MS. COMEY: Could you describe where Mr. Combs' room was in relation to the rest of the staff's rooms?
DEONTE NASH: The end of the hallway.
MS. COMEY: So his was at the end of the hallway.
When you arrived in Vegas for this trip, where did you go?
DEONTE NASH: To their -- Puff and Cassie's room to unload Cassie's clothes.
MS. COMEY: And what happened when you went to Mr. Combs' and Cassie's room?
DEONTE NASH: He told me that she had been asleep for 24 hours and we needed -- I needed to wake her up.
MR. DONALDSON: Objection.
MS. COMEY: Who told you that?
DEONTE NASH: Puff.
THE COURT: It's overruled. You can continue.
MS. COMEY: I'm sorry. Who told you that?
DEONTE NASH: Puff.
MS. COMEY: After Mr. Combs told you that, what did you do?
DEONTE NASH: I went to wake her up.
MS. COMEY: And did you wake her up?
DEONTE NASH: Yeah. She woke up right away for me.
MS. COMEY: And what did she tell you she wanted to do?
DEONTE NASH: Stay in.
MS. COMEY: And then what if any conversation did you have with Mr. Combs about what he wanted to happen that night?
DEONTE NASH: He pulled me in the hallway and told me that he spent all that money, she needed to get ready.
MS. COMEY: So then what did you and Cassie do?
DEONTE NASH: Got her ready.
MS. COMEY: And then where did you, Cassie, and Mr. Combs go?
DEONTE NASH: To a couple of clubs.
MS. COMEY: After going out, where did you end up at the end of the night?
DEONTE NASH: In Puff and Cassie's room.
MS. COMEY: Who do you remember being there?
DEONTE NASH: Me, Cassie, Rob Holladay, and Puff.
MS. COMEY: Who is Rob Holladay?
DEONTE NASH: A low budget producer.
MS. COMEY: What do you remember happening in Mr. Combs' suite?
DEONTE NASH: Well, I usually go to sleep before everybody, so I went to sleep in the room, and Cassie woke me up and said that Puff wanted to invite a guy over.
MR. DONALDSON: Objection, Judge.
THE COURT: It's overruled.
MS. COMEY: How did you respond when Cassie told you that Puff wanted to invite a guy over?
DEONTE NASH: I just went ugh, and I got up and went to my hotel room.
MS. COMEY: And what did you do when you went to your hotel room?
DEONTE NASH: I started packing.
MS. COMEY: And as you were packing, where were you?
DEONTE NASH: Going between two rooms.
MS. COMEY: Why were you going between two rooms?
DEONTE NASH: Because I had clothes in both rooms.
MS. COMEY: So were you out in the hallway?
DEONTE NASH: Yes.
MS. COMEY: What did you see when you were going in and out of rooms into the hotel hallway?
DEONTE NASH: A guy knocking on the door.
MS. COMEY: A guy knocking on which door?
DEONTE NASH: Puff and Cassie's.
MS. COMEY: Do you know what that guy looked like?
DEONTE NASH: I can only see him from the back.
MS. COMEY: What did you see happen after this guy knocked on Mr. Combs' and Cassie's door?
DEONTE NASH: Somebody opened the door and he went in.
MS. COMEY: Did you see that man again?
DEONTE NASH: No.
MS. COMEY: What year did you ultimately stop working as a stylist for Mr. Combs?
DEONTE NASH: 2018.
MS. COMEY: And what year did Cassie break up with Mr. Combs once and for all?
DEONTE NASH: 2018.
MS. COMEY: What is your relationship like with Cassie now?
DEONTE NASH: Very close.
MS. COMEY: How often do you talk?
DEONTE NASH: Pretty often.
MS. COMEY: Have you discussed the substance of your testimony here today with Cassie at all?
DEONTE NASH: No.
MS. COMEY: Has she discussed the substance of her testimony, if any, with you at all?
DEONTE NASH: No.
MS. COMEY: About how many times have you met with prosecutors in connection with this case?
DEONTE NASH: Too many.
MS. COMEY: Can you estimate the number?
DEONTE NASH: What, five.
MS. COMEY: Approximately?
DEONTE NASH: Maybe.
MS. COMEY: How many of those meetings did you cut off and end early because you did not want to continue participating in them?
MR. DONALDSON: Objection. Excuse me. Objection.
THE COURT: That's overruled.
MS. COMEY: How many of your meetings with prosecutors did you cut off and --
THE COURT: Let's rephrase the question just to avoid the form objection.
MS. COMEY: How many, if any, meetings with prosecutors did you end early?
DEONTE NASH: Probably all of them.
MS. COMEY: And did you do that because you did not want to continue speaking with prosecutors?
DEONTE NASH: Yeah.
MS. COMEY: During your meetings with prosecutors, did you volunteer information or did you only answer the specific questions you were asked?
DEONTE NASH: Only specific questions.
MS. COMEY: Now, after you stopped working for Mr. Combs, did you still communicate with him?
DEONTE NASH: Absolutely.
MS. COMEY: By text and by phone?
DEONTE NASH: Absolutely.
MS. COMEY: Did you also occasionally see him in person?
DEONTE NASH: No.
MS. COMEY: What was the tone of your text messages to Mr. Combs after you stopped working for him?
DEONTE NASH: Loving.
MS. COMEY: Why was your tone to him loving if you had seen him do all of these things to one of your closest friends and if he had been violent with you?
DEONTE NASH: I mean, my -- my whole 20s, this man's sanity was my safety. So it was just very -- it was what I was used to.
MS. COMEY: Have you personally filed any lawsuits against Mr. Combs?
DEONTE NASH: No.
MS. COMEY: Have you personally sent any demands for money to Mr. Combs?
DEONTE NASH: No.
MS. COMEY: How do you feel about Mr. Combs here today?
DEONTE NASH: I don't hate him.
MS. COMEY: Why is that?
DEONTE NASH: I mean, I don't. It's just not in me.
MS. COMEY: May I have a moment, your Honor.
THE COURT: You may.
MS. COMEY: No further questions.
THE COURT: All right. Cross-examination.
MR. DONALDSON: Yes. But can I take a two-minute break, please? Go to the bathroom.
THE COURT: Yes. Let's take five minutes. We'll come back at 2:30. All rise.
(Continued on next page)
(In open court; jury not present)
THE COURT: Mr. Nash, we'll be back in a few minutes. You can head back to that room and we'll bring you out.
DEONTE NASH: Okay.
THE COURT: All right. We'll be back in five.
(Continued on next page)
(Jury not present)
THE COURT: All right. Please be seated.
Let's have Mr. Nash back.
MS. COMEY: Your Honor, I've raised this with defense counsel. I know this may not be possible. If there's any way we can go a little late today. The witness has a flight back home to Los Angeles tonight. If we have to rebook it, we will. If there's any way we can stay a little late and get this witness done, I think the witness will appreciate it.
THE COURT: That's fine. I think the jury will understand.
Mr. Donaldson, any issues with that?
MR. DONALDSON: Not from me personally.
THE COURT: OK.
MR. DONALDSON: Just tell me what we think.
THE COURT: I could be mistaken. I think I told the jury at some point in the beginning of this case that it may be a little bit longer, we will get them out. I think we said at some point, the latest, 4:00. I think we have some breathing room there.
(Witness returned)
THE COURT: Welcome back.
DEONTE NASH: Thank you.
(Continued on next page)
(Jury present)
THE COURT: Please be seated.
Welcome back, members of the jury.
Just to give you a heads-up, we're going to be stay ago little bit later today, just for some scheduling reasons. The bad news is we're going to be going later than 3:00. I assure you we're not going to get out of here any later than 4:00.
The good news is, we're doing all of this is make sure that we stay on schedule, on a more general level, for the trial so we can make sure that we're keeping on track.
So, with that, thank you for your patience.
And, Mr. Donaldson, when you're ready.
MR. DONALDSON: Thank you, Judge.
BY MR. DONALDSON:
MS. COMEY: Good afternoon, sir. Good afternoon.
DEONTE NASH: How are you?
MS. COMEY: I'm pretty good. Thank you.
How are you?
DEONTE NASH: Blessed.
MS. COMEY: Blessed.
I'm going to ask you to try to speak up as loud as you can so that the last person in this jury box can hear you.
All right?
DEONTE NASH: Sure.
MS. COMEY: Cool.
Now, you just mentioned on direct with Ms. Comey here that you met with the government several times, is that right?
DEONTE NASH: Yes.
MS. COMEY: And during those times you met with the government, you had an attorney present, is that right?
DEONTE NASH: Um, yes.
MS. COMEY: And you also said that you, a few times, you wanted to leave early, is that right?
DEONTE NASH: Yeah.
MS. COMEY: By leave early, you were saying that you wanted to stop whatever questions they were asking you, you wanted to just get out of there?
DEONTE NASH: Yes.
MS. COMEY: Because either you were tired of the questions or you just didn't want to be there, correct?
DEONTE NASH: Correct.
MS. COMEY: And I think you said, when you first sat down this afternoon, that you did not want to be here, right?
DEONTE NASH: Absolutely.
MS. COMEY: You did not want to testify in this case?
DEONTE NASH: Yep.
MS. COMEY: And you were told you had to be here because of a subpoena, is that right?
DEONTE NASH: Correct.
MS. COMEY: And that subpoena told you, you had to come to court, correct?
DEONTE NASH: Yes.
MS. COMEY: Now, as far as you going to the government's offices to talk to them, you didn't have to go there, correct?
DEONTE NASH: Nope.
MS. COMEY: So when you went there, you went because --
Well, you went voluntarily, right?
DEONTE NASH: Yeah.
MS. COMEY: And so, you went there to answer their questions, like they said, correct?
DEONTE NASH: Yes.
MS. COMEY: And give them truthful answers?
DEONTE NASH: Nothing but the truth.
MS. COMEY: And that is what you did every time you was there?
DEONTE NASH: Every single time.
MS. COMEY: When you said you went there with the lawyer, Mr. Dunn, is that it?
DEONTE NASH: Yes.
MS. COMEY: And Mr. Dunn -- well, you also said that, I think one of your last questions -- answers was you're not -- you haven't filed a lawsuit, right?
DEONTE NASH: No.
MS. COMEY: And you haven't sent out a demand letter?
DEONTE NASH: No.
MS. COMEY: You know what a demand letter is?
DEONTE NASH: Yes, I do.
MS. COMEY: So you haven't sent out anything to Mr. Combs demanding money?
DEONTE NASH: No.
MS. COMEY: But you did hire Mr. Dunn to pursue possible civil litigation against Mr. Combs, right?
THE COURT: Sustained.
MS. COMEY: Objection.
MS. COMEY: Do you have a civil --
Are you considering a lawsuit against Mr. Combs?
DEONTE NASH: No. I'm focused on getting out of here.
MR. DONALDSON: Could you put up 3514-5, just for the parties and the witness, please. Would you just highlight the first hyphen, please.
MS. COMEY: Mr. Nash, could you read that first part to yourself, and let me know when you're finished reading it?
DEONTE NASH: Um, let me see. Dunn representing --
MS. COMEY: No, no, no, no. Read it to yourself. I'm sorry about that. Read it to yourself.
THE COURT: Mr. Nash, are you done reading that?
DEONTE NASH: Yes.
THE COURT: Can we take it down.
Mr. Donaldson, a question.
MR. DONALDSON: Thank you.
BY MR. DONALDSON:
MS. COMEY: Now, after reading that document, does that refresh your recollection, or does that change your testimony, whether or not you are considering civil litigation against Mr. Combs?
DEONTE NASH: No, it doesn't. It seems like an assumption.
MS. COMEY: We don't want to do assumptions in the courtroom, so does that document refresh your recollection that you are considering civil --
DEONTE NASH: No, it doesn't.
MS. COMEY: Hold on.
DEONTE NASH: It doesn't.
MS. COMEY: It does not?
DEONTE NASH: No.
MS. COMEY: So it's fair to say then that you do not have, or not as much March -- one second -- as of March 10, 2025, you are not considering or retaining counsel to consider suing Mr. Combs in civil actions?
DEONTE NASH: I have counsel to protect me. I don't -- I don't do federal court.
MS. COMEY: All right. So you have counsel to protect you related to?
DEONTE NASH: This case.
MS. COMEY: Protect you related to your interests regarding civil claims against Mr. Combs, correct?
DEONTE NASH: No. This case.
MS. COMEY: Did you not tell the government on March 10, 2025, that you have civil counsel to consider civil claims against Mr. Combs?
MS. COMEY: Objection, asked and answered, your Honor.
MR. DONALDSON: Different question, Judge.
THE COURT: I don't know about that. I'll let you ask it one more time.
Overruled.
MR. DONALDSON: Excuse me.
Mr. Donaldson, do you want to ask your question?
MR. DONALDSON: Yes. I want to make sure I get the date right.
THE COURT: All right.
BY MR. DONALDSON:
MS. COMEY: On Mr. March 10, 2025, did you not tell the government, Ms. Comey, that you have civil counsel to consider pursuing a civil complaint against Mr. Combs?
DEONTE NASH: No.
MR. DONALDSON: All right. Could you put up 1800, please. I want to show the witness and the parties, witness only, what's been premarked as a Defense Exhibit 1800. A. Yes.
MS. COMEY: Mr. Nash, do you recognize that?
DEONTE NASH: Yes.
MS. COMEY: What do you recognize that to be?
DEONTE NASH: Cassie in the Numb video.
MS. COMEY: I'm sorry?
DEONTE NASH: Cassie in the Numb video.
MS. COMEY: The Numb video?
DEONTE NASH: Yes.
MS. COMEY: What's the Numb video?
DEONTE NASH: It's a music video from a mix tape.
MS. COMEY: From the mix tape?
DEONTE NASH: Yes.
MR. DONALDSON: We would like to have that moved in as Defense Exhibit 1800?
MS. COMEY: No objection.
THE COURT: 1800 will be admitted.
(Defendant's Exhibit 1800 received in evidence)
MR. DONALDSON: Could you put up 1801, please.
MS. COMEY: Mr. Nash, do you see what's been marked as Defense Exhibit 1801?
DEONTE NASH: Yes.
MS. COMEY: What do you recognize that to be?
DEONTE NASH: Cassie and it looks like Usher.
MR. DONALDSON: Your Honor, I would like to move Defense Exhibit 1801 in.
MS. COMEY: I would object, your Honor. I don't think the witness has established the relevance.
THE COURT: All right. Mr. Donaldson.
BY MR. DONALDSON:
MS. COMEY: Mr. Nash, do you know where this particular picture comes from?
DEONTE NASH: The Bad Boy Reunion tour.
MS. COMEY: Was that 2016?
DEONTE NASH: Maybe.
MS. COMEY: Were you a part of that tour?
DEONTE NASH: Yes.
MS. COMEY: You participated as a stylist in that tour?
DEONTE NASH: Yes.
MS. COMEY: And is this -- was Cassie your -- were you styling for Cassie at that time?
DEONTE NASH: Yes.
MR. DONALDSON: I would like to move this in as Defense Exhibit 1801.
MS. COMEY: No objection, your Honor.
THE COURT: 1801 will be admitted.
(Defendant's Exhibit 1801 received in evidence)
MR. DONALDSON: Publish that to the jury, please, if you don't mind.
Take that down, please.
Could you please put up 1802, please.
BY MR. DONALDSON:
MS. COMEY: Mr. Nash, do you recognize what's been previously marked as Defense Exhibit 1802?
DEONTE NASH: Yes.
MS. COMEY: What do you recognize that to be?
DEONTE NASH: This is Cassie doing her two-minute performance at the Bad Boy Reunion tour.
MS. COMEY: This is the same 2016 Bad Boy Reunion tour?
DEONTE NASH: This is actually the show. This is not the tour. She didn't do the tour. She did the show.
MS. COMEY: OK. This is the show from that?
DEONTE NASH: Yes, yes.
MS. COMEY: Were you her stylist at that time?
DEONTE NASH: Yes.
MR. DONALDSON: Your Honor, I move to in as Defense Exhibit 1802.
MS. COMEY: No objection.
THE COURT: 1802 will be admitted.
(Defendant's Exhibit 1802 received in evidence)
MR. DONALDSON: Please publish for the jury, please.
BY MR. DONALDSON:
MS. COMEY: Did you pick out that dress?
DEONTE NASH: I don't remember.
MR. DONALDSON: Could we go back to 1801, please. Put back up 1801.
MS. COMEY: Did you pick out that one?
DEONTE NASH: I don't remember.
MR. DONALDSON: Could we put up 1803 just for the witness and the parties.
Now, your Honor, can I have a word with the prosecution, please?
THE COURT: Yes, you may.
(Counsel confer)
MR. DONALDSON: Your Honor, with the consent of the government, we have approximately ten more exhibits we would like to put in. The government has indicated it has no objection. We can do a batch, if that's OK, to make it quicker, or we can go through it one by one.
THE COURT: Do you need to use those during your Honor examination or get them into evidence?
MR. DONALDSON: I want to get them into evidence now and use them later on.
THE COURT: In the examination?
MR. DONALDSON: Yes.
THE COURT: What are the exhibits?
MR. DONALDSON: 1810, 1811, 1814, 1818, 1820 -- those are over the government's objection, but the court allowed those in -- 1819, 1821 through 1826, 1828, 1829, 1833, 1835, 1837, 1839 through 1841.
MS. COMEY: No objection, so long as 1841 has the redactions that I requested.
MR. DONALDSON: I believe it does. Yes, it does.
THE COURT: All right. Those exhibits identified by counsel will be admitted.
MR. DONALDSON: Thank you.
(Defendant's Exhibits 1810, 1811, 1814, 1818, 1820 1819, 1821 through 1826, 1828, 1829, 1833, 1835, 1837, 1839 through 1841 received in evidence)
BY MR. DONALDSON:
MS. COMEY: All right. Mr. Nash, you testified this afternoon about your relationship with Ms. Ventura, right, Cassie, right?
DEONTE NASH: Mrs. Fine.
MS. COMEY: I'm sorry?
DEONTE NASH: Mrs. Fine.
MS. COMEY: Mrs. Fine?
DEONTE NASH: Yes.
MS. COMEY: Because she's married to Alex?
DEONTE NASH: Yes.
MS. COMEY: And that was -- we'll get to that.
So, well, you testified about your relationship to Mrs. Fine?
DEONTE NASH: Yes.
MS. COMEY: It started in 2001 what?
DEONTE NASH: 2009, '8.
MS. COMEY: And you mentioned back in 2008, when you started this relationship, you were a -- you still are a stylist, right?
DEONTE NASH: Yes.
MS. COMEY: I think when you came into there, you said that you are a celebrity stylist?
DEONTE NASH: Yes, correct.
MS. COMEY: And a celebrity stylist means someone that styles for celebrities, right?
DEONTE NASH: Yes.
MS. COMEY: That's contrary to someone who doesn't style for celebrities, right?
DEONTE NASH: Yes.
MS. COMEY: So someone that's not a celebrity stylist can call themselves just a stylist?
DEONTE NASH: Yes.
MS. COMEY: So you have earned the distinction of being a celebrity stylist because you style primarily for celebrities?
MS. COMEY: Objection, your Honor.
DEONTE NASH: Yes.
THE COURT: It's overruled.
MS. COMEY: Now, when you -- that's not how you started your career, though, correct?
You don't just become a celebrity stylist, you have to move up to become that?
DEONTE NASH: No. That's how I started it.
MS. COMEY: So, in 2007, when you were an intern at Bad Boy, you were a celebrity stylist?
DEONTE NASH: I started as an intern.
MS. COMEY: But were you a celebrity stylist is my question?
DEONTE NASH: Oh, no.
MS. COMEY: So, in 2008, you became a celebrity stylist?
DEONTE NASH: Yeah.
MS. COMEY: What do you mean yeah?
DEONTE NASH: Yes.
MS. COMEY: So, by working at Bad Boy between 2007 and 2008, you just became a celebrity stylist?
DEONTE NASH: Yes.
MS. COMEY: And that was because Mr. Combs introduced you to Cassie?
DEONTE NASH: I introduced myself to Cassie.
MS. COMEY: You introduced yourself to Cassie while working for Mr. Combs?
DEONTE NASH: Yes.
MS. COMEY: And you were still styling Mr. Combs, as well?
DEONTE NASH: Yes.
MS. COMEY: So that's how you became a celebrity stylist, by that kind of movement, correct?
DEONTE NASH: Yes.
MS. COMEY: And that was -- but that only happened, though, because you started your internship with Bad Boy, right?
DEONTE NASH: Yes.
MS. COMEY: So it would be fair to say that Mr. Combs or Bad Boy helped start your career you have now as a stylist, as a celebrity stylist, would that be fair to say?
DEONTE NASH: Yeah. Go ahead.
MS. COMEY: I'm going. Don't worry about it.
So now, when you say stylist, what do you mean by stylist? What is a stylist? Tell everybody what a stylist is.
DEONTE NASH: Someone that goes shopping for clothes, you style them for music, dress them for music videos, personal appearances, some people do personal styling, which I do, as well, where I do everyday looks for clients.
MS. COMEY: What about music?
DEONTE NASH: No.
MS. COMEY: You don't do any music?
DEONTE NASH: What do you mean?
MS. COMEY: So when you talked this morning, this afternoon, about your knowledge of studios and your knowledge of time period, your knowledge of when records get released and your knowledge of who releases records and your knowledge of all this, you were giving us that information based upon your extensive experience as a celebrity stylist, right?
MS. COMEY: Objection, misstates the testimony, your Honor.
THE COURT: You've got to rephrase the question, Mr. Donaldson.
Mr. Donaldson, if you can just do me a favor and stay at the lectern, just because the court reporters are having difficulty if you're not at the microphone.
MR. DONALDSON: OK, Judge. Got you. Let me start over.
BY MR. DONALDSON:
MS. COMEY: As a celebrity stylist, you indicated that you purchased clothes, correct?
DEONTE NASH: Um-hmm.
MS. COMEY: Is that a yes?
DEONTE NASH: Yes.
MS. COMEY: You also helped people pick out clothing for their videos, correct?
DEONTE NASH: Um-hmm.
MS. COMEY: Is that a yes?
DEONTE NASH: Yes.
MS. COMEY: You also helped people pick out clothing for their photo shoots, correct?
DEONTE NASH: Yes.
MS. COMEY: You also helped them pick out clothing for their weddings, correct?
DEONTE NASH: Yes.
MS. COMEY: And, in fact, as you indicated, for Mrs. Fine, you helped pick out her wedding dress, correct?
DEONTE NASH: Yes.
MS. COMEY: You and who else? A father-daughter group?
DEONTE NASH: Who?
MS. COMEY: Who was it?
Who helped you pick out that dress?
DEONTE NASH: What do you mean father-daughter group?
MS. COMEY: Who helped you pick out Mrs. Fine's wedding dress?
DEONTE NASH: Marni Senofonte.
MS. COMEY: Did his daughter help, too?
DEONTE NASH: Whose daughter?
MS. COMEY: Don't worry about it. We'll get to it.
So now, once you finished picking out the clothing for the celebrities and their photo shoots and their video shoots, is your job done?
DEONTE NASH: Depends.
MS. COMEY: OK. You also helped people pick out their clothing for tours, correct?
DEONTE NASH: Correct.
MS. COMEY: For when they perform on these tours, correct?
DEONTE NASH: Yes.
MS. COMEY: So, in 2016, doing this Reunion tour, you were present to help pick out persons' clothing for their performances, correct?
DEONTE NASH: Yes.
MS. COMEY: And that's a very important job, right?
DEONTE NASH: Yes.
MS. COMEY: Because people have to look -- celebrities have to look a certain way when they walk outside, correct?
DEONTE NASH: Yes.
MS. COMEY: Because their look is part of their celebrity status, correct?
DEONTE NASH: Yes.
MS. COMEY: And it has to be -- I mean, it takes a lot to pick out the right outfit for the right event, correct?
DEONTE NASH: Yes.
MS. COMEY: And you have to have the right hair, correct?
DEONTE NASH: Yes.
MS. COMEY: And that's all a part of being an artist, correct?
DEONTE NASH: Yes.
MS. COMEY: All right. And you help people do that, correct?
DEONTE NASH: Yes.
MS. COMEY: You helped Mr. Combs do that, correct?
DEONTE NASH: Yes.
MS. COMEY: You did that for a while with Mr. Combs, correct?
DEONTE NASH: Yes.
MS. COMEY: And he would send you -- you would send him pictures of what to wear, he would pick which ones he wanted, correct?
DEONTE NASH: Cassie would usually send them, but yes.
MS. COMEY: Cassie would send him pictures?
DEONTE NASH: Yes.
MS. COMEY: And he would pick out which ones he wanted from those?
DEONTE NASH: Yes.
MS. COMEY: You know someone named Scott Langston or Scott Langston?
DEONTE NASH: No.
MS. COMEY: OK. What about -- do you know the Public School brand, the Public School clothing brand?
DEONTE NASH: No.
MS. COMEY: Do you know Murio Solomon?
DEONTE NASH: No.
MS. COMEY: Do you know Groovey Lew?
DEONTE NASH: Yes.
MS. COMEY: Who is Groovey Lew?
DEONTE NASH: Puff's longtime friend and one of his stylists.
MS. COMEY: Do you know Mike B?
DEONTE NASH: From around, yes.
MS. COMEY: Who was Mike B?
DEONTE NASH: One of Puff's old stylists.
MS. COMEY: Now, it would be fair to say that when you worked at Bad Boy as an intern and as a stylist for Mr. Combs and as stylist for Mrs. -- what's her name, Mrs --
DEONTE NASH: Fine.
MS. COMEY: -- Fine, Mrs. Fine, there were other artists that were also signed to the Bad Boy roster, would that be fair to say?
DEONTE NASH: Yes.
MS. COMEY: Who were they?
DEONTE NASH: Um, French Montana.
MS. COMEY: Wait. French Montana, the hip-hop person, rap star?
DEONTE NASH: Yes. I mean, and Puff. That's all I can really remember right now.
MS. COMEY: Just two of them?
DEONTE NASH: I just -- I don't know.
While I was there?
MS. COMEY: You were --
DEONTE NASH: Danity Kane, Day 26.
MS. COMEY: Danity Kane, Day 26. Who else?
DEONTE NASH: I don't remember.
MS. COMEY: Did you ever see Gun Kelly there?
DEONTE NASH: Oh, yeah.
MS. COMEY: You seen Gun Kelly?
DEONTE NASH: Yes.
MS. COMEY: OK. Who else?
DEONTE NASH: I don't remember.
MS. COMEY: All those people that were there, they also had stylists, correct?
DEONTE NASH: Oh, I don't know.
MS. COMEY: Well, when at a label such as Bad Boy Records or Bad Boy, period, as you said, artists have to be, well, pay attention to their clothing, correct?
DEONTE NASH: Yes.
MS. COMEY: You would agree that it is in the best interest, based upon your experience as indicated on direct, you would agree it's in the label's best interest to make sure that the artists signed to a label are dressed appropriately, correct?
DEONTE NASH: Yes.
MS. COMEY: You would agree that it's in a label's best interest that its stars or its artists that are signed to them, hair is appropriate, correct?
DEONTE NASH: Yes.
MS. COMEY: You would agree that it's in the label's best interest that the artists signed to the label represent themselves properly in public, correct?
DEONTE NASH: Yes.
MS. COMEY: And that's all because the label, I guess, makes more money if the artists make money, does that make sense?
DEONTE NASH: Yes.
MS. COMEY: OK. And so you would agree then that if Cassie -- well, strike.
Was Cassie signed to the Bad Boy label?
DEONTE NASH: Yes.
MS. COMEY: So you would agree then that the label had an interest in how Cassie looked when she went outside, correct?
DEONTE NASH: Yes.
MS. COMEY: You would agree that the label had an interest in how Cassie's clothing looked like, correct?
DEONTE NASH: Yes.
MS. COMEY: You would even agree that that --
Do you recall a haircut that Cassie had, the side haircut?
DEONTE NASH: Yes.
MS. COMEY: That haircut became almost iconic status, correct?
DEONTE NASH: Yes.
MS. COMEY: It became the Cassie cut, correct?
DEONTE NASH: Yes.
MS. COMEY: People all around the world was getting their hair cut, correct?
MS. COMEY: Objection, your Honor.
THE COURT: Sustained.
Let's move on.
MS. COMEY: Who decided that haircut? Who suggested the haircut?
DEONTE NASH: Puff.
MS. COMEY: Who?
DEONTE NASH: Puff.
MS. COMEY: Mr. Combs?
DEONTE NASH: Um-hmm.
MS. COMEY: Is that a yes?
DEONTE NASH: Yes.
MS. COMEY: So Mr. Combs suggested the haircut on Cassie that became iconic status?
DEONTE NASH: Yes.
MS. COMEY: And so when Cassie was wearing certain clothing outside, it would be important for the person who ran the label, that her clothing looked good, would that be fair to say?
DEONTE NASH: Sometimes, yeah.
MS. COMEY: You also mentioned during direct that you were -- Cassie was at studio sessions quite often.
Do you recall saying that?
DEONTE NASH: Yes.
MS. COMEY: I believe you said she was recording almost every day.
Do you recall saying that?
DEONTE NASH: Towards the end, yes.
MS. COMEY: And this was in a studio, correct?
DEONTE NASH: Correct.
MS. COMEY: I believe you also said that the something about -- we'll get to the mix tape.
When you say recording every day, this is in an actual studio, correct?
DEONTE NASH: Yes.
MS. COMEY: So the jury understands, we're talking about a studio that can record songs that could be released commercially, correct?
DEONTE NASH: Correct.
MS. COMEY: And you know the difference, you know what commercial releases mean, correct?
DEONTE NASH: Yes.
MS. COMEY: That means releases that are to the public so that can have some commercial profit, I guess, right?
DEONTE NASH: Yes.
MS. COMEY: And making those songs in those studios take time, correct?
DEONTE NASH: Yes.
MS. COMEY: Sometimes days and weeks, correct?
DEONTE NASH: Yes.
MS. COMEY: For one song, correct?
DEONTE NASH: Um-hmm.
MS. COMEY: Is that a yes?
DEONTE NASH: That's a little excessive, but yes.
MS. COMEY: OK. Studios are expensive, correct?
DEONTE NASH: Yes.
MS. COMEY: Studio time is expensive, correct?
DEONTE NASH: Yes.
MS. COMEY: So when you say that you and Cassie were in the studio quite often, almost every day, recording songs, somebody had to pay for that studio, correct?
DEONTE NASH: Yes.
MS. COMEY: And it is in the label's best interest to ensure that the artist is putting out a commercially satisfactory song, correct, if you know?
DEONTE NASH: Yes.
MS. COMEY: OK. And so the label pays for the studio time, correct?
DEONTE NASH: Yes.
MS. COMEY: And so the label in this situation was Bad Boy, correct?
DEONTE NASH: Correct.
MS. COMEY: And that would be Mr. Combs, correct?
DEONTE NASH: Correct.
MS. COMEY: So when you say that you and Cassie were in the studio almost every day or quite often, that means that Mr. Combs was paying for that studio time, correct?
DEONTE NASH: Correct.
MS. COMEY: She wouldn't be able to go to the studio unless he pays for it, correct?
DEONTE NASH: Correct.
MS. COMEY: And so the label wants -- well, I shouldn't say wants.
It would be fair to say that -- well, when you say a lot, you mean over the course of between 2009 and 2018, you and Cassie went to a studio quite often, paid for by Mr. Combs, correct?
DEONTE NASH: Um-hmm.
MS. COMEY: Yes?
DEONTE NASH: Yes.
MS. COMEY: Well, that would mean then that you would agree that Mr. Combs and Bad Boy had an interest in Cassie's future, correct?
DEONTE NASH: Yeah.
MS. COMEY: Do you know what Young & Reckless is?
DEONTE NASH: Yes.
MS. COMEY: And that's something that was -- well, I don't want --
You tell the jury what that is.
DEONTE NASH: A streetwear brand, clothing brand.
MS. COMEY: Streetwear clubbing brand?
DEONTE NASH: Clothing brand.
MS. COMEY: Say that again?
DEONTE NASH: A streetwear clothing brand.
MS. COMEY: Clothing brand.
And it was founded or owned or made by whom?
DEONTE NASH: I don't know. I don't remember.
MS. COMEY: Well, Cassie had an interest in this, right?
DEONTE NASH: Yes.
MS. COMEY: And Cassie was part of that, correct?
DEONTE NASH: Yes.
MS. COMEY: That was in 2015, '16?
DEONTE NASH: Maybe around there.
MS. COMEY: And as part of this clothing streetwear brand, Cassie was taking photos, correct?
DEONTE NASH: Yes.
MS. COMEY: She was doing photo shoots, correct?
DEONTE NASH: Yes.
MS. COMEY: Were you styling that as well?
DEONTE NASH: Yes.
MS. COMEY: And that wasn't under the auspices of Bad Boy, correct?
DEONTE NASH: What do you mean?
MS. COMEY: Bad Boy had nothing to do with Young & Reckless, correct?
DEONTE NASH: No. Puff had to approve the photos.
MS. COMEY: Puff had to approve the photos?
DEONTE NASH: Yes.
MS. COMEY: But Puff didn't have to approve Cassie going to do work with Young & Reckless, correct?
DEONTE NASH: Yes, he did.
MS. COMEY: Did he approve that?
DEONTE NASH: Yes.
MS. COMEY: When did he approve that?
DEONTE NASH: You say what?
MS. COMEY: When did he approve that?
DEONTE NASH: I don't -- it was years ago, but he approved it.
MS. COMEY: Just so I'm clear, that was also to make money, correct?
DEONTE NASH: Yes.
MS. COMEY: So Mr. Combs approved Cassie to go out and make money with the clothing and streetwear brand, correct?
DEONTE NASH: Yes.
MS. COMEY: And Mr. Combs had nothing to do with the release of Young & Reckless, correct?
DEONTE NASH: I mean, he was hands on.
MS. COMEY: But it wasn't his company, correct?
DEONTE NASH: No.
MS. COMEY: So someone else was making money off of Young & Reckless with Cassie, correct?
DEONTE NASH: Yes.
MS. COMEY: How long did that last?
DEONTE NASH: I don't remember.
MS. COMEY: Do you know someone named Bana?
DEONTE NASH: Yes.
MS. COMEY: Did Bana have something to do with Young & Reckless?
DEONTE NASH: Yes.
MS. COMEY: What did Bana have to do with Young & Reckless?
DEONTE NASH: She was a designer.
MS. COMEY: So Bana was the designer for Young & Reckless, is that right?
Is that a yes?
DEONTE NASH: Um, yes.
MS. COMEY: And Bana -- would it be fair to say that Bana is a friend of Cassie's?
DEONTE NASH: Yes.
MS. COMEY: And so Bana asked Cassie to help her with Young & Reckless, correct?
DEONTE NASH: Yes.
MS. COMEY: And then Cassie decides to step away from her singing and go into making money with Bana in Young & Reckless, correct?
DEONTE NASH: It wasn't a step-away from syncing.
MS. COMEY: OK. In addition to her singing, she decided to do something else to help her make money, correct?
DEONTE NASH: Correct.
MS. COMEY: And Mr. Combs said that's fine, go ahead and do that, correct?
DEONTE NASH: Yes.
MS. COMEY: Did not hold her back at all, correct?
DEONTE NASH: No, not with that.
MS. COMEY: Now, you said you mentioned a Bad Boy tour that was in 2016.
Do you recall that?
DEONTE NASH: Yes. Yes.
MS. COMEY: And you were part of that tour, correct?
DEONTE NASH: Yes.
MS. COMEY: And when I say part of it, you were a stylist for the tour, correct?
DEONTE NASH: Yes.
MS. COMEY: That means you traveled with the tour, correct?
DEONTE NASH: Oh, no, no, no. I stayed home.
MS. COMEY: You stayed home?
DEONTE NASH: Yeah.
MS. COMEY: I don't blame you.
Where is home, California?
DEONTE NASH: Yes.
MS. COMEY: I'm not mad at you.
So you stayed home and you styled from home?
DEONTE NASH: No. We did a fitting beforehand.
MS. COMEY: What does that mean?
DEONTE NASH: Um, you do a fitting, you prep the clothes, and Derek took the clothes with him.
MS. COMEY: When you say prep the clothes, what does prep --
We don't know what that means. What do you mean by prep the clothes?
DEONTE NASH: You go shopping, you make outfits, you pack everything and, you know, we put it on garment racks, you have a fitting, and you take the edits with you.
MS. COMEY: Well, for how many people, for how many artists did you do that for?
DEONTE NASH: I think maybe, like, four.
MS. COMEY: Which artists?
DEONTE NASH: It was Lil' Kim, Cassie, Puff, and Mase, I want to say.
MS. COMEY: So, fair to say then, that back in 2016, during this particular tour, you did the styling or helped do the styling for what would be considered major musicians at that time, correct?
DEONTE NASH: Yes.
MS. COMEY: Mase would be a major platinum-selling musician, correct?
DEONTE NASH: Not at the time.
MS. COMEY: Well, overall?
DEONTE NASH: Yes.
MS. COMEY: And who else was there?
DEONTE NASH: Lil' Kim.
MS. COMEY: Major platinum-selling artist, correct?
DEONTE NASH: Yes.
MS. COMEY: Mr. Combs, as well?
DEONTE NASH: Yes.
MS. COMEY: Major platinum-selling artist, correct?
DEONTE NASH: Yes.
MS. COMEY: And your personal client was Cassie?
DEONTE NASH: Yes.
MS. COMEY: Anyone else on that tour?
DEONTE NASH: No.
MS. COMEY: And this was after --
Just quickly, you mentioned something about seeing a black eye on FaceTime. Do you remember saying that?
DEONTE NASH: Yes.
MS. COMEY: And that was after this InterContinental incident, correct, during the InterContinental incident, correct?
DEONTE NASH: No. The black eye -- yes, I did see that one, yes. I thought you meant the Vegas. Yes.
MS. COMEY: And this tour that you styled for was after that, correct?
The tour was in May, June 2016, and the incident at InterContinental happened in March 2016, correct?
DEONTE NASH: Hmm. Yes, but there was a show, maybe, like a year before, before the tour, at Barclays. It was maybe, like, a two-night show and then, maybe, I want to say the next year, six months later, then they went out on tour.
MS. COMEY: Who was in the show?
DEONTE NASH: Bad Boy artists.
MS. COMEY: Who?
DEONTE NASH: Carl Thomas. I don't remember.
MS. COMEY: Did you style for them as well?
DEONTE NASH: I actually did, yeah.
MS. COMEY: You styled for Carl Thomas, as well?
DEONTE NASH: Yes.
MS. COMEY: Let's get this right then.
You started as an intern 2007, 2008. You catapulted to celebrity stylist, right?
DEONTE NASH: Yes.
MS. COMEY: And then after that, by the time 2016 came around, you styled Carl Thomas, Sean Combs, Mase, Lil' Kim?
DEONTE NASH: Yes.
MS. COMEY: Who else?
DEONTE NASH: Cassie.
MS. COMEY: Cassie?
DEONTE NASH: Um-hmm.
MS. COMEY: Anybody else?
DEONTE NASH: Puff. Who else?
MS. COMEY: So based upon your internship with Bad Boy, you became a serious celebrity stylist, correct?
DEONTE NASH: Yes.
MS. COMEY: Is that a yes?
DEONTE NASH: Yes.
MS. COMEY: Now, I'm going to get back to your studio stuff.
You said Cassie was inside the studio all the time. These studio sessions weren't just by herself, though, correct?
DEONTE NASH: What do you mean?
MS. COMEY: Well, we talked about this mix tape.
Do you recall talking about that?
DEONTE NASH: Yes.
MS. COMEY: All right. And the mix tape, for some of the jurors that might not know what it is, a mix tape is a tape of a lot of different songs, correct?
DEONTE NASH: Yes.
MS. COMEY: With various artists, correct?
DEONTE NASH: Yes.
MS. COMEY: And in this particular situation, the mix tape they were talking about was Cassie and a lot of different people, correct?
DEONTE NASH: Yes.
MS. COMEY: And all these artists had to be in studios, had to do work with Cassie to make their particular song, correct?
DEONTE NASH: They weren't necessarily in the studio all the time.
MS. COMEY: Not all the time?
DEONTE NASH: Yes. Some of them, yes.
MS. COMEY: Some of them, right? OK.
So the mix tape that Cassie made while being with Bad Boy had --
well, you recall the mix tape, correct?
DEONTE NASH: Yes.
MS. COMEY: You said you helped -- what did you say you helped do? You helped make it? You helped --
DEONTE NASH: Yeah.
MS. COMEY: No. Tell us what you did.
DEONTE NASH: I helped Cassie pick songs, I helped her set up sessions, I helped with the creative ideas.
MS. COMEY: So you went from celebrity stylist to executive producer status?
DEONTE NASH: I mean, yeah.
MS. COMEY: Say that again louder.
DEONTE NASH: Actually, my original interview with Bad Boy was to work in AR.
MS. COMEY: All right. But at this point 2016, you are basically executive producing this mix tape, correct?
DEONTE NASH: With the team. We have a team.
MS. COMEY: You got no credit for that, right?
DEONTE NASH: No.
MS. COMEY: You got paid no money for that?
DEONTE NASH: No one got paid for the mix tape.
MS. COMEY: You even get no acknowledgment for being the executive producer of the mix tape, correct?
DEONTE NASH: No.
MS. COMEY: So no one besides you and Cassie knew what you did on this mix tape, is that fair to say?
DEONTE NASH: No. Rob Holiday.
MS. COMEY: Rob Holiday --
DEONTE NASH: Dominique.
MS. COMEY: -- rob Holiday is the low-budget producer you said earlier?
DEONTE NASH: Yes.
MS. COMEY: Is that what you said?
DEONTE NASH: Yes.
MS. COMEY: When you said low-budget producer, you were just saying that because he's a low-paying producer, or he's not a good producer, he's a whack producer?
Why is he a low-budget producer?
DEONTE NASH: Hmm, a little bit of all of the above.
MS. COMEY: And he was, this low-budget producer, was also on the mix tape, correct?
DEONTE NASH: Yes.
MS. COMEY: Meek Mills on the mix tape, correct?
DEONTE NASH: Yes.
MS. COMEY: And Meek Mills at that time was a really popular internationally known rap artist, correct?
DEONTE NASH: Correct.
MS. COMEY: You also said French Montana, correct?
DEONTE NASH: Yes.
MS. COMEY: He also was a pretty well-known popular rap artist, correct?
DEONTE NASH: Correct.
MS. COMEY: Jeremih, right?
DEONTE NASH: Yes.
MS. COMEY: Platinum-selling artist?
DEONTE NASH: Oh, I don't know his stats.
MS. COMEY: Very popular at the time, correct?
DEONTE NASH: Yes.
MS. COMEY: Fabolous?
DEONTE NASH: Yes.
MS. COMEY: Very popular rap artist?
DEONTE NASH: Yes.
MS. COMEY: Pusha T?
DEONTE NASH: Yes.
MS. COMEY: Pusha T was on the mix tape?
DEONTE NASH: Yes.
MS. COMEY: Whiz Khalifa?
DEONTE NASH: Yes.
MS. COMEY: And, just so we're clear, Pusha T and Whiz Khalifa are both really well-known popular major rap artists, correct?
DEONTE NASH: Correct.
MS. COMEY: Rick Ross?
DEONTE NASH: Yes.
MS. COMEY: At that time, Rick Ross was super major well-known rap artist, correct?
DEONTE NASH: Correct.
MS. COMEY: Too Short?
DEONTE NASH: Yes.
MS. COMEY: The Too Short from the West Coast?
DEONTE NASH: Yes.
MS. COMEY: Who decided that, you?
DEONTE NASH: Um...
MS. COMEY: You're from California?
DEONTE NASH: I'm from California, yes.
MS. COMEY: Did you pick Too Short?
DEONTE NASH: Um, no, not -- no.
MS. COMEY: But Too Short was on there, too?
DEONTE NASH: Yes.
MS. COMEY: And he is really well-known, correct?
DEONTE NASH: Moderately.
MS. COMEY: Moderately.
So this -- these rap artists, these platinum-selling popular rap artists at the time, all were on Cassie's mix tape, correct?
DEONTE NASH: Correct.
MS. COMEY: And that's only possible because the label got them to do that, correct?
DEONTE NASH: The label and Cassie, yes.
DEONTE NASH: Do you guys mind if I take a break?
THE COURT: You need a break?
DEONTE NASH: Um-hmm, I do.
THE COURT: OK. Let's take a break.
DEONTE NASH: All right.
THE COURT: Members of the jury, we'll take a short break and come back.
Let's come back at 3:30. Thank you very much.
All rise.
(Continued on next page)
(Jury not present)
THE COURT: Mr. Nash, you're not to have any discussions with the government lawyers here, but you can take your break.
We'll be back here at 3:30.
DEONTE NASH: Thank you.
(Witness temporarily excused)
THE COURT: Please be seated.
Mr. Donaldson, about how much time do you have left?
I'm just mindful of the issues that were raised before.
MR. DONALDSON: I have absolutely no reason to believe I'll be finished by 4:00.
THE COURT: All right. Then should we let the jury go home, since they are supposed to go home at 3:00?
MR. DONALDSON: Yes. I won't be finished by 4:00, I can tell you that clearly.
THE COURT: Wait. But did you know that you were not going to be finished by 4:00 when we had the discussion and I told the jury that I was going to get them out by 4:00? Because if you knew that --
THE COURT: -- you should have told me that. We would have let the jury go, and Ms. Comey or other folks from the government side could have made appropriate arrangements, given that there's a flight later today.
MR. DONALDSON: Respectfully, Judge --
THE COURT: Is this a late-breaking development that you now think you won't be done by 4:00?
MR. DONALDSON: Judge, respectfully, I tried to do what the court and Ms. Comey was considering, which is try to get finished by 4:00.
After going through what I'm going through, I'm telling the court that I do not think I'll be done by 4:00.
THE COURT: I understand.
Look, you should ask the questions you need to ask. My only request is, moving forward, just let me know, because I don't want to tell the jury something and then have them leave. I don't know. When they think they are going to be here, we can finish something up, I let them go. I want to be able to give the right instructions to the jury in the future.
MR. DONALDSON: I totally appreciate that.
THE COURT: All right. So, given that, I've told them we'll keep them here through 4:00.
Let's go ahead and see what we can do here. Let's go to 4:00, and then at that point, we'll adjourn for the day.
Anyone from the government's side, any response or anything regarding scheduling that we need to know?
MS. COMEY: I'll work on rebooking the witness's flight, your Honor.
I'll note that this witness does not seem to be fighting Mr. Donaldson. He seems to be answering the questions. I think many of the questions are repetitive and covering the same territory over and over again. I'm hoping we can be more efficient.
THE COURT: You mean, how would you define stylist?
MS. COMEY: Exactly, your Honor.
THE COURT: All right. So let's go to 4:00 and then we'll take a break. And then on the break, you know, the only thing is, we do need to move this along. Maybe we can use the break to make sure that we're being as streamlined as possible.
Again, Mr. Donaldson, I understand what you said. I hear you, the questions you need to ask, and you're fully permitted to ask those questions.
MR. DONALDSON: I appreciate that, Judge. Thank you.
THE COURT: We'll take a break and come back at 3:30.
MR. STEEL: Thank you, sir.
(Recess)
THE COURT: Please be seated.
Let's have Mr. Nash back.
(Witness returned)
THE COURT: Welcome back.
DEONTE NASH: Thank you.
THE COURT: It's not just you. It's freezing in here.
DEONTE NASH: It is freezing in here. I'm, like, how y'all do this all day.
(Continued on next page)
(Jury present)
BY MR. DONALDSON:
MS. COMEY: Mr. Nash, welcome back.
DEONTE NASH: Thank you.
MS. COMEY: You're welcome. Nice coat.
DEONTE NASH: Ah, thank you.
MS. COMEY: You're very welcome. What size is it?
DEONTE NASH: Not yo size.
MS. COMEY: That's the right answer. You got the right answer.
I just want to ask you a few more questions about the stylist part. I'm just going to go real quickly.
When we talk about styling for labels, for Bad Boy in particular, Mr. Combs would be the person that makes the final decision in those people -- in those artists' performance clothing, is that correct?
DEONTE NASH: Not all, no.
MS. COMEY: Who would be the final decision-maker?
DEONTE NASH: Um, most of the artists kind of did their own thing.
MS. COMEY: But they would send it to Mr. Combs or someone to get some type of consultation in the decision-making, would that be fair to say?
DEONTE NASH: Not that I know of. Some of them look terrible.
MS. COMEY: The ones that you did, that didn't look terrible?
DEONTE NASH: Um, yeah.
MS. COMEY: OK. All right. And as far as the mix tape is concerned, several platinum-selling artists that appeared on that mix tape, those had to be approved by Mr. Combs or the label, correct?
DEONTE NASH: Correct.
MS. COMEY: And when you mentioned that it did well streaming but didn't get released commercially or for profit, that's a decision to be made by the label, correct?
DEONTE NASH: Correct.
MS. COMEY: Now, I just want to move a little bit to a different section.
You said you and Mrs. Fine are good friends, is that fair to say?
DEONTE NASH: Yes.
MS. COMEY: And sometimes you would even consider yourself her best friend, correct?
DEONTE NASH: Yes.
MS. COMEY: And when you say best friend, would it be fair to say you spoke to her a lot between 2008 and -- well, today, would that be fair to say?
DEONTE NASH: Yes.
MS. COMEY: And do you also speak to someone named Bana?
DEONTE NASH: Yes.
MS. COMEY: And Bana, I believe you said, is a designer, is that correct?
DEONTE NASH: Yes.
MS. COMEY: And how often do you speak to her?
Let me ask a different question. When is the last time you spoke to her?
DEONTE NASH: Yesterday.
MS. COMEY: And I'm sure you were told not to speak to her about her -- about your testimony or her testimony, correct?
DEONTE NASH: Absolutely.
MS. COMEY: And you didn't do that?
DEONTE NASH: No.
MS. COMEY: You spoke to her about coming to New York and having to testify?
DEONTE NASH: Yes.
MS. COMEY: And the last time you spoke to --
DEONTE NASH: I didn't speak with her with it. She saw it on the news. But yes.
MS. COMEY: OK. And the last time you spoke to her was yesterday. And before that was when?
DEONTE NASH: Oh, I don't know. Probably a couple days.
MS. COMEY: So it would be fair to say that Bana, at least, you have spoken to her often over the last three weeks?
DEONTE NASH: Yeah.
MS. COMEY: Now, as far as Cassie is concerned, she's your good friend or best friend.
What is the last time you spoke to her?
DEONTE NASH: After she had the baby yesterday. Tell her congratulations.
MS. COMEY: Oh, you're saying congratulations or you're telling me to tell her congratulations?
DEONTE NASH: No, no. No thanks.
THE COURT: All right. Let's keep going.
MS. COMEY: The last time you spoke to her was yesterday?
DEONTE NASH: Yes.
MS. COMEY: And before that was when?
DEONTE NASH: Probably the day before that.
MS. COMEY: So it's fair to say that you spoke to her --
You know she testified in this trial, correct?
DEONTE NASH: Yes.
MS. COMEY: You spoke to her before she testified, correct?
DEONTE NASH: Yes.
MS. COMEY: You spoke to her after she testified, correct?
DEONTE NASH: Yes.
MS. COMEY: Did you speak to her in the middle of her testimony?
DEONTE NASH: Um, not really, no.
MS. COMEY: You say not really. What does that mean?
Did she call you? Did you ask her how she's doing?
DEONTE NASH: How she was doing. But more, like, her clothes stuff. And Marni handled most of that because she was here in New York and I was in Los Angeles.
MS. COMEY: So you spoke to her about what clothes she should wear while she was testifying, is that fair to say?
DEONTE NASH: Yes.
MS. COMEY: You also mentioned -- I want to talk to you a little bit about drug use or Cassie's drug use.
Do you recall testifying about that?
DEONTE NASH: Yes.
MS. COMEY: I believe you said she takes cocaine, is that right?
DEONTE NASH: Yes, yes.
MS. COMEY: Or was?
DEONTE NASH: Yes.
MS. COMEY: She also took prescription pills?
DEONTE NASH: Yes.
MS. COMEY: She also took what else?
DEONTE NASH: Molly and ectasy.
MS. COMEY: She also used mushrooms and acid, as well, correct?
DEONTE NASH: Mushrooms. The acid, I'm not, like, privy on that.
MS. COMEY: And when she took these drugs, you actually saw her taking these drugs, correct?
DEONTE NASH: Sometimes.
MS. COMEY: Which drugs did you see her take?
DEONTE NASH: Cocaine, ectasy, and molly.
MS. COMEY: And when you saw her taking these drugs, it would be inside her house, correct?
DEONTE NASH: Yes.
MS. COMEY: And sometimes inside your house, correct?
DEONTE NASH: No.
MS. COMEY: So you would be inside her house, and at that point you would observe her taking cocaine, ectasy, or what was the other one?
DEONTE NASH: Molly.
MS. COMEY: Molly. And she would have the drugs already in her house?
DEONTE NASH: That was so long ago.
MS. COMEY: How long ago was it?
DEONTE NASH: I don't recall. Like, 2017, '18.
MS. COMEY: OK. So in 2017 or '18, we're saying, you're saying that you were in her house and you observed Cassie taking either cocaine, molly, or some prescription pill?
DEONTE NASH: Yes.
MS. COMEY: But you don't know whether she got it from inside her house?
DEONTE NASH: Correct.
MS. COMEY: You don't know whether it was already there when she took it?
DEONTE NASH: No.
MS. COMEY: And it's true that nobody delivered it to her, though, correct?
DEONTE NASH: I have no clue. I'm not the friend that, you know, that they indulge that stuff to.
MS. COMEY: OK. Not to get too much into your business.
You have used cocaine before?
DEONTE NASH: Yes.
MS. COMEY: You have used ectasy and molly before?
DEONTE NASH: Um, I tried ectasy and I tried molly, yes.
MS. COMEY: It's fair to say that you don't do that anymore now, correct?
DEONTE NASH: Absolutely not.
MS. COMEY: And you still smoke marijuana --
Do you smoke marijuana?
DEONTE NASH: Yes.
MS. COMEY: On the few of your meetings with the government, were you -- did you arrive at the meeting before smoking marijuana?
DEONTE NASH: One of them Maurene cut it short.
MS. COMEY: Because of what?
DEONTE NASH: She said she wanted me to have a clear mind.
MS. COMEY: So you went to the meeting and you told her that you were high at that time?
DEONTE NASH: Yeah. I didn't say high. I said I'm smoking right now. I didn't say I was high.
MS. COMEY: I'm sorry.
So you told her that you were smoking -- well, not in the meeting, before you got to the meeting?
DEONTE NASH: Yes.
MS. COMEY: And then Ms. Comey told you, you need to stop the meeting because she wanted you to have a clear mind?
DEONTE NASH: Yes.
MS. COMEY: Do you know which meeting that was?
DEONTE NASH: I don't know. I told her very early in the meeting.
MS. COMEY: OK. So we know you had a meeting April 2025 and three meetings in May of 2025.
Do you know whether it was in April or May of 2025?
DEONTE NASH: I don't know. It was, like, all running together at this moment.
MS. COMEY: Now, in your -- between 2008 and 2018, that's when you left Bad Boy, correct?
DEONTE NASH: Yes.
MS. COMEY: And you -- I believe you testified earlier that you were, you had some interactions with security guards at work for Bad Boy that worked with Mr. Combs, correct?
DEONTE NASH: Yes.
MS. COMEY: And in those several years, you never saw any of those security guards with guns, correct?
DEONTE NASH: I don't recall.
MS. COMEY: Besides -- well, strike that.
You never saw those security guards committing any acts of violence, correct?
DEONTE NASH: No.
(Continued on next page)
BY MR. DONALDSON:
MS. COMEY: And you never saw those security guards delivering any narcotics to Cassie, correct?
DEONTE NASH: No.
MS. COMEY: And you never saw those security guards delivering any narcotics to you, correct?
DEONTE NASH: No.
MS. COMEY: And you never saw any of those security guards delivering narcotics to Mr. Combs, correct?
DEONTE NASH: No.
MS. COMEY: In fact, it's fair to say that in your nine or ten years of working at Bad Boy and -- well, strike that.
Were you getting paid from Mr. Combs from 2009 to 2018?
DEONTE NASH: Yes.
MS. COMEY: So for all those years you were actually receiving a check from the Combs --
DEONTE NASH: Combs Enterprise and some of the other entities, yes.
MS. COMEY: So it would be fair to say you were an employee all that time?
DEONTE NASH: Yes.
MS. COMEY: And as an employee of Combs Enterprises, of Mr. Combs, you didn't participate in any criminal conduct for Mr. Combs, correct?
DEONTE NASH: I know that he --
MS. COMEY: You -- did you participate in any criminal conduct for Mr. Combs?
DEONTE NASH: Yes.
MS. COMEY: Okay. You also said you were at a music video shoot where you got thrown against a car?
DEONTE NASH: Yes.
MS. COMEY: Which video shoot was that?
DEONTE NASH: I Love It.
MS. COMEY: When was that?
DEONTE NASH: 2013.
MS. COMEY: And whose video shoot was that?
DEONTE NASH: Cassie.
MS. COMEY: Who else was in the video besides Cassie?
DEONTE NASH: Fabolous.
MS. COMEY: I'm sorry?
DEONTE NASH: Fabolous.
MS. COMEY: And was that part of the mix tape?
DEONTE NASH: Yes.
MS. COMEY: And the video for that particular song was -- it cost to make that video, correct?
DEONTE NASH: Yes.
MS. COMEY: And that cost for the video was paid for by Bad Boy, correct?
DEONTE NASH: Yes. It was never released.
MS. COMEY: I understand that. But was the video made?
DEONTE NASH: Yes.
MS. COMEY: Was Fabolous in the video?
DEONTE NASH: Yes.
MS. COMEY: Was Ms. Fine in the video?
DEONTE NASH: Yes.
MS. COMEY: Was there a cost associated with that video?
DEONTE NASH: Yes.
MS. COMEY: And Mr. Combs and Bad Boy paid for that video?
DEONTE NASH: Yes.
MS. COMEY: Were there other videos made for the mix tape -- well, there was.
Did Rick Ross make a video?
DEONTE NASH: Yes.
MS. COMEY: Was that video with Cassie?
DEONTE NASH: Yes.
MS. COMEY: And was that video paid for by Bad Boy?
DEONTE NASH: Yes.
MS. COMEY: So then it's fair to say then that at least in 2013 or up to there Bad Boy Records or Mr. Combs invested significant money into videos and studio time for Cassie; is that correct?
DEONTE NASH: Yes.
MS. COMEY: Was that a yes?
DEONTE NASH: Yes.
MS. COMEY: And we say invested significant money, based upon your experience, videos, to make a video, costs hundreds of thousands of dollars, correct?
DEONTE NASH: Not the videos we were shooting, no.
MS. COMEY: Okay. How many videos did you all make for that particular mix tape, if you know?
DEONTE NASH: The first three I know Puff paid for and then there were two other ones that we did that Cassie paid for.
MS. COMEY: Now, you also mentioned earlier today about an incident where there was -- Ms. Fine sustained a cut to her head; do you recall that?
DEONTE NASH: Yes.
MS. COMEY: What year was that?
DEONTE NASH: 2013. '12, '13.
MS. COMEY: I think Ms. Comey asked you a few times if you were estimating. Do you know whether it was 2013, 2014?
DEONTE NASH: I'm not sure.
MS. COMEY: Estimating 2013?
DEONTE NASH: Yes. Let's just say that.
MS. COMEY: Okay. Now, at that time you had only been working for with Cassie and Mr. Combs for approximately five, approximately four, five years, correct?
DEONTE NASH: Correct.
MS. COMEY: And I believe you said during that incident Mr. Combs came over to Cassie's house; is that right?
DEONTE NASH: Yes.
MS. COMEY: And she was on the couch; is that correct?
DEONTE NASH: Yes.
MS. COMEY: And this was the day that you all were about to go to Toronto for a Drake concert or Drake performance, whatever it was, right?
DEONTE NASH: Yes.
MS. COMEY: And Mr. Combs I believe you said knocked on the door and you let him in, correct?
DEONTE NASH: Yes.
MS. COMEY: And when you let him in, he then grabbed Cassie's hair and started beating on her, correct?
DEONTE NASH: Correct.
MS. COMEY: Now, I believe you said that there was somebody else present in the house at that time. Who was that?
DEONTE NASH: Mia.
MS. COMEY: And Mia at that time worked for Mr. Combs, correct?
DEONTE NASH: Yes.
MS. COMEY: Do you know what her position was?
DEONTE NASH: She was his assistant.
MS. COMEY: His assistant?
DEONTE NASH: Mm-hmm.
MS. COMEY: Is that a yes?
DEONTE NASH: Yes.
MS. COMEY: Okay. And then you said at that time that you and Mia and Cassie ran to the bedroom, correct?
DEONTE NASH: Yes.
MS. COMEY: And Mr. Combs ran behind you, correct?
DEONTE NASH: Yes.
MS. COMEY: And then at some point he grabbed Cassie again; is that right?
DEONTE NASH: Yes.
MS. COMEY: And then you jumped on his back to protect Cassie, correct?
DEONTE NASH: Correct.
MS. COMEY: So as an employee of Mr. Combs, you jump on his back to protect Cassie from him, correct?
DEONTE NASH: Yes.
MS. COMEY: And as an employee -- Mia you said was an employee as well, correct?
DEONTE NASH: Yes.
MS. COMEY: And she jumped on his back to protect Cassie from Mr. Combs, correct?
DEONTE NASH: Yes. And protect him from doing something more serious.
MS. COMEY: Okay. So you -- both employees of Mr. Combs at that time, was trying to protect Cassie from Mr. Combs, correct?
DEONTE NASH: Correct.
MS. COMEY: And I believe you said on direct -- well, maybe you didn't, but this was the first time that you had saw a gash on Cassie's head as related to Mr. Combs' conduct, correct?
DEONTE NASH: Yes.
MS. COMEY: And that -- be fair to say that startled you, correct?
DEONTE NASH: Absolutely.
MS. COMEY: And it concerned you because you're -- at this time, she was still a good friend of yours, correct?
DEONTE NASH: Yes.
MS. COMEY: And you had been talking to her every day between -- almost every day between 2008 and 2013; is that fair to say?
DEONTE NASH: Yes.
MS. COMEY: So when this violent incident happened where Mr. Combs caused Cassie to hit her head on a bed frame and bleeding, that shocked you, correct?
DEONTE NASH: Yeah. Completely.
MS. COMEY: Because your friend, your good friend, Cassie, was now bleeding with a gash on her head?
DEONTE NASH: It wasn't about her -- it wasn't about it being my friend. It was about the act in general.
MS. COMEY: So the act in general of Mr. Combs causing a gash on Cassie's head, that shocked you, correct?
DEONTE NASH: Yes.
MS. COMEY: But you, after that, you did still have interactions with Mr. Combs, correct?
DEONTE NASH: Yes.
MS. COMEY: You did still have interactions with Cassie, correct?
DEONTE NASH: Yes.
MS. COMEY: You did still have interactions where you invited Mr. Combs to some place where Cassie was, correct?
DEONTE NASH: Yes.
MS. COMEY: In fact, I believe it was, if you remember, Halloween of that year, I believe you invited both of them to the Boulevard to go to a Halloween show, correct?
DEONTE NASH: Yeah.
MS. COMEY: And that was after the cut, correct?
DEONTE NASH: Absolutely.
MS. COMEY: So after the violence by Mr. Combs, you invited him and Cassie to come with you to a Halloween function, correct?
DEONTE NASH: Correct.
MS. COMEY: You also mentioned an incident involving D-Roc. Do you know who D-Roc is?
DEONTE NASH: Yes.
MS. COMEY: Who is D-Roc?
DEONTE NASH: Puff's long time friend and security.
MS. COMEY: Be fair to say he was head of security, correct?
DEONTE NASH: Yes.
MS. COMEY: Now, there was an incident where I believe you said you were cooking in -- was it your apartment or Cassie's apartment?
DEONTE NASH: Cassie's.
MS. COMEY: And I believe you said at that time Mr. Combs came over to Cassie's house, correct?
DEONTE NASH: Yes.
MS. COMEY: Knocked on the door and you let him in; is that right?
DEONTE NASH: Yes.
MS. COMEY: Mr. Combs, when he arrived inside the house, he was -- was he angry?
DEONTE NASH: He was calm.
MS. COMEY: And this was after the cut as well, after the cut on the bed frame?
DEONTE NASH: Mm-hmm. Yes.
MS. COMEY: All right. So he called you before he came over, correct, or he called Cassie before he came over?
DEONTE NASH: Called Cassie.
MS. COMEY: And, if you know, Cassie let him know that you all were over there cooking, correct?
DEONTE NASH: I don't know.
MS. COMEY: And when he arrived at the home, you and -- well, him and Cassie get into an argument; is that fair to say?
DEONTE NASH: No, they went to the room, but I didn't hear like -- I didn't hear an argument.
MS. COMEY: So when he got there, he and Cassie went to the room and you stayed in the kitchen?
DEONTE NASH: Yes.
MS. COMEY: And at some point they came back outside; is that right?
DEONTE NASH: Yes.
MS. COMEY: And I believe you said on direct that at that moment Cassie -- he started pushing Cassie out the door; is that correct?
DEONTE NASH: Yes.
MS. COMEY: And then he started I think you said slapped you in the back of the head and moving you out the door; is that right?
DEONTE NASH: Yes.
MS. COMEY: And when you got outside, D-Roc was outside, correct?
DEONTE NASH: Yes.
MS. COMEY: And D-Roc is head of security?
DEONTE NASH: Yes.
MS. COMEY: Or one of the heads of security?
DEONTE NASH: Yes.
MS. COMEY: Now, when you got outside, isn't it fair to say that security was trying to convince Mr. Combs to stop bothering you and Cassie?
DEONTE NASH: Yes.
MS. COMEY: And when we say that, we're saying that Mr. Combs' security, at that point, his employees, was telling him to basically leave you guys alone, correct?
DEONTE NASH: Yes.
MS. COMEY: They were not trying to participate in doing anything to you, correct?
DEONTE NASH: Correct.
MS. COMEY: They were trying to stop him from doing something to you, correct?
DEONTE NASH: Correct.
MS. COMEY: And they were telling him that he should leave you alone, correct?
DEONTE NASH: Yes.
MS. COMEY: And that was D-Roc and other members of his security team, correct?
DEONTE NASH: Yes.
MS. COMEY: Those are other employees of Mr. Combs, correct?
DEONTE NASH: Correct.
MS. COMEY: At some point I believe you said you all went to the hotel; is that right? Is this the same instance when you went to the hotel?
DEONTE NASH: Mm-hmm.
MS. COMEY: Is that a yes?
DEONTE NASH: Yes.
MS. COMEY: Do you know who Uncle Paulie is?
DEONTE NASH: Yes.
MS. COMEY: In fact, on that day -- do you know who Ruben is?
DEONTE NASH: Yes.
MS. COMEY: On that day, Rube, Uncle Paulie, and D-Roc was there, correct?
DEONTE NASH: I don't recall.
MR. DONALDSON: Can we have one second, please, Judge.
THE COURT: Yes.
MR. DONALDSON: Can we please put up 35-1412 for the parties and witness only.
Can we highlight the four boxes under the fifth open circle.
MS. COMEY: Mr. Nash, can you do me a favor and read that to yourself. When you're finished reading it, lift up your head, let me know you're finished reading it, and then I'll follow up with some questions.
DEONTE NASH: Okay.
MR. DONALDSON: Take that down, please.
MS. COMEY: Now, I just want to ask you some questions.
Now, after reading that does that refresh your recollection as to whether or not Rube and Uncle Paulie were there at that particular time?
DEONTE NASH: I don't remember.
MS. COMEY: Okay.
DEONTE NASH: I don't recall.
MS. COMEY: Okay. You do recall -- well, not you do recall.
Do you recall whether or not Uncle Paulie and Rube also in the past told Mr. Combs to leave you alone?
DEONTE NASH: Yes.
MS. COMEY: And when Uncle Paulie and Rube told Mr. Combs to leave you all alone, they were acting in their capacity as his employees, correct?
DEONTE NASH: Yes.
MS. COMEY: So those moments, his employees were actually trying to protect -- stop him from doing something against you all, correct?
DEONTE NASH: Correct.
MS. COMEY: Now, you mentioned someone named I believe it was Toni; do you remember saying that?
DEONTE NASH: Yes.
MS. COMEY: Her name was Toni Fletcher, correct?
DEONTE NASH: Correct.
MS. COMEY: I believe they showed you a picture of Ms. Fletcher on the screen, correct?
DEONTE NASH: Yes.
MS. COMEY: And I believe you said that Ms. Fletcher was Bad Boy's chief of staff; is that correct?
DEONTE NASH: Correct.
MS. COMEY: And I believe you mentioned on one of the occasions, on this occasion, you went to the hotel and Cassie was upstairs in one of the hotel rooms, correct?
DEONTE NASH: Yes.
MS. COMEY: And then you went upstairs, and who went upstairs with you?
DEONTE NASH: D-Roc and Toni Bias.
MS. COMEY: Toni Bias Fletcher?
DEONTE NASH: Correct.
MS. COMEY: I'm sorry. I didn't know it was Bias.
So you, Toni Bias Fletcher, and D-Roc went upstairs to Cassie's room, correct?
DEONTE NASH: Correct.
MS. COMEY: To see if she was there, correct?
DEONTE NASH: Yes.
MS. COMEY: And then when you saw her -- strike that.
You went inside and she was actually there, correct?
DEONTE NASH: Yes.
MS. COMEY: And D-Roc and Toni Fletcher were again working as employees of Mr. Combs, correct?
DEONTE NASH: Yes.
MS. COMEY: Now, and Cassie at that point, according to your testimony, was running from or hiding from Mr. Combs, correct?
DEONTE NASH: Yes.
MS. COMEY: And, at that time, when they were at this hotel, you, D-Roc, and Toni Fletcher, Cassie eventually came downstairs, correct?
DEONTE NASH: Yes.
MS. COMEY: She came down stairs with Toni Fletcher and D-Roc, correct?
DEONTE NASH: I don't recall.
MS. COMEY: Well, they showed -- they're the ones that showed her out the back door, correct?
DEONTE NASH: No. That's not what I said.
MS. COMEY: I'm not asking what you said.
Isn't it true that Toni Fletcher and D-Roc showed Cassie out the back door, or out the side door?
DEONTE NASH: Probably so. But I remember walking down the front with D-Roc.
MS. COMEY: Okay. That would mean then that Toni Fletcher, as chief of staff of Bad Boy, an employee of Mr. Combs, was actually helping you all as opposed to helping Mr. Combs, correct?
DEONTE NASH: Correct.
MS. COMEY: And that would mean that D-Roc, as the head of security, again, was helping you all as opposed to helping Mr. Combs, correct?
DEONTE NASH: Correct.
MS. COMEY: And as employees of Bad Boy, they were doing something counter to what the head of Bad Boy wanted, correct?
DEONTE NASH: Correct.
MS. COMEY: And that means they were -- when I say counter to, they were doing something to help you as opposed to help Mr. Combs, correct?
DEONTE NASH: Correct.
THE COURT: Mr. Donaldson.
MR. DONALDSON: Yes.
THE COURT: We're about 4:00 p.m.
MR. DONALDSON: I'm sorry, Judge.
THE COURT: This is a good place?
MR. DONALDSON: Yes, it is, Judge. I was trying to be efficient. I'm trying.
THE COURT: Very good. We'll be back tomorrow.
Thank you, members of the jury. Again, don't speak to each other about the case. Don't talk to anyone else about the case. Don't look up anything about the case or reach out to anyone about the case. We'll see you back here to start at 9:00. Try to get here at 8:45. (Continued on next page)
(In open court; jury not present)
THE COURT: Mr. Nash, we will see you here tomorrow. Again, no discussions with anyone from the government.
Please be seated.
MS. COMEY: Your Honor, for the record, we'll need to rebook Mr. Nash's flight, so can I coordinate with him and his counsel just for those logistics, please.
THE COURT: Of course.
MS. COMEY: Thank you.
THE COURT: Anything to address what -- I guess so after our next witness, Mia, who do we have next after Mia?
MS. COMEY: So I think the next witness would be Enrique Santos, but I think that we are unlikely to get to him. I suspect Mia will -- given how long today went, I suspect Mia will take us close to the end of the day Friday, and then if we get to Enrique Santos, I think he'll certainly take us into the weekend.
THE COURT: Very good.
Mr. Agnifilo?
MR. AGNIFILO: Yes. Thank you, your Honor.
THE COURT: In terms of -- I'll get to your issues.
MR. AGNIFILO: Yes.
THE COURT: Just a question. Since we're, except for today, ending earlier, I'm going to ask you to make your exhibit disclosure earlier. And I think this is for your benefit because one of the issues that happened, one of the things that happened today, is that the government's letter came in after midnight. And I think there's a way to avoid that if we're stopping close to 3:00.
So I'm going to make the deadline, instead of 7:00 p.m., 5:00 p.m. So there will be two extra hours. We're only talking about the exhibits that are not being used for impeachment purposes. There shouldn't be that many of those. But what that is going to do is it's going to make it easier for the government to respond, to meet and confer, to let you know what their objections are, which is going to help you make sure that there's no issue getting those exhibits in if they are properly admissible.
Now, we're not going to do that today because it's 4:00 and I'm just telling you this now. But I think looking after today, I think it's important for us to have an earlier deadline so we can avoid some of these after midnight filings.
MR. AGNIFILO: I understand the Court's concern. My concern is by the time we get back to our offices, it's practically 5:00. And it's just -- and it just doesn't give us a lot of time. So let me mix two issues together at the risk of doing that.
I think I might have a possible solution for the access to Mr. Combs. And the solution would be this. There's a SCIF in the marshal's lockup area. It's typically used for confidential information. And we don't -- this is not the typical use of the SCIF, but it is a facility. And I believe the Court could order things to happen that would make access to Mr. Combs there possible.
And one of the ways I think the Court can do -- the Court can do it because the Court can do lots of things. But I also note that under the Bail Reform Act, and I think we actually cited I think it's subdivision I, there's that one sort of subdivision that no one knows --
THE COURT: I got it.
MR. AGNIFILO: But I think what it probably means is that when there's somewhat of an urgent situation of a defendant being able to defend one's self, that the Court can take measures, including -- and I'm not asking for this obviously -- including even letting him leave, you know, a facility. And obviously that would somehow be paid for and ordered.
So it seems to me if that's in the Bail Reform Act and that goes as far as to do that, a more modest accommodation would be there's a room in the building, in the marshal's lockup, and we would need meaningful access. Meaning, you know, as late as we can get. I mean, 9:00 at night, 10:00 at night. And it seems that if the Court has a statutory basis to order things like, well, under these circumstances, you know, the defendant who's incarcerated can temporarily be released we're not asking for anything remotely that extreme, that this must be something that not only can the Court order of its own Article III power and authority, but it's actually rooted in a statute. So that's the ask. That's the target that I'm trying to shoot at.
And I don't know how that's going to play in practice. But I think the Court certainly has the power to order that, and then the logistics of that will have to be taken care of. Just as though if we asked your Honor to do something else, you know, to allow us access so that Mr. Combs could better defend. And let me just add one thing to the record and this is I think the important part.
Every trial is different. And I don't know that this is necessary in every trial. One thing that I've seen is your Honor has given a great deal of thought to making things run as orderly as possible with deadlines that, you know, one of the deadlines is 10:00 p.m. because we want to raise issues for the next day. The problem with this particular trial and having an incarcerated client in this particular trial, is we lose all access to him at about 7:00. 7:30 maybe. So we, from 7:30 until 10:00, we are necessarily having to make decisions without him. And that really isn't right. And is certainly not preferred. And I'm not looking to raise Constitutional issues because I know your Honor is trying to come up with a solution. So we don't need to go there and I'm not going there. Except to say there seems to be, in the statute, something that contemplates this, that in this particular case, we need this degree of access. Maybe not in every case. I've never had a 10:00 p.m. deadline in a case so far. We have one here. Not because your Honor is driving a hard case, but because that's what the case requires. That's what this particular case requires. And it's different than other cases I've tried over the last 35 years. And that's what this case requires. And what this case requires is we just need more access to Mr. Combs.
The best kind of access is in-person access. You know, we were trying with the VTC, that could have worked but it's just not easy to do because the MDC has its own, you know, situation. My hope is that because it's in the building, that if your Honor orders something, the logistics will somehow work themselves out the way sort of the statute contemplates that these logistics would have to work themselves out. So that's my request.
I guess the request, if I could just say it all in one sort of paragraph, is that your Honor direct that the SCIF be made available to Mr. Combs and his defense counsel every night until 10:00. That's the ask.
THE COURT: All right. I hear you, and let me talk to the appropriate people about that request.
MR. AGNIFILO: Yes, Judge.
THE COURT: Now, what I don't understand is what that has to do with the deadlines that concern evidentiary issues. Meaning, you've had months to prepare for trial and the Court purposely had deadlines that the government didn't like, let me put it that way, for the disclosure of witnesses, exhibits, and so forth. And the reason for that is so that you would be aware of what was coming down the pike and could prepare your case.
Now, despite all of that, when the government requested that exhibits that would go to the defendant's case in chief be produced at the beginning of this trial, the Court rejected that request and then said that you would just need to turn them over the day before. And these are only the ones that go to your affirmative case and not to impeachment.
And so, in that regard, the problem that we're having is that because the exhibits are being turned over late, and this is just like telling here's the things we might use so that the government can lodge their evidentiary objections, is just coming in late. Which is causing issues like getting a letter at 12:36 a.m. that the defense can't respond to until the morning.
So I don't see what that issue has to do with the issue concerning the SCIF. So is there any issue moving the deadline up -- not today because it's 4:00 -- but for days coming up since we're ending close to 3:00. You'll have enough time to just get those exhibits over. If you have, like if there's one you missed, okay, you get it over late, and that's fine because there's a good cause. I said in my order that if there's some cause, some reason that there's an extra exhibit, that's okay. But just to get it turned over a little bit earlier so people don't have to be up until 2:00 in the morning.
MR. AGNIFILO: One second, Judge.
MS. GERAGOS: Your Honor, I apologize for jumping in on this. I heard your Honor this morning about not appreciating multiple lawyers addressing one issue. If you would allow me to address this point.
THE COURT: That's fine.
MS. GERAGOS: Thank you.
Our affirmative exhibits, your Honor, change on a daily basis with each witness based on the testimony that comes out with each witness. So while it would be great and preferred I think for us to know everything we're going to use for the witnesses in the upcoming week, it's not practical on the defense side because we are responding -- we really are responding to testimony that comes in on a daily basis.
So just practically I want to explain to your Honor why this is difficult for us and why 7:00 p.m. works. I understand what -- none of us want to be up as late as we are every single night. It's just what's happening.
The government preps their witnesses every night and then gets to our exhibits and we're dealing with -- we're meeting and conferring all the time. But just so I can explain to your Honor practically what happens is we're getting the government's witnesses for the next week when they're ordered to give it over. We spend weekends with Mr. Combs with visitation cuts off at 2:15. We all have child care issues that's not always practical. We have to go over with him the affirmative exhibits that we want to go over for the witnesses who are available in the upcoming week or who are going to be called by the government. Then we are with him afterwards after court until about 5:00 p.m. going over the witnesses for the next day.
So when Mr. Agnifilo says we're just practically not at our office until, you know, 5:00, 5:30, it's because we're meeting with our client to try to figure out what do we need to get out affirmatively for the next day. We have made great efforts to work with your Honor's deadline to get these over to the government by 7:00 p.m. And we do over mark our exhibits because we don't really know what we'll use based on the testimony. And that's what leads to a lot of the letters because we are over marking in an abundance of caution so that the government can see anything that we may use for each witness.
But I think it's because our affirmative exhibits change daily based on testimony that we get in court. It's why kind of a 5:00 p.m. makes it very difficult because we're meeting with our client after court, then going to our office, which is uptown, and then based on our conversations changing those exhibits.
I will note that for Mia, we have given the government, as your Honor knows, I think all the exhibits so far that we've marked. There may be some that may change. And I -- we've been meeting and conferring with Ms. Johnson about Mr. Santos. So perhaps we could do this earlier for next week if we were to get the witnesses they're going to call like today or tomorrow, and that could speed things along.
But, practically, with respect to the -- I think that's why Mr. Agnifilo was addressing an incarcerated client, it makes it very, very difficult for us because we have to confer with him while we're addressing what affirmative exhibits to use.
THE COURT: All right. Look, for present purposes, do me a favor, 7:00 p.m. is the deadline. But you're over marking as you noted. So there's probably a set of exhibits that you can get out earlier. Understanding that you're going through them, some of them might not work, you might have additional exhibits to add. But it's just for your benefit to get them out earlier. Because once you get them out by 5:00 or earlier, right, and if there's someone there who can just send those over and say, hey, here are the exhibits we're considering, you're going to have more time to address any government objections and get these in. So that's a request.
MS. GERAGOS: Agree. And we've done that for Mia. We are doing that to the extent we can.
THE COURT: All right.
MS. GERAGOS: We did that. We really did with Mia. We sent them over I think a couple nights ago.
THE COURT: Fair enough.
So as to the issue concerning the SCIF, I've heard you, Mr. Agnifilo. Are you planning to put in something in writing? And the reason why I ask that is sometimes it's easier for me if I need to speak to the marshals to understand the full nature of the question.
MR. AGNIFILO: Yes.
THE COURT: That you put something in writing.
MR. AGNIFILO: Absolutely. I wanted to raise it with your Honor now. I'll have something to the Court in a few hours.
THE COURT: That's helpful. I will talk to them in the meantime, but it's helpful to have something in writing.
And the only other update, I did raise what you said yesterday about the minutes and the reason why the minutes might be helpful as well with the MDC, so I'll let you know when I hear from them.
MR. AGNIFILO: Thank you so much, Judge.
THE COURT: Of course. Anything else from your side?
MR. AGNIFILO: Nothing.
THE COURT: Anything else from the government before we adjourn?
MS. COMEY: One thing to flag, your Honor. We're going to assess among ourselves, but we think we may be moving even ahead of schedule at this point. I know today was a long today, but we're hopeful we are going to be able to cut some witnesses from the witness list, and we wanted to flag for your Honor that we'll plan to let your Honor and the defense know from this week any witnesses we've identified we can cut. I do think we'll end up resting in less than six weeks. I don't know how much less, but I think it will be less than six weeks.
THE COURT: Just I'm so bad with the calendar. But six weeks means?
MS. COMEY: I think our hope is to be able to rest by the end of the second week of June. We may bleed over into the third week.
THE COURT: All right. Very good.
Good. So that's helpful. And given that, I will start looking at the request to charge and then I'll have some parameters of what I'd like to do in that regard. I think it makes a lot of sense a lot of times to have an initial charge conference where we go over to get -- address any larger objections. And so I can take all those into account and come up with a response from the Court based on the parties' submissions. And then we'll have the actual charge conference closer to when we're at the end of the case.
So that's just a heads up, but I'm happy to hear any thoughts on what the parties think might be most productive.
MS. COMEY: I think that makes sense, your Honor, if there's going to be a very short defense case. If there's going to be a longer defense case, they've given quite a long witness list, so if there's going to be a long defense case, we might want to wait. I defer to defense counsel on the timing there.
THE COURT: Yeah. Let me take a look at the requests and see how different they really are.
Anything further from the government?
MS. COMEY: Nothing.
THE COURT: Anything from the defense?
MR. AGNIFILO: Nothing. Thank you.
THE COURT: We'll see everyone here tomorrow at 8:30.
(Adjourned to May 29, 2025, at 8:30 a.m.)