CROSS-EXAMINATION BY MR. STEEL:
MR. STEEL: Let me ask you, while they are getting headphones for you, can you do me a courtesy. Do you still have that binder in front of you?
MR. STEEL: Do we have the binders? One for the jury and for the witness.
MR. STEEL: All right. Let me ask you some questions. We're getting binders for you. Can you tell the jurors, if you don't mind, where you went to school?
MR. STEEL: And what year did you graduate?
MR. STEEL: Do you remember what your GPA would be?
MS. SMYSER: Objection.
THE COURT: Sustained.
MR. STEEL: After graduating, did you go into the workforce?
MR. STEEL: And when you say eventually, did you start work immediately after graduating or shortly after graduating?
MIA: After graduating, I took advantage of the study abroad program. So I did not start working, I believe, until maybe the fall. I'm not sure of the exact dates.
MR. STEEL: OK. Would that be with Pure Chemistry?
MR. STEEL: OK. After that, did you do any work as an assistant to somebody?
MR. STEEL: And when did you do that, what years, if you remember?
MIA: I -- the years? Well, if I started in 2009, maybe 2000 -- maybe 2008 or 2007. I'm not -- I'm not sure of the exact years.
MR. STEEL: And do you remember compiling a resume or a c.v.?
MR. STEEL: And do you remember on your resume, that you had before working with Mr. Combs and his companies, explaining that you have the ability to multitask?
MR. STEEL: You worked well under pressure?
MR. STEEL: Using an energetic and positive approach?
MR. STEEL: You always maintained thick skin?
MR. STEEL: And you're accustomed to and comfortable in a 24/7 role?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MS. SMYSER: We're reading from a document not in evidence, your Honor.
THE COURT: I understand. It's overruled.
MR. STEEL: We can show you, with the court's permission, Defense Exhibit 1753.
MR. STEEL: Your Honor, the exhibits, the binders are coming up to the court at this time, is my understanding, for the witness and the jurors.
MR. STEEL: Do you see what's on the screen, Mr. Combs 1753R?
MR. STEEL: And do you see on the bottom, if it refreshes your memory, that you maintained thick skin? Do you see that? 1753R, by the way.
MR. STEEL: OK. And is this an accurate depiction of your resume or c.v.?
MIA: I mean, it looks -- it looks familiar, but I don't remember the exact document from that long ago.
MR. STEEL: Well, look at the whole document and we can take out the personal, the highlighted version. Does that look like it accurately depicts what you have previously put forth as your c.v.?
MR. STEEL: Your Honor, I would move for the admission of 1753R.
THE COURT: Any objection?
MS. SMYSER: No objection.
THE COURT: All right. 1753R will be admitted.
(Defendant's Exhibit DX 1753R received in evidence)
MR. STEEL: Then 1753 for under seal, your Honor.
THE COURT: That exhibit under seal.
(Defendant's Exhibit DX 1753 (Sealed) received in evidence)
MR. STEEL: May this be published, your Honor?
THE COURT: It may.
BY MR. STEEL:
MR. STEEL: Now, here on this document, as you said, you attended and graduated from James Madison University, right?
MR. STEEL: And that is a prestigious university, would you agree with me; it's well-known?
MR. STEEL: And it says that you graduated bachelor of science in May 2025 with a 3.6 grade point?
MR. STEEL: OK. If I said something different, I apologize. Then it has your majors and your activities?
MR. STEEL: And then starting at the bottom, under experience, your first experience that you list is the office manager here in New York as a designer assistant/executive assistant, fair?
MR. STEEL: And that's January 2006 to September 2006?
MR. STEEL: And in the second bullet point, you catered to celebrity clients, all their studio needs, right?
MR. STEEL: This is something that you wanted to be involved in, around the celebrity entertainment world, is that fair to say?
MR. STEEL: And then if there's anything else significant that you want to talk about, we will. Otherwise, I would going to go to the job above that. Do you see that, also in New York, as the executive assistant production coordinator?
MR. STEEL: And you transitioned from one job to the next and you worked about nine months -- excuse me -- about just under two years, is that true?
MR. STEEL: And there, you acted as an in-house personal assistant to the executive?
MR. STEEL: And then you took another job from June of 2008 until September 2009, fair?
MR. STEEL: And you provided, in the first bullet point, round-the-clock support, all personal and professional needs, true?
MR. STEEL: And then toward the bottom, the third bullet point from the bottom, you kept the inventory of all personal possessions and documentation, including passports, driver's licenses, etc., right?
MR. STEEL: And if people went on a vacation or a trip and there were passports involved at that job, did you put all of the -- not you, but were all of the passports collected as one so they were in somebody's charge?
MIA: I -- I don't exactly remember, but I didn't travel, like I did... So I would have given them their passports. I don't really remember the exact process, it was so long ago.
MR. STEEL: When you worked with Mr. Combs' company, is it true that you did travel internationally at times?
MR. STEEL: And other people traveled as well?
MR. STEEL: And were all the passports collected by one person to be in charge to make sure everyone's passport is not misplaced?
MR. STEEL: And when you said earlier on your testimony that you couldn't leave, do you remember that testimony, that your passport was being held or housed with Mr. Combs; do you remember that testimony?
MR. STEEL: That's everyone's passport was being held or housed with the same person, right?
MR. STEEL: Now, with regards to the very last bullet point in that first job experience, supervise other assistants and manage interviewing process. Do you see that?
MR. STEEL: You have -- you have a personality that you are strong, is that fair to say? I would like you to describe yourself. Is that fair to say?
MS. SMYSER: Objection.
THE COURT: I think you need to be a little bit more specific as to what you're asking.
MR. STEEL: You can understand and take on responsibility, true?
MR. STEEL: And you can kind of govern other people? I don't mean that in a poor way. I mean, you can kind of explain what you need to do and have other people follow your instruction when needed, true?
MR. STEEL: And you're a leader; wouldn't you consider yourself a leader?
MR. STEEL: You speak up for yourself, true?
MR. STEEL: You tell other people and you empower other people, is that true?
MR. STEEL: You try to encourage other people, right?
MR. STEEL: To be powerful and speak up for what's right, right?
MR. STEEL: Now, on the professional skills, do you see that, at the very bottom of 1753R, do you see what's highlighted?
MR. STEEL: Correct.
MR. STEEL: And you speak at least four languages that you can converse in, true?
MR. STEEL: OK. And you also, as you say, you multitask under pressure, right?
MR. STEEL: You're a positive, energetic person, right?
MR. STEEL: And you used that approach in your business, right?
MR. STEEL: And you have a thick skin?
MR. STEEL: And that's what you wrote on your resume, right?
MR. STEEL: And on the second line, you're accustomed to and comfortable in a 24/7 role, right?
MR. STEEL: OK. You can take this down if you don't mind. Your Honor, can we pass out to binder if, with the court's permission?
THE COURT: You may. These are the same binders from Friday, is that correct?
MR. STEEL: I'm being told yes. I think they are added, though, aren't they? Can you look at it?
(Counsel confer)
MR. STEEL: Your Honor, there are photographs that were added. I'll get the exhibit numbers.
THE COURT: Well, if there are additions to the binder, then you need to provide Ms. Smyser with a copy so that they can review them in advance.
MR. STEEL: She has them. They are in the binder now. It's from this morning. They are added.
MS. SMYSER: Your Honor, I would like to see the binder. And also, I would like the jury to be instructed not to turn to tabs without being instructed to do so.
THE COURT: The second instruction I will give, but let's do this in steps. Mr. Steel, provide Ms. Smyser a copy of the binder so she can quickly look at it and ensure there is no issue. So, do you have a binder? Grab one. Give it to Ms. Smyser. She'll take a look and we'll make sure there is no issue.
MS. SMYSER: Your Honor, it's fine to go to the jury, as long as they don't turn to tabs.
THE COURT: Members of the jury, these are the binders from last week. There are tabs in the binders. Don't look at anything in these binders, unless we tell you to, just because there is some exhibits that haven't been entered into evidence yet. And this is just to make it easier for you to look at them. Mr. Steel, you can hand out the binders now.
MR. STEEL: Thank you, your Honor. Could we pass them to the courtroom deputy to hand them to the jury.
THE COURT: Just start handing them over and we'll -- that's probably the easiest way to do it.
MR. STEEL: Directly to the jury?
THE COURT: You can hand it directly to the jury. All right. Does everyone have a binder now? Who needs a binder? OK. We need one more binder. If we're missing a binder, we'll share. OK. We've got enough binders. There you go. Teamwork is good. Thank you for your cooperation, everybody. With that, Mr. Steel, let's proceed.
MR. STEEL: Your Honor, may I approach?
THE COURT: Yes.
MR. STEEL: The courtroom deputy for the witness.
THE COURT: Yes. You can just hand it up.
MR. STEEL: May I come forward?
THE COURT: Please approach. Why don't you lay the binder down on the podium.
THE COURT: All right. Thank you very much.
BY MR. STEEL:
MR. STEEL: You can turn -- excuse me, your Honor. OK. If you can please do me a favor. When you get the binder in front of you, if you could please turn to 1730. We're going to take three in a row, 1731, 1732 and 1733. But let's go one at a time. Behind the tab starting at 31, if you don't mind looking at that. Behind tab 1730, rather. Tell me if you recognize what is depicted as your text message in 1730?
MR. STEEL: Yes, if you don't mind.
MR. STEEL: Is it true and accurate?
MR. STEEL: Can you look at what's behind tab 31, which is 1731. It's going to be the same question. Do you recognize this text message sequence?
MR. STEEL: And does it look true and accurate, to the best of your knowledge?
MR. STEEL: Can you look at what's behind 17 -- excuse me -- what's behind exhibit tab 32, but it's 1732. It's going to be the same question. Do you recognize this text message exchange?
MR. STEEL: Would you do me the courtesy, go to the next tab, which is 33, can you look at 1733 exhibit and tell me -- it's a couple of pages. Just tell me, again, if it looks like your text exchange, message exchange?
MR. STEEL: And that's in 1733, I believe, correct?
MR. STEEL: Your Honor, I move for the admission of 1730, 1731, 1732, 1733. And then, your Honor, the corresponding R, which would be 1730R, 31R, 1732R, 1733R, as well, and the ones without R under seal.
THE COURT: All right. Any objection other than those previously addressed by the court?
MS. SMYSER: No additional objections.
THE COURT: So those exhibits will be admitted on that basis, with the redacted exhibits admitted and the other exhibits admitted under seal.
(Defendant's Exhibits DX 1730, 1731, 1732, 1733 (Sealed) received in evidence)
(Defendant's Exhibits DX 1730R, 1731R, 1732R, 1733R received in evidence)
MR. STEEL: Your Honor, can we turn to 1733, if you don't mind.
THE COURT: Yes. You would like the jury now to turn to that exhibit?
MR. STEEL: With the court's permission.
THE COURT: Of course.
BY MR. STEEL:
MR. STEEL: Mia, it's on your screen, but also you have it in your booklet as well. Make sure you're at 1733.
MR. STEEL: And just to orient the jury, you left Mr. Combs employ by March 2017, fair to say?
MR. STEEL: And this is -- well, this is a text message exchange between you and Mr. Combs, is that true?
MR. STEEL: All right. I would like you to help me out if you don't mind. We're talking about, if you could look at it, the first blue text exchange on the left-hand side. This is Christmas of 2018. Do you see that?
MR. STEEL: All right. And tell the ladies and gentlemen of the jury what you wrote to Mr. Combs.
MR. STEEL: And then Mr. Combs responded to you, Same to you?
MR. STEEL: And that was two days later, is that fair to say?
MR. STEEL: And then on the next page.
MR. STEEL: That's you to Mr. Combs, fair?
MR. STEEL: And that's a couple days later. So we're talking about New Year's Eve 2018 going into the new year of 2019, true?
MR. STEEL: And these are your sentences to Mr. Combs, right?
MR. STEEL: And he's not with your -- or you're not with his employ, right?
MR. STEEL: And you don't see him anymore?
MR. STEEL: OK.
MR. STEEL: All right. And you reached out wishing, you know, nicely, Merry Christmas, Happy New Year, fair?
MR. STEEL: And then on the next chat is 1/15, so it's January 15 in the New Year, 2019, fair to say?
MR. STEEL: And can you read to the jury what you wrote to Mr. Combs?
MIA: Just thinking of you today and every day. Also no lie, last night I had a nightmare I was trapped in an elevator with R Kelly and I screamed for you and you came to rescue me. So thank you for that too. Sending you love.
MR. STEEL: Now, at that time in 2019, you had -- you wrote that you had a nightmare concerning the person, the artist known as R Kelly, right?
MR. STEEL: And the person who sexually assaulted you in your dream, or nightmare rather, came to your rescue; that's what you wrote?
MR. STEEL: And you not only had that vision in your mind, but then you express it to Mr. Combs?
MR. STEEL: You had to tell him that in the text message that he's your actual savior, right?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MR. STEEL: So the person who you told the ladies and gentlemen of the jury terrorized you and caused you PTSD, you wrote to that person and explained how that person saved you from the other person named there, right?
MS. SMYSER: Objection.
THE COURT: Sustained. Needs to be rephrased.
MR. STEEL: Let's go to the next text message that you sent to Mr. Combs. And just to orient, would you agree with me, this is March 8, 2019, so approximately -- I know it's not perfect -- but approximately just a week short of two months after the nightmare R Kelly text, is that fair?
MR. STEEL: All right. Can you read this to the jury what you wrote to Mr. Combs?
MR. STEEL: With a what type of emoji?
(Continued on next page)
BY MR. STEEL:
MR. STEEL: And you were not under the grip of Mr. Combs at that time, right?
MR. STEEL: Why?
MIA: Psychologically, also Puff used to be my protector. Also, these were based around after tragic events that happened in his life. And, again, I don't know how to explain the psychology behind it.
MR. STEEL: Why can't you explain your thoughts? You keep relying, it seems, like on psychology. What about what you would do?
MS. SMYSER: Objection.
MR. STEEL: Okay. I'll rephrase it right now.
THE COURT: Okay.
MR. STEEL: Thank you.
BY MR. STEEL:
MR. STEEL: Explain to the jury, if you can, why are you reaching out to Mr. Combs telling him this --
MR. STEEL: -- I'm sorry, with all the love in the world, heart emoji, when you had nothing to do with him?
MIA: Because he had just -- there were -- because Kim had just passed away, and I felt horrible for him.
MR. STEEL: Ma'am, that tragedy occurred — that death, that unexpected death — occurred five months earlier.
MS. SMYSER: Objection.
THE COURT: That was a statement. So, do you have a question?
BY MR. STEEL:
MR. STEEL: Is that true?
MR. STEEL: So you go to, the person who has terrorized you, the funeral of his significant other mother of his children, in November of 2018, right?
MR. STEEL: But it's five months later, and you are having thoughts that he's your savior, and you just reached out unilaterally --
MS. SMYSER: Objection.
MR. STEEL: -- to send you all the love in the world?
THE COURT: We've got to finish the question, and then we'll get an objection. That question does need to be rephrased, Mr. Steel.
BY MR. STEEL:
MR. STEEL: Can you explain, besides just saying psychology, why you are reaching out to Mr. Combs when you painted this picture for the jury how he has ruined your life?
MS. SMYSER: Objection.
THE COURT: That's overruled.
MIA: Why was I reaching out? Because I don't believe five months is really that long to get over -- I feel that's a lifelong tragedy to recover from. And these were specific dates. I don't remember why, that something would have happened, for me to reach out. The version of Puff that did treat me like the best friend, I did love that dude. He protected me from the other versions of themselves. And I didn't understand what happened to me until these -- until recently, as he was still being praised by everybody in the world. So how would I have known?
MR. STEEL: You know because you told the jury that Mr. Combs suffocated you?
MS. SMYSER: Objection.
THE COURT: It's overruled.
BY MR. STEEL:
MR. STEEL: You know -- you're saying I didn't know -- I don't know, actually; I don't want to speak for you. What didn't you know? What didn't you understand, according to your testimony, that Mr. Combs was brutal to you, according to you? How did that not make sense until more recently?
MS. SMYSER: Objection; it's argumentative, your Honor.
THE COURT: It's overruled.
BY MR. STEEL:
MR. STEEL: Okay. Let's --
THE COURT: Mr. Steel, let's have a very brief sidebar.
(Continued on next page)
(At sidebar)
THE COURT: So, these questions need to be cleaned up because you're drawing valid form objections to these questions, and so you're going to keep drawing them, and then I'm going to have to keep telling you to rephrase the question. So just be mindful of that, because I understand the line of questioning and why the defense believes it's relevant. However, there are some times where there are statements, there are other times when there are multiple questions, and the witness is having a hard time following what you are exactly asking her. So if you can just clean it up a little bit, then you can proceed very swiftly through this, and move to the next topic.
MR. STEEL: Thank you.
THE COURT: All right.
MR. STEEL: Can we step back?
(Continued on next page)
(In open court)
BY MR. STEEL:
MR. STEEL: Do you see on the next page, 7 of 12 of this exhibit --
MR. STEEL: -- can you see it's March 8th of 2019? Is that true?
MR. STEEL: And that's the same date as the last text message you sent to Mr. Combs, just sending you all the love in the world heart emoji, right?
MR. STEEL: Can you read to the jurors what you wrote to Mr. Combs on the same date?
MIA: Speaking of, you should watch Love on Netflix. Judd Apatow created it. It's superbad-esque funny.
MR. STEEL: The next post you made is the 15th day of December, 2019 — when I say post, text message to Mr. Combs — is that true?
MR. STEEL: And can you tell the ladies and gentlemen of the jury what you wrote?
MR. STEEL: With a heart emoji?
MR. STEEL: Just reaching out to Mr. Combs, right?
MR. STEEL: Say again?
MR. STEEL: And then the next page, which should be 1733, the fourth page, do you see it's New Year's Eve, December 31, 2019?
MR. STEEL: And you sent to Mr. Combs that attachment; is that true?
MIA: That's true. Someone was sending it to me over and over again asking me to forward it to him, so I did. It was for children with cancer.
MR. STEEL: The next reach-out you made to Mr. Combs was on the same day, New Year's Eve, right? Or, actually, that's just the metadata. Going to the next page, which is page 5 of this exhibit --
MR. STEEL: It should be on your screen, on the top.
MR. STEEL: May 14, 2020 now, right?
MR. STEEL: So you had been gone from Mr. Combs' employment for three years, just three years and two months, approximately, true?
MR. STEEL: And you texted Mr. Combs on May 14, 2020?
MR. STEEL: Can you read it to the jury?
MIA: Puff, my heart is broken about Dre, and I have spent all week praying and crying for you as well. I hope you know I love you so much, and I will always be here for you in every capacity. I was fortunate enough to have Dre in my life because of you, and in my spirituality, I know when people are done with the physical world, it is because they are finished with their mission of teachings to who is supposed to pass it along. You are one of the most influential people on the planet — a master — and he will live on through you forever, to continue on his message. I know this is excruciating, and, again, it might be small, but I will always be there for you. I love you.
MR. STEEL: The next one is August 29, 2020. Do you see that?
MR. STEEL: And what did you write to Mr. Combs?
MR. STEEL: Tell the ladies and gentlemen what that's about.
MIA: Chad Boseman passed away, and we had done this -- I don't know how to explain it. He was auditioning for this role for the James Brown movie that Chad Boseman got, and, essentially, he put on his own production that was -- or we put on his own production for, like, a week, and it was really intense. Yeah, that's it.
MR. STEEL: And Mr. Combs responded to you: How are you, with a question mark. Yeah, life is crazy. Is that true the same day?
MR. STEEL: And then Mr. Combs responds to you the same day, the next page: Who has that tape? I need a copy. Laugh out loud, or LOL. SHI was fun. Do you see that?
MR. STEEL: Do you know what he's talking about?
MR. STEEL: Can you tell the ladies and gentlemen of the jury?
MR. STEEL: What did you respond on the same day?
MIA: I was just going through my computer this week randomly, and I have so many videos, things I thought I lost. I'll buy a hard drive and toss them over and mail it to you.
MR. STEEL: So, when you say that you were going through your computer, your videos, we live in an age, and you specifically when you were with Mr. Combs lived in an age, that things were recorded, true?
MR. STEEL: And you used to, in fact, carry around like a little video recorder with you at times, right?
MIA: He required me to carry around a flip cam before he had full-time videographers back in whatever technology era that was pre-iPhones, correct.
MR. STEEL: And you knew how to use it, right?
MR. STEEL: And you used it, right?
MR. STEEL: And you would save the data or the visual or the audio, fair?
MR. STEEL: And you would also do that with -- like everyone can with their iPhones, right, or whatever type of phone they choose, once it had cameras and videos, right?
MR. STEEL: You had capability of carrying around your phone with you, right? You had a cell phone?
MR. STEEL: And it could record, right?
MR. STEEL: So my question is: Do you have any recording of Mr. Combs berating you?
MS. SMYSER: Objection.
THE COURT: Overruled.
MIA: No. I would not have been allowed to film that. I was filming whatever he wanted me to film.
BY MR. STEEL:
MR. STEEL: But did you ever just put on your iPhone recorder to capture Mr. Combs in a moment of rage, like you described to the jury?
MR. STEEL: Do you have any text message that you sent to a friend or family member of what was going on, according to you, that Mr. Combs was somehow berating you, being violent to you, humiliating you? Do you have anything like that?
MS. SMYSER: Objection.
THE COURT: Overruled.
MIA: I would -- like I said before, I never told anybody outside, and I -- I never would have -- no, that would have been a huge break of trust, loyalty, and confidentiality.
BY MR. STEEL:
MR. STEEL: How about getting out the truth, though, preserving the truth? My question is: Do you have any of those in a text message form?
MR. STEEL: Well, we'll -- what was the text message?
MR. STEEL: I'm sorry, I didn't mean to interrupt you.
MR. STEEL: Are you done?
MR. STEEL: My question is different. Do you have anything where you contemporaneously wrote to a friend, a family member, police officer, anybody, and said this is what's going on, I'm being assaulted, berated, anything?
MIA: No. I -- the only time I reached out for help was very subtly to people in the office, but not disclosing things that other people hadn't witnessed. No, I would never.
MR. STEEL: All of these messages are positive; would you agree with me?
MR. STEEL: Showing almost a loving relationship from you to Mr. Combs, true?
MR. STEEL: Let's look at the next -- it's August 29, 2020. Do you see that?
MR. STEEL: Yes. 2020.
MR. STEEL: At the bottom of that screen?
MR. STEEL: Can you read to the jurors what you wrote to Mr. Combs?
MR. STEEL: Just go a little slower.
MR. STEEL: Thank you.
MIA: Life is fucking insane, and, supposedly, it all happens for a reason, in order to elevate us in our human experience, but it's rough. I've been tapping into spirituality a lot lately, and it really makes shit make sense. I've also been thinking about you so much and feeling your pain. And just so you know, I love you with all my heart, and I'm still here for you forever. We have so many hilarious ass memories and stories. OMGGGG. I'll send you the videos and even random notes I have in my phone titled like, quote-unquote, funny shit, Puff said.
MR. STEEL: Do you have any random notes in your phone talking about being brutalized by Mr. Combs?
MS. SMYSER: Objection.
THE COURT: It's overruled.
BY MR. STEEL:
MR. STEEL: How would we find out?
MS. SMYSER: Objection.
THE COURT: Sustained.
BY MR. STEEL:
MR. STEEL: Did you ever produce any random notes showing that Mr. Combs was anything but professional with you?
MS. SMYSER: Objection.
THE COURT: Sustained.
BY MR. STEEL:
MR. STEEL: Do you have any notes that you made showing anything that Mr. Combs was nothing but professional?
MS. SMYSER: Objection.
THE COURT: That needs to be rephrased.
BY MR. STEEL:
MR. STEEL: Do you have any notes, like you did here, like you memorialized here in this text message, that Mr. Combs was violent towards you?
MIA: I don't know. I don't think so. I would never have -- I don't think so. I mean, Puff used to make me follow him around and write down all the funny stuff he said that day. That's why I have stuff like that.
MR. STEEL: Mia, didn't you have time away from Mr. Combs where you could write a note to yourself — today, he sexually assaulted me, God forbid?
MS. SMYSER: Objection.
THE COURT: Overruled.
BY MR. STEEL:
MR. STEEL: Of course that's my question.
MR. STEEL: Mr. Combs responds to you -- I'm going on the next series of the same conversation, if you don't mind, and it's on page 7 of 1733, 1733R. This is Mr. Combs responding to you on the same date, correct? It's 8/29, which is August 29, 2020?
MR. STEEL: And he wrote to you: I love it. Glad you're well. Love, with a period. Please send me all of the footage. Cause we're working on our doc. And know that I only remember the good times. Love you. Want you to know that. You see that?
MR. STEEL: And what's the doc?
MR. STEEL: A documentary, does that sound right?
MR. STEEL: And Mr. Combs let you go from your employment, right?
MR. STEEL: You were separated from your employment, fair?
MIA: Yeah, I got a notification, and, once again, I took it as such, but then I was called back, so it was very confusing, but, yes, I was no longer working there.
MR. STEEL: But he says he'll only remember the good times. You see that?
MR. STEEL: Now, did you respond to him: You know, it's 2020. The #MeToo movement has been strong for approximately two and a half years, and you should remember what you did to me? Did you say that?
MS. SMYSER: Objection.
THE COURT: Mr. Steel, can you rephrase the question?
MR. STEEL: Yes.
BY MR. STEEL:
MR. STEEL: When Mr. Combs wrote to you, I only remember the good times, why didn't you respond, well, I remember the bad times?
MIA: Sorry. Why didn't I say that? Because that would have -- I would have never responded that way.
MR. STEEL: Because it's not true; is that true, Mia?
MS. SMYSER: Objection.
THE COURT: Overruled.
BY MR. STEEL:
MR. STEEL: Your testimony and statements that it was -- you were the victim at the hands of Mr. Combs' brutality and sexual assaults is not true, is it?
MIA: I have never lied in this courtroom, and I never will lie in this courtroom. Everything I've said is true.
MR. STEEL: Let's see what you wrote in response to Mr. Combs. This is, again, just to orient the jurors. It's August 29, 2020, and you're responding at 8:42, but it's minus seven UTC time. So, can you read what you wrote to Mr. Combs in response to his writing to you, send me all the footage, and we're working on our documentary, I only remember the good times, love you, want you to know that.
MR. STEEL: Can you just go slower?
MIA: Oh, sorry. Love you, too. And the only things to remember are the good times, and those are the only memories I have!! Ha ha ha, like fucking hysterical ones! I'll send you everything I've got! I remember even before you had videographers with us, I carried around the little iVid thing. I found those, too. Completely forgot about them. So many magical hilarious things, like drinking 1942 on the Parrot Cay Beach and champagne under the Eiffel Tower at 4:00 a.m. in the dark; and singing with Jimmy at Interscope; and Mick Jagger trying to take me home, but I ran away; and Ibiza caves, where I got a seven-inch scar; and Hawaii 5.0, when you punched that dick fuck for talking shit to me; and launching Revolt; and that random underground Baccarat game where Jlolo wouldn't pay out and I stayed only, and you won 650 grand, and that little prick ran away from me, and Leo grabbed my pink bedazzled BlackBerry, and you said that Titanic mother fucker doesn't know shit. He won 10K, I won 650K. Ha ha ha. Gosh, there are trillions of stories that are amazing. Of course I'll send it to you. And also...what documentary without me?? I will say I reflect back, and I know I did really fucking great with Can't Stop Won't Stop. I was just bamboozled by Heather because I didn't realize how shitty people could be, and I believed everyone was good. But you taught me so much, and I appreciate that! But I have all of your doc stuff — remember the scrapbook I made you of every time you had ever been mentioned in the press from day one until ultimate fame? Just thought about that — I've got you.
MR. STEEL: When you said in this message to -- communication to Mr. Combs — it's in the fifth line up from the bottom, starting in the center — I was bamboozled by Heather because I didn't realize how s-h-i-t-t-y people could be, and I believed everyone was good -- you see that?
MR. STEEL: -- why didn't you say, and, Mr. Combs, you bamboozled me as well?
MR. STEEL: Who brainwashed you, Mia?
MR. STEEL: How did he brainwash you into thinking that it's okay to be woken up from your slumber with a man's private part being inserted into your person without permission?
MS. SMYSER: Objection.
THE COURT: Sustained.
BY MR. STEEL:
MR. STEEL: How did he bamboozle you to believe it was okay when you were orienting different items in a closet?
MS. SMYSER: Objection, your Honor.
THE COURT: That's sustained.
BY MR. STEEL:
MR. STEEL: How did he bam -- why didn't you write how he — how he — was one of the people that caused you to believe that not everyone was good?
MR. STEEL: That's your answer?
MS. SMYSER: Objection.
THE COURT: That's sustained.
BY MR. STEEL:
MR. STEEL: What does brainwashed mean?
MS. SMYSER: Objection.
THE COURT: That's overruled.
MIA: Brainwashed meant I was in an environment where the highs were really high and the lows were really low, which created a huge confusion in me trusting my instincts. I was punished whenever Puff would be violent or -- and I would react, therefore, again, confusing me and making me believe I had done something wrong, and then I would try so hard to get back to that good space. And I'd work harder and be nicer, and nobody around batted an eye. He was still praised by everyone around him and the public. Again, I felt like I had done something horrifically -- like I had betrayed him in some way by going to mediation, and I felt horrible about it, like, again, I had done something wrong. And I was always constantly seeking his approval. He was my authority figure, the only authority figure.
THE COURT: Mr. Steel?
MR. STEEL: Are you finished?
MR. STEEL: You had not been with Mr. Combs on the date that you wrote this text message for approximately three years and five months. Do you realize that?
MR. STEEL: And it is also approximately three years after you told the jurors that the #MeToo movement went viral, right?
MR. STEEL: October 15, 2017, and this is August 29, 2020, so just under, two months shy, of the #MeToo movement going viral, according to what you said, right?
MS. SMYSER: Objection.
THE COURT: That's overruled. I think you can rephrase that question, Mr. Steel. Sorry, sustained. Rephrase.
BY MR. STEEL:
MR. STEEL: You were aware of the #MeToo movement for years by August 29, 2020, right?
MR. STEEL: Well, what does that mean?
MR. STEEL: I can't understand -- can you elaborate more? For you?
THE COURT: No, hold on. Mr. Steel, why don't you ask a new question and rephrase it in a way that the witness can understand. Thank you.
BY MR. STEEL:
MR. STEEL: My question to you is: You were aware of the #MeToo movement for years by this time that you wrote this?
MS. SMYSER: Objection.
THE COURT: That's overruled.
BY MR. STEEL:
MR. STEEL: Isn't that true?
MR. STEEL: Yes. By August 29th of 2020, you were already aware, for years, of the #MeToo movement, right?
MR. STEEL: And you told the ladies and gentlemen of the jury one of the reasons you did not outcry earlier was because there was no #MeToo movement around when you worked for Mr. Combs, right?
MS. SMYSER: Objection.
THE COURT: Overruled.
MIA: I was saying back then there was no #MeToo movement, there was no social media, there was no mental health awareness -- sorry, social media as though it is today. Every adult that I reached out to within this organization or the people that witnessed what happened to me, nobody acted like what was happening to me was wrong. And his threats about that he was going to tell Cassie what happened made me internalize, blame, and shame.
MR. STEEL: All right. Let's talk about that for a minute. Who threatened to tell Ms. Ventura about Mr. Combs supposedly sexually assaulting you?
MR. STEEL: So your testimony before this jury is that Mr. Combs told you — threatened you is your word — that, hey, I have a mind to tell Ms. Ventura that I sexually assault you?
MS. SMYSER: Objection.
THE COURT: It's overruled.
BY MR. STEEL:
MR. STEEL: I can't hear you.
MR. STEEL: No, no.
THE COURT: No, Mia, you finish your answer, and then Mr. Steel will get the next question.
MIA: The words that you used were not his words, but he threatened to tell Cassie, quote-unquote, everything, which made me feel like I had done something wrong. I don't know how to explain what that does to a person.
BY MR. STEEL:
MR. STEEL: Are you finished?
MR. STEEL: Why didn't you respond by saying, great, let's tell everyone what happened when you violated me?
MS. SMYSER: Objection.
THE COURT: Sustained.
BY MR. STEEL:
MR. STEEL: Why didn't you respond by saying, absolutely, tell Ms. Ventura and everyone else, that would be great?
MS. SMYSER: Objection.
THE COURT: That's sustained, and let's move on.
BY MR. STEEL:
MR. STEEL: By 2020, August 29th, you knew, according to you what you said earlier on direct examination, that you have a moral obligation to speak up. Do you remember saying that to the jury?
MS. SMYSER: Objection.
THE COURT: That's overruled.
BY MR. STEEL:
MR. STEEL: Why didn't this moral obligation happen in 2017?
MR. STEEL: Didn't it?
MR. STEEL: Yes. Why didn't you have the moral obligation to say, this is my experience with Mr. Combs?
MR. STEEL: Why in 2018 didn't you have the moral obligation to come forward and make these allegations against Mr. Combs, that he had sexually abused you?
MS. SMYSER: Objection.
THE COURT: It's overruled.
BY MR. STEEL:
MR. STEEL: Why in 2019? It's the same question.
THE COURT: That's sustained. Next question.
MR. STEEL: When did the moral obligation come to your mind that you need to say this information that you are putting forth, that Mr. Combs violated you in a sexual manner and other ways?
MIA: When I started witnessing him being held accountable for his actions and being told what happened to me was wrong.
MR. STEEL: When was that?
MIA: When -- it began, I guess, when it all came out in the media and he was being held responsible.
MR. STEEL: That's when you first said me too?
MIA: No, that's not the first moment I did. It's been a long process. Again, I'm still untangling these things. I'm in therapy. Like, there's a lot of support I've been given that I didn't have or know what to do with before.
MR. STEEL: Mr. Combs responds to you, on the bottom of that page, 1733, page 7, same date, August 29, 2020, 9:02 minus 7 for UTC time: I gotta find that. You got a copy. You see that?
MR. STEEL: You know what that's referring to?
MIA: I don't remember what I just wrote in the text... I'm guessing he means the James Brown or any of these videos.
MR. STEEL: How about the scrapbook that the ladies and gentlemen of the jury saw?
MIA: I didn't think that was -- or maybe it was. I'm not sure. I got to find that. You got a copy in this page I'm just glancing at? I'm trying to interpret. I'm not sure. I guess so.
MR. STEEL: Let's go to page 8 of 1733. And you respond, August 29, 2020?
MR. STEEL: Can you read to the ladies and gentlemen of the jury what you wrote to Mr. Combs?
MIA: I think I have PDFs of everything somewhere that will take me a minute to organize — I think I gave it to you for a Bday at your house on Mapleton.
MR. STEEL: Mia, I don't mean to interrupt. Can you just read slower?
MIA: Sure. I think I have PDFs of everything somewhere that will take me a minute to organize — I think I gave it to you for a Bday at your house on Mapleton if that helps locate it? Also remember, I customized that purple leather suit a~la Eddie Murphy so you could walk down Sunset Boulevard not giving an F. If y'all can't find it, I'll put it together again.
MR. STEEL: And you're talking about the scrapbook, right?
MR. STEEL: You don't believe you did what?
MR. STEEL: That's fine. But you're clearly speaking about the scrapbook birthday present?
MR. STEEL: And that's the one that the ladies and gentlemen of the jury were shown that you prepared, right?
MR. STEEL: And you kept, potentially, a PDF of them, right?
MIA: I just saw it probably in my email somewhere because I forwarded things that were sent to me to, like, be able to organize. I just assumed I probably had it somewhere in an email or on a drive somewhere.
MR. STEEL: Mia, if you're able to forward things to you while working for Mr. Combs, why didn't you forward any proof that you were in any way violated?
MS. SMYSER: Objection.
THE COURT: Sustained.
BY MR. STEEL:
MR. STEEL: Mr. Combs wrote back to you at the bottom of that exhibit: Thanks. I'ma look also. Do you see that?
MR. STEEL: And that was two days later, just for the record, true?
MR. STEEL: I'd like you to go to tab, which is 30, but it's 1730 is the exhibit.
MR. STEEL: And, your Honor, with the Court's permission, may this be displayed as 1730R, but you've already admitted it, for the sealed record, 1730 as well.
THE COURT: All right. You may proceed.
BY MR. STEEL:
MR. STEEL: Now, Mia, this is April 25 of 2019; fair to say?
MR. STEEL: And it's 1:10 in the morning, so it's an hour after midnight, right?
MR. STEEL: Okay. And this is written to Mr. Combs by you, right?
MR. STEEL: Can you please read this to the jury?
MIA: Hey, Puff. Heart emoji. Thinking about you forever and as always. Just wanted to send you the biggest gust of love and happiness and thankfulness for coming to my hometown and changing the dynamic of what happens here during, quote-unquote, beach week and, instead, making it a festival of love and togetherness. I can't explain to you how much all thousands of my friends are so excited for this weekend and how the conversation has already changed into positivity. Unfortunately, I just found out today that my grandma went into hospice and has maybe a day or two to live, so I just booked a flight out at 5:00 a.m. to hug her goodbye. Otherwise I would be here and witness y'all make history. Heart emoji. Love you so much and thank you for this historic moment. Can't believe after almost a decade with y'all. I miss this beautiful combination of all the people I love that I grew up with and the people I love that helped me grow up (y'all.) But as they say, c'est la vie. Now go and do as you do best and fucking crush it and make history, heart emoji, heart emoji, heart emoji, heart emoji.
MR. STEEL: And this -- sorry about your -- deepest sympathies about your grandma.
MR. STEEL: This beach week, can you explain that to the jury, what you're talking about?
MIA: I'm from Virginia Beach. They had a week called beach week that I believe there was some horrible things that police had done historically to Black people. Pharrell decided to start have a festival there — we had never had a festival like that — to shift the conversation around beach week, which I guess is a spring break for colleges, maybe. And so everybody that I grew up with was going, and, yeah, Puff was in the lineup.
MR. STEEL: And you explained that Mr. Combs' presence already makes this a positive environment. You see that?
MR. STEEL: And that he brings love and togetherness?
MR. STEEL: And you are disappointed that you won't be able to see him in person, right?
MR. STEEL: Well, isn't it true?
MR. STEEL: Why isn't that true?
MR. STEEL: I can't hear you.
MR. STEEL: Mia --
MR. STEEL: -- who made you write this text message to Mr. Combs?
MS. SMYSER: Objection.
THE COURT: It's overruled.
BY MR. STEEL:
MR. STEEL: Why would you lie in this text message that I wanted to see you, but you really didn't want to see Mr. Combs?
MIA: Because I didn't want to seem -- I don't know -- it provided me with, like, safety, I guess. I didn't want to let him know -- I had never said something direct and mean to him before in my life. I wasn't going to start.
MR. STEEL: Why write this at all if you didn't want to see Mr. Combs?
MIA: Because he was going to be in my hometown, which, again, doesn't get that sort of -- I believe that I would have been, like, almost expected to be there. That's all.
MR. STEEL: When did Mr. Combs ever expect you to be anywhere after you left his employ in March of 2017?
MS. SMYSER: Objection.
THE COURT: That's sustained.
BY MR. STEEL:
MR. STEEL: Would you agree with me that all of these messages that the jurors have heard that you authored, everything is positive and loving from you to Mr. Combs? Would you agree with that?
MR. STEEL: Let's look at it is behind your tab 31, but it's Exhibit 1731. With the Court's permission, it will come up on your screen. Do you see that?
MR. STEEL: And FB, do you know what FB -- Frank Black?
MR. STEEL: That's Mr. Combs; is that fair to say?
MR. STEEL: I'm sorry, I didn't mean to interrupt you. Were you saying something?
MIA: No, it's just, like, I don't memorize phone numbers, but if you said FB is Frank Black, yeah.
MR. STEEL: Can you read to the jury what you wrote? And just to orient everyone, this is now July 30th of 2022, correct?
MR. STEEL: And what did you write to Mr. Combs?
MR. STEEL: And doc, again, is the same thing, documentary?
MR. STEEL: All right. And then Mr. Combs says: Love, love, love, with an exclamation point?
MR. STEEL: And your response again?
MR. STEEL: Let's go to the next tab, which should be about 32, if you don't mind. That is Exhibit 1732 that will come up on the screen as 1732R, with the Court's permission, and this is, again, you and Mr. Combs in a conversation, or text conversation, true?
MR. STEEL: And this is December 28, 2022?
MR. STEEL: Can you read what you wrote to Mr. Combs?
MIA: Happy holidays. I hope it's filled with love and happiness and every dream you've ever had! Tell your family and crew I love them. Heart emoji XOXO.
MR. STEEL: And Mr. Combs wrote back: I'm great. Sending you life and love, true?
MR. STEEL: And you wrote?
MR. STEEL: Okay. Now, this is the person that you did not want to see in 2019, when coming to Virginia Beach to perform; that's what you're telling the jurors, right?
MR. STEEL: You just keep on this communication with this man who you are terrorized -- excuse my language --
MS. SMYSER: Objection.
MR. STEEL: -- terrified of, right?
THE COURT: Why don't we get a fresh question.
MR. STEEL: Okay.
BY MR. STEEL:
MR. STEEL: You're telling the jury that you can't see Mr. Combs, which you wrote in Exhibit No. 1730, is a lie, you did not wish to see him because you were scared of him, right?
MS. SMYSER: Objection.
THE COURT: That's sustained.
BY MR. STEEL:
MR. STEEL: Years later, you're still communicating with Mr. Combs, true?
MR. STEEL: Even though you're telling the jury that you couldn't -- didn't desire to see him because you were scared of him; is that true?
MS. SMYSER: Objection.
THE COURT: That's sustained. I think it needs to be rephrased.
BY MR. STEEL:
MR. STEEL: You hold your position, Mia, that you were scared to see Mr. Combs; is that true?
MR. STEEL: And when I say "your position," I'm referring to now year 2022. That's your position, right?
MS. SMYSER: Objection.
THE COURT: That's overruled.
BY MR. STEEL:
MR. STEEL: From 2019, when you told the jury that you were scared to see Mr. Combs, that same feeling is December 28, 2022, right?
MS. SMYSER: Objection.
THE COURT: That's overruled.
BY MR. STEEL:
MR. STEEL: That's the same position that you're maintaining throughout your time with Mr. Combs, right?
MS. SMYSER: Objection to the form, your Honor.
THE COURT: That's sustained.
BY MR. STEEL:
MR. STEEL: Is that how you felt the entire time that you were with Mr. Combs?
MR. STEEL: Being scared of him.
MR. STEEL: The way you felt the entire time of your relationship with Mr. Combs. That's my question.
MR. STEEL: Now, I'd like you to listen to, privately, with the Court's permission, Exhibit No. 1750. And tell me if you recognize this, and if it's accurate to what it depicts.
MR. STEEL: Your Honor, can a computer be handed up to the courtroom deputy?
THE COURT: It may.
MR. STEEL: And headphones?
(Pause)
THE COURT: All right, Mr. Steel.
MR. STEEL: Thank you, your Honor.
BY MR. STEEL:
MR. STEEL: Mia, do you recognize what you just listened to and watched that has been marked as Mr. Combs' 1750?
MR. STEEL: And is it true and accurate?
MR. STEEL: Your Honor, can I ask the Court to consider moving into evidence 1750, but then that's under seal, I understand, and then there's also 1750R.
THE COURT: Ms. Smyser?
MS. SMYSER: Your Honor, we would object. The proper basis for admission has not been established here.
THE COURT: Let's have a very brief sidebar.
(Continued on next page)
(At sidebar)
THE COURT: So you don't believe that this is -- that they've made the case that this goes to impeachment?
MS. SMYSER: Correct, your Honor.
THE COURT: What I heard, prior to us starting today, is that it goes to demeanor, meaning it shows a different demeanor than the witness has here on the stand. And, so, why wouldn't that be sufficient, at least for admissibility purposes, and then, obviously, you can address it on redirect?
MS. SMYSER: Speaking first to demeanor, your Honor, I think that the defense was speaking about her direct examination when she was looking down talking about the most traumatic things that had ever happened to her. She has been more direct in responding to questions. She has looked up and been more forceful when she's not talking about sexual assaults and violence that Mr. Combs committed against her. So I don't think there's any basis to impeach on her demeanor. And there's also no basis to impeach on her statement. She hasn't said she's scared -- she was scared of him at all times, for example. She's established this is how -- the defense has established this is how she talks to him, and these repeated text messages and social media posts, it's very cumulative, your Honor, at this point.
THE COURT: Well, I take your point on it being cumulative. So, let me hear the response on impeachment, and then why isn't this cumulative, given everything that we've seen, including even text messages that go into 2022, at this point?
MR. STEEL: Because this is a different type of means of her communication. As the Court may remember, she's extremely positive, energetic, forward, loving, and it's different than a written word and I thought you'd ruled on already this morning. It's the same objection. This is a totally different piece of evidence, and it's --
THE COURT: Other than putting the video in, what questions are you --
MR. STEEL: I'm going to say this is accurate. I've already established that.
THE COURT: And you are going to establish the date on the video?
MR. STEEL: Of course, of course.
THE COURT: Why don't you establish the date on the video, and then it can be admitted.
MR. STEEL: Thank you.
MS. SMYSER: Your Honor, she's established that she's positive and loving, and her tone, when she's spoken about these text messages on the stand, has been very bubbly. We don't think that they have shown that there's impeachment here.
THE COURT: Understood. The objection is overruled.
(Continued on next page)
(In open court)
BY MR. STEEL:
MR. STEEL: Do you remember --
THE COURT: One second.
(Pause)
THE COURT: Mr. Steel, why don't we finish up with this exhibit, and then we'll take a short break. Mr. Steel, you may proceed.
BY MR. STEEL:
MR. STEEL: Do you remember, in this exhibit, 1750, making this for Mr. Combs' 44th birthday?
MR. STEEL: And that date would have been November 4th of 2013, true?
MR. STEEL: Your Honor, I move for the admission of Mr. Combs' 1750 for, as I understand the rule, under seal, but then 1750R, as well.
THE COURT: It will be admitted on that basis.
(Defendant's Exhibits 1750 (Sealed) received in evidence)
(Defendant's Exhibits 1750R received in evidence)
MR. STEEL: Can we display, your Honor? Is that okay?
THE COURT: You may.
(Video played)
MR. STEEL: Thank you, your Honor.
THE COURT: All right. Mr. Steel, next question. Do you have anything else on this exhibit? Otherwise, we'll take a break.
MR. STEEL: What I told the Court, it's fine.
THE COURT: All right. Members of the jury, we're going to take a short break. We'll be back in ten minutes. So let's say 10:50 a.m. All rise for the jury.
(Continued on next page)
THE COURT: Thank you. We'll be back at 10:50.
(Recess)
(Continued on next page)
THE COURT: Let's come back.
MS. COMEY: Your Honor, I have one issue to raise before the witness comes back, if that's all right.
THE COURT: All right.
MS. COMEY: Thank you, your Honor. I wanted to expand our record on our 403 and, at this point, 611 objections to a number of questions and number of exhibits with respect to this witness. At this point, we have been objecting and we have had a number of those objections overruled to questions, to exhibits, and this morning, to turning over private correspondence of this victim to her abuser's attorneys. At this point, we have now sat through hours of a humiliating cross-examination for this witness, and I just wanted to put it on the record, because I don't know that the transcript will really do it justice, Mr. Steel has yelled at this witness, Mr. Steel has been sarcastic with this witness, Mr.
Steel has been argumentative with this witness by injecting his own views about her testimony, calling it her position, saying things like "God forbid" after repeating things that she has said on the stand, saying things that suggest to this jury that she is lying, that he believes that she is lying through his questioning, making statements instead of questions. And meanwhile, throughout that whole tone and approach to this cross, this witness is having to pick apart social media post, after social media post, after social media post, which individually, have virtually no probative value. And I understand that individually, your Honor has found that, one by one, looking at these in isolation, there is very minimal prejudice. But at this point, in the context of this cross- examination and the collective totality of all of these exhibits that have been allowed in, we are crossing the threshold into prejudice and into harassing and unduly embarrassing this witness under Rule 611.
That's the record that I wanted to make. In particular, the concern is that, given the tone of the questions, the number of exhibits that have nothing to do with her credibility and that are only cumulative, we don't think it's appropriate to allow this line of cross-examination with this victim, who has carried herself with remarkable dignity and grace throughout the cross-examination. I also wanted to note that, some of what your Honor has said, understandably, in making the rulings on one exhibit at a time and this morning in ruling that the victim would have to turn over her communications to defense counsel, is that there is no real apparent prejudice. I just wanted to note that, in addition to the prejudice of adding to the trauma of this victim having to testify at this trial, there is a broader prejudice that eyes are on this trial and victims in other cases are going to see how victims in this case are treated. And they are going to see what level of privacy, respect, and dignity they would get if they decided to testify. And so our concern is that, if this victim is not protected from further harassment, that it will deter other victims in other cases from saying, yes, I will testify and I will tell the truth. So I just wanted to make that record, your Honor. And it is with that background that we will be continuing to object to additional cumulative exhibits and additional argumentative questioning.
THE COURT: All right. Do you have an application at this time? I mean, look, I understand that you're making your record. I have not heard any yelling from Mr. Steel, and I have not heard anything that was sarcastic in the questions. To the extent that there were improper questions, the court has sustained numerous objections. My understanding when Mr. Steel says "God forbid," is that he's talking about things that the witness has said that are extreme in nature. And so he's saying "God forbid" as an apology to him having to repeat that and recollect that with the witness. That's my understanding of what he's saying. I didn't take that to be an effort to in any way intimidate or harass the witness. That being said, you raised the issue of the questions that are argumentative. And I think the problem, Mr. Steel, and this is something that -- Is Mr. Steel here? Yes. Here's the issue, that there are lines of questioning where if you had asked one question and moved on, that would be one thing. But you're repeating the same question multiple times, often with an improper form. Ms. Smyser has been objecting to those questions, so what we have is that you're repeatedly asking these questions that are -- where the tone, I agree with Ms. Comey, may be, you know, on the line, but the form is improper, so I sustained the objection. Then you keep asking these questions, and at a certain point, I'm going to think that you're doing that just to get the question out there so the jury can hear it. If I start to think that, I'll ask you to just move on, and you're not going to be able to ask questions on the topic you're raising. Do you understand?
MR. STEEL: Sure, yes.
THE COURT: Just to address the other things, you've heard Ms. Comey talk about any kind of yelling or sarcastic commentary. You heard what I said. But you should be mindful, looking forward, that we're not running into any of those issues. And there is no reason to do anything other than to just ask straightforward questions, get the answer, and then move on to the next topic. Right?
MR. STEEL: Yes, sir.
THE COURT: All right. Now, as to the people seeing how the witness is being treated, again, I don't see that this witness has been treated in any improper way at this point. But I'll ask the government, Ms. Smyser, you'll let the court know if there is any conduct that's offensive on those lines, and we'll take it from there. I hear the issue. I hear what you said, Ms. Comey, and we'll be watching from here on out. With that, let's have Mia back.
MR. STEEL: Your Honor, may I ask a question to speed up things?
THE COURT: Yes.
MR. STEEL: Let me just get to a microphone. So, your Honor, this morning I was alerted that there were photographs. I immediately, when I saw it and digested it, I texted the Assistant United States Attorney and I told her it would be for impeachment. They are now marked, given to the U.S. Attorney's office, and I would like to get into these photographs. There are -- it's a series of markings. 1799, but then it has a hyphen 1 through 25. I just want to give the court, I think it would be helpful for judicial economy, I understand that the court will rule on objections as they come, but can I just tell you my overall belief of why they are admissible. And it's as follows.
THE COURT: Can I see them?
MR. STEEL: Of course. Can you do it?
MS. COMEY: Your Honor, we don't have stamped versions of these with defense exhibit stickers.
THE COURT: Do you have the actual photographs.
MS. COMEY: We have the photographs. If you say a number, we won't know which photograph you're looking at.
THE COURT: Can whoever is putting this on the screen just show me, and let's turn off the screens otherwise. There's a series of these, Mr. Steel?
MR. STEEL: Correct, your Honor.
THE COURT: Let's go through them.
MR. STEEL: Do you mind if I just stand over there and see what is being shown to the court?
THE COURT: Yes.
MR. STEEL: Your Honor, what I believe this to be -- this is going to encompass the entire series.
THE COURT: Let me pause you for a second.
MR. STEEL: Yes, sir.
THE COURT: Are these within the binders that you gave to the jury?
MR. STEEL: No, they are not in the binders that we gave to the jury.
THE COURT: Why doesn't the government have a stamped copy of these?
MR. STEEL: I presume, for the reason I said. We were alerted to this, this morning. I immediately advised the prosecutor they had to be redacted and put an exhibit sticker on. And as soon as we did that, that should have been given to the prosecutor. Even before having the exhibit sticker and redacting, these should have been shared with the prosecutor.
THE COURT: All right. Let's just go through these quickly.
MR. STEEL: Can I speak, or do you just want to look at them?
THE COURT: I just want to look at them right now.
MR. STEEL: OK. Yes.
THE COURT: Let's go to the next one. Let's go next. Go next. Let's go next. Let's go next let's next. Let's go next. Keep going. Keep going. Keep going. Keep going. Keep going. Keep going. Keep going. Let's keep going. Keep going. Keep going. Just me a second with each one, and keep going, so I don't have to keep saying that to you. Mr. Steel, what's the proffer of any kind of relevance to this case?
MR. STEEL: I wanted to alert this honorable court, I've already told the prosecutor, this is for impeachment. The way my memory of last week, which would be Friday, I asked Mia whether she alerted any family member, friend, any other person. And her response was, as it was today, your Honor, I didn't have any time. I couldn't do that. I had no time to myself to do that. I asked her that again today. These images will show Mia I believe, as she identifies them, of course, with family and friends over a period from 20 -- approximately, I'm not looking at the exhibits -- 2012 throughout her entire stay with Mr. Combs' entity, which would be in 2017 March, as well as beyond, to show that she's still friends with these people. That is the overall reason. It is total impeachment. I wanted to share it with the government immediately, and I did it this morning right when I got it. That's what happened.
THE COURT: Why would you -- to the extent that you needed clarification on her response that she didn't have time, I don't think that's all she said. I think there were other parts to her answers as to why there wasn't any disclosure about the things you've been asking her about, both Friday and today. But even if you needed to probe into that, why would you need to put these into evidence? Why do the images of Mia having, you know, spending time with her friends and family and with people who are having baby showers and things of that, have any kind of relevance even to issues of impeachment?
MR. STEEL: Because she testified that she had no time away from Mr. Combs.
THE COURT: Yes. Just ask, if you want to ask a question along those lines, and just ask her, isn't it true that you spent time with friends and family throughout this time period? Isn't it true you posted things about these friends and family? Why do you have to show -- why do you have to put her actual posts into evidence?
MR. STEEL: Because I would like to do the impeachment that way. Because I think I already laid the foundation that she said that I can't speak with anybody else. There was no time.
THE COURT: OK. So what's the exhibit number?
MR. STEEL: Well, it starts with 1799, but has a hyphen, and it says 1 through 25, consecutive.
THE COURT: Absent any further showing, Exhibit 1799 is excluded. All right. Anything else?
MR. STEEL: Just my objection, your Honor.
THE COURT: All right.
MR. STEEL: Can we just move these in for the record, your Honor?
THE COURT: Move what in?
MR. STEEL: The photographs that the court just said it will not be admitted, just for the record.
THE COURT: No. That doesn't even make any sense. I mean, you want to lodge them with the court so that it will be reflected in the court record?
MR. STEEL: True.
THE COURT: That will not be done. That's not how we've been doing it as to any other exhibit excluded in this case, right?
MR. STEEL: I can't say right or wrong. I'm saying the court, if there is an appeal ...
(Counsel confer)
MS. SHAPIRO: We can still use it.
THE COURT: We'll handle it. We'll make sure everyone is aware of what those numbered exhibits are. I don't think there will be a dispute about that. If we need to take further action, we can do that. At this point, there nothing to move in, in terms of records.
MS. COMEY: Your Honor, if the defense just provides us marked copies, we will maintain it in a case file, which is what we do in every case, and if there is an appeal, we will have marked exhibits from both sides for the appeal record.
THE COURT: All right.
MR. STEEL: Your Honor, can I say something? I was just handed the transcript on Mia's cross. Transcript page 3485, starting at line 18 -- excuse me, I'm sorry -- starting at line 7. I asked Mia: during the time that you were working with Sean Combs from 2009 until the posting on the 4th day of November 2014, you still had friends outside of people who worked with Mr. -- excuse me -- with Combs Enterprise, is that true? Answer: I didn't get to see them or speak to them. But your friends don't just stop being friends to you. But no, at this point in time, I did not have an external sounding board. I didn't get to see or talk to any friends and family in any capacity that made sense. Every once in a while. Question: You could have though, right? Answer: No. I asked, Why? There was absolutely no time. I was also -- couldn't, didn't have -- then there is a hyphen -- I had to get permission to leave or do things -- there is a hyphen -- I mean, I had to beg to go to my grandmother's funeral. So I don't know if that paints any sort of picture. I believe that this goes to impeach that type of direct.
THE COURT: Yes, you can ask questions about that, if you want to, so there's no objection to that. The objection is to putting these posts in, which the actual images and the posts themselves have no relevance to anything and are cumulative of a number of other exhibits that have been put in. To give just one example, to the point -- to the extent you wanted to make a point along the lines of what you're saying, you already spent a lot of time on the scrapbook and cover letter, which obviously reflected -- and you asked Mia about this -- the immense amount of time that she devoted on her personal time to crafting a message on the occasion of Mr. Combs' birthday. You could always ask questions about that scrapbook and the cover letter, if you wanted to make the point that you're talking about. By the way, you could also do that as to a number of the other Instagram posts and other videos, the happy birthday video, etc. You could do that through testimony. But what I'm not hearing, I haven't heard it yet, is why the actual posts, which include things like Mia with her friends and family -- I'm guessing, I don't know who these people are -- at particular family events, why that wouldn't be grossly prejudicial and have no relevance to the case? What might have relevance, because you've shown me the testimony you're talking about, is you asking questions along those lines to understand what the witness' answer is. There is no objection to that. So that's how you should proceed. All right. Let's have Mia back.
(Witness resumed)
THE COURT: Welcome back.
(Continued on next page)
(Jury present)
THE COURT: Please be seated. Mr. Steel, you may proceed when ready.
BY MR. STEEL:
MR. STEEL: You explained that you and Ms. Ventura were best friends, fair?
MR. STEEL: And that continued or that began -- excuse me -- from the time that you met her and started to learn about her and she met you and started to learn about you and you spent time together, is that fair to say?
MR. STEEL: And that would be approximately 2009 throughout the term of your employment with Mr. Combs and the businesses that he's affiliated with and you were affiliated with in March 2017, is that true?
MR. STEEL: Yes?
MR. STEEL: Not just friends, I mean, you describe Ms. Ventura to the jury as your sister, fair?
MR. STEEL: I mean, that, to me, connotes something, but to you, is it true that that's somebody that you love?
MR. STEEL: True to your heart?
MR. STEEL: It's like a part of you?
MR. STEEL: And that relationship continued after March 2017 and actually survives today, that's the same way you feel about Ms. Ventura, is that true?
MR. STEEL: Yes, ma'am.
MR. STEEL: OK. And that never wavered, right?
MIA: Never wavered, no. But there was a time period where we didn't see each other. But it never wavered.
MR. STEEL: OK. Now, you would not lie to Ms. Ventura, would you?
MIA: I would not lie to her -- I wouldn't lie to her -- I wouldn't lie to her from my own -- I wouldn't lie to her about, um, anything that I wasn't forced to lie to her about.
MR. STEEL: Explain that.
MIA: As of current day, no, I would never lie to her. But when I was working for Puff, I was not allowed to tell her the truth about a lot of things.
MR. STEEL: Such as what?
MIA: Where Puff was, what he was -- just anything that Puff told me, whatever story Puff told me, I had to uphold that.
MR. STEEL: Let's talk about this. Did you ever tell Ms. Ventura that -- well, was Mr. Ventura, to your observation, in love with Mr. Combs?
MR. STEEL: Did you ever tell Ms. Ventura that the person you're in love with sexually assaulted me?
MR. STEEL: Did you ever tell Ms. Ventura that the person that you're in love with is -- turns eyes that are black and enrage and he beats you often; did you ever say that to her?
MS. SMYSER: Objection.
THE COURT: Sustained.
MR. STEEL: Did you ever discuss with Ms. Ventura your concern that she should get away from Mr. Combs?
MR. STEEL: Yes.
MR. STEEL: And the reason you couldn't have is for the reason you stated, you made a promise to Mr. Combs, is that what you're saying?
MS. SMYSER: Objection.
THE COURT: That's sustained.
MR. STEEL: Why couldn't you have told your sister that, you've got to get out of this relationship, if it was so bad?
MR. STEEL: By whom?
MR. STEEL: Do you have any writing or anything else, besides your word --
MS. SMYSER: Objection.
MR. STEEL: -- that Mr. Combs told you that?
THE COURT: It's overruled. Wait. Hold on. Hold on. That needs to be rephrased, Mr. Steel.
MR. STEEL: I'll move on.
MR. STEEL: Now, do you remember a time in March 16, 2016, when Ms. Ventura told you that she was mad with Mr. Combs for being jerky?
MR. STEEL: Do you recall you putting up or taking up for Mr. Combs and saying to Ms. Ventura, your sister, that Mr. Combs is dealing with heavy things?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MR. STEEL: All right.
THE COURT: All right. Mr. Steel, next question.
MR. STEEL: Do you remember telling Ms. Ventura that Mr. Combs only deals with heavy things by lashing out at the person he is closest to and loves the most, which is Ms. Ventura?
MS. SMYSER: Objection.
THE COURT: It's overruled.
THE COURT: All right. Mr. Steel.
MR. STEEL: Do you remember telling Ms. Ventura that Mr. Combs' brain needed to be re-wired, you compared him to a child throwing a tantrum?
MS. SMYSER: Objection, your Honor. Could we please have a sidebar?
THE COURT: We may.
(Continued on next page)