(In open court)
THE COURT: All right. Members of the jury, this is a good time for us to take our lunch break. As I always tell you, don't have any discussions with each other about this case and don't speak with anyone else about this case. With that, enjoy your lunch, and we'll be back at 12:50. All rise.
(Continued on next page)
(Jury not present)
THE COURT: All right. Please be seated. Mia, during the lunch break -- as you can remember, because it just happened, you were asked some questions about your discussions with the government in 2023 and 2024. What's going to happen during the lunch break is that you're going to be given copies of some documents that you should read over during the lunch break and see if they refresh your recollection, and then when we come back, you'll be asked some questions, to just follow up on that, okay?
THE COURT: Other than that, have a good lunch, and we'll be back here at 12:50. Thank you.
(Witness temporarily excused)
THE COURT: Anything further to address before we adjourn for the lunch break? Ms. Smyser or Ms. Comey?
MS. SMYSER: No, your Honor.
THE COURT: Anything from the defense?
MR. AGNIFILO: Nothing from us, Judge. Thank you.
THE COURT: All right. Now, there was some issue raised about some line of inquiry concerning the retention of counsel. Have we got past that?
MR. AGNIFILO: We're --
THE COURT: During the sidebar, there was a suggestion from Mr. Steel that he was going to ask questions about some prior litigation result obtained by an attorney that Mia retained. Is that still an issue?
MR. AGNIFILO: I'd like to -- yes. We have the lunch break. Let's talk to the government about it, and we'll come back to the Court, and if we could agree, great; if not, we'll tee the issue up for your Honor.
THE COURT: Very good. We'll be back at 12:45 to address that issue, and we'll seek to restart at 12:50.
(Luncheon recess)
AFTERNOON SESSION 12:45 PM
(Trial resumed; in open court; jury not present)
THE COURT: Anything further to address before we bring the witness and the jury back?
MS. COMEY: I'll just note for the record, your Honor, that during the lunch break, with defense counsel's permission, we shared an iPad containing some of the 3500 material with Mia. I understand she wasn't able to read through everything the defense wanted her to, but with the defense's permission, we directed her to 3500 from her June 2024 meeting, which I think is the focus of the inquiry.
THE COURT: All right. Very good. So, with that, Mr. Agnifilo -- and you have to get on a microphone or you have to speak --
MR. AGNIFILO: No, I'm just speaking with my colleagues for a second.
THE COURT: Okay.
(Pause)
MR. AGNIFILO: We think we resolved the lawyer issue.
MS. COMEY: Your Honor, Mr. Agnifilo just said we've conferred, and we believe that there will not be an objection if Mr. Steel asks Mia why she engaged the lawyer that represents her today.
THE COURT: All right. Very good. Anything further from the defense?
MR. AGNIFILO: Nothing, nothing, Judge. Thank you.
THE COURT: All right, Mr. Steel. Are you prepared to proceed at this time so we can bring the witness and the jury back?
MR. STEEL: Yes. Once the witness is ready, I guess, if she is ready.
MS. COMEY: I can go check, your Honor. In the meantime, I think the government counted over the lunch break and is prepared to orally stipulate, when the jury comes back, that this witness met with the prosecutors 28 times in total.
THE COURT: All right. So let's check and make sure Mia is ready. If she is, then she can return to the stand.
(Pause)
THE COURT: All right. Everyone, get ready.
(Continued on next page)
(Jury present)
THE COURT: Please be seated. Welcome back, members of the jury. Mia, you understand you are still under oath?
THE COURT: Now, Mr. Steel, are you ready to proceed?
MR. STEEL: Correct. MIA, CROSS-EXAMINATION CONTINUED
BY MR. STEEL:
MR. STEEL: Were you able, over the break, to review the notes of your interviews, or some of your interviews, with federal agents and the federal prosecutors?
MR. STEEL: Isn't it true that you did not mention anything of any type of sexual abuse until June 28, 2024?
MR. STEEL: Did you look at the documents that the Honorable Court let you review during the lunch break and the date?
MR. STEEL: You didn't review the June 28, 2024?
MR. STEEL: Correct?
MR. STEEL: And is it fair to say that's the first time that you ever mentioned anything about sexual abuse?
MR. STEEL: Well, you didn't see it in the three previous notes, did you?
MIA: I just saw one -- no, actually, the two that I reviewed both mentioned -- both of them mentioned it.
MR. STEEL: Mentioned you being abused by Sean Combs sexually? Is that what you're telling the jury?
MIA: The two that I just reviewed both mentioned -- wait, did the first one mention it? I believe -- I believe so.
MR. STEEL: Ma'am, we're going to come right back to that, but I'd like to put up, with the Court's permission, admitted Government Exhibit 3T109. Do you remember viewing this and discussing this photograph that's memorialized in 3T109, Government Exhibit?
MR. STEEL: You said that there's bruises on the arm of Ms. Ventura. Do you remember saying that?
MR. STEEL: And where are these -- this is right after Ms. Ventura's what, according to you?
MR. STEEL: And when did the bruise supposedly occur?
MR. STEEL: Show the jury — and we're going to blow it up with the Court's permission — the arm.
MR. STEEL: Are you talking about the right or the left arm?
MR. STEEL: 3T109, with the Court's permission, can it be enhanced on the arm, your Honor?
THE COURT: All right.
MR. STEEL: Where on that arm do you see this bruise?
MR. STEEL: That's the bruise you're referring to?
MR. STEEL: You also mentioned eyes of Ms. Ventura --
MR. STEEL: -- were covered up in makeup; is that true?
MR. STEEL: Can you focus on the facial part of that exhibit, 3T109. Do you see the eyes are partially -- see the eyes of Ms. Ventura?
MR. STEEL: Do you see any redness in the pupils area?
MR. STEEL: All right. Now --
MR. STEEL: You can take that down if you don't mind.
MR. STEEL: -- do you have any photographs of Ms. Ventura's bruising from anything that you witnessed?
(Continued on next page)
BY MR. STEEL:
MR. STEEL: Well, would you have turned them over if you did?
MS. SMYSER: Objection.
THE COURT: That's sustained.
MR. STEEL: Did you turn them over?
MS. SMYSER: Objection.
THE COURT: Sustained.
MR. STEEL: Why are you unsure?
MR. STEEL: Didn't you look at your devices, electronic devices, and computers and hard drives for any evidence that was relevant in this matter?
MS. SMYSER: Objection.
THE COURT: Sustained.
MR. STEEL: Did you ever look for any type of bruises that you would have of Ms. Ventura in any electronic form?
MS. SMYSER: Objection.
THE COURT: I think you might need to just rephrase that last question.
MR. STEEL: Did you search for any -- Did you search your devices in order to look at evidence that may be relevant to this case? When I say evidence, anything related to Sean Combs, Ms. Ventura, her bruisings, your supposed outcries, anything like that?
MS. SMYSER: Objection.
THE COURT: There was a lot in there, Mr. Steel. Maybe you can rephrase it.
MR. STEEL: Did you search your computers or your devices for any photographs of Ms. Ventura being bruised that you may have?
MIA: I gave everything to my attorneys and I searched -- I mean, I did look through things, but I wasn't specifically looking for that.
MR. STEEL: Did you ever give over screenshots from your devices to the government or have your attorneys do that?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MR. STEEL: Do you know whether you prevented -- or your agents on your behalf, your lawyers -- the government from searching your devices?
MS. SMYSER: Objection.
THE COURT: Sustained.
MR. STEEL: I would like to show you what you already reviewed during the break, January 5, 2024, notes from your meeting with the government. That would be 3404-002, starting page two. You reviewed this during the break, you stated?
MR. STEEL: You can review it again, if you need to. But where in here does it say anything about sexual abuse on January 5, 2024, meeting with the government?
MS. SMYSER: Objection.
THE COURT: Sustained.
MR. STEEL: Looking here, review it to yourself, and then I'm going to ask you a series of questions based upon what you said. Just tell us to turn the page.
MR. STEEL: You're looking for anything about sexual --
MS. SMYSER: Objection.
THE COURT: Hold on. Hold on. Hold on. You can just let us know when you want the page turned.
THE COURT: OK. Same thing when you're done with this page, just let us know.
BY MR. STEEL:
MR. STEEL: On January 5 of 2024, did you ever tell the government anything about your being sexual abused, to your memory --
MS. SMYSER: Objection.
MR. STEEL: -- to your memory, if it's refreshed, or your memory?
THE COURT: Why don't we reask that question.
MR. STEEL: Do you agree or disagree that, on January 5, 2024, you never told the government anything about a sexual abuse allegation against Mr. Combs?
MS. SMYSER: Objection, your Honor. This is improper.
THE COURT: Grounds?
MS. SMYSER: It's improper refreshment.
THE COURT: OK. Well, it's overruled. But because we have the exchange, Mr. Steel, why don't you ask the question again, please.
MR. STEEL: Sure.
BY MR. STEEL:
MR. STEEL: Do you agree that, on January 5, 2024, you never mentioned anything about sexual abuse at the hands of Mr. Combs to the government?
MIA: Again, I don't remember dates. But if it was the first meeting, then I absolutely did not mention it.
MR. STEEL: OK. Look at 3504, if you don't mind, 004, starting on page two. You reviewed this during the break, do you remember that?
THE COURT: You don't have anything up. Do you want the witness to review this?
MR. STEEL: Just for a moment, yes.
THE COURT: All right.
BY MR. STEEL:
MR. STEEL: Do you remember reviewing this during the break, the honorable court let you do this and you reviewed it?
THE COURT: Hold on. Mia, take your time. Take a look at what you're seeing. If you need to see anything more, let you know, and look up when you're done.
MR. STEEL: Do you need the next page, or your memory is refreshed?
MR. STEEL: Go ahead.
THE COURT: Let's go to the next page. Did you see this page? You've got it up here. All right.
MR. STEEL: Do you agree that, on January of 2024, you never told the government anything that you were supposedly sexually abused by Mr. Combs, is that true?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MR. STEEL: Am I correct --
THE COURT: Well, hold on. Mr. Steel, you asked the witness to look at some documents to refresh the witness's recollection, is that correct?
MR. STEEL: True.
THE COURT: All right. So why don't you phrase your question in that way so that there is no confusion as to what you're asking.
BY MR. STEEL:
MR. STEEL: With your memory refreshed, am I correct when I say that you did not tell the government anything about the supposed sexual abuse on January 8, 2024 --
MS. SMYSER: Objection.
MR. STEEL: -- as that document just was shown?
THE COURT: That's overruled.
MIA: Again, I don't remember the dates, and I don't remember each specific meeting or what was said in each meeting. But I did not tell the government the first time. More than likely, whenever I had representation. Before that, I did not.
MR. STEEL: Well, let's go to 3504-004. You may have reviewed this on the break. That's wrong. That's wrong. 3504-008. Did you review this document? If not, just let us know, and review it to yourself. If you have already done it, just tell us when you're ready and you need the next page.
MR. STEEL: And in this document that you just reviewed to refresh your memory --
THE COURT: Hold on. Just so we're clear on what the form of the question should be, you should ask the witness if her memory was refreshed, whatever it is you're asking about.
MR. STEEL: Did what you just read, did that refresh your memory of the March 19, 2024, meeting with the government?
MIA: It did not refresh my memory to the specific meeting, because I -- it does not refresh my memory to a specific meeting.
MR. STEEL: Did it refresh your memory that, in that meeting, you never mentioned any type of sexual abuse at the hands of Mr. Combs, true?
MS. SMYSER: Objection.
THE COURT: That's overruled.
MIA: Again, I don't remember -- I don't remember, like, dates or what was said in each meeting. So it doesn't refresh my memory, if that's what you're asking.
MR. STEEL: And in this document, you were represented by a lawyer, Shawn Crowley, correct?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MR. STEEL: Then I would like you to look at what you mentioned earlier, if you need it, 3504-014. Remember you saw the handwritten notes?
MR. STEEL: OK. You've reviewed these during the break, I presume?
MR. STEEL: And this -- You can take it down. If you need to see it again, let us know. This will be the first time you ever mentioned that Sean Combs ever supposedly sexual assaulted you, correct?
MS. SMYSER: Objection.
THE COURT: That's sustained.
MR. STEEL: Do you deny this is the first time that you ever mentioned to anyone that Sean Combs sexually assaulted you?
MS. SMYSER: Objection.
THE COURT: Yes. What is the "this?"
MR. STEEL: June 18, 2024.
THE COURT: Let's get a new question, and we just need to be a little clearer what we're talking about here.
BY MR. STEEL:
MR. STEEL: Isn't it true that the June 18, 2024, meeting with the government and the agents was the first time that you ever mentioned anything about sexual abuse at the hands of Sean Combs?
MIA: I have no idea when I first mentioned it. I didn't see -- I have no idea when I first mentioned it, except for it was after I had representation.
MR. STEEL: All right. Now, you do intend to sue Mr. Combs for monetary gain based upon your allegations, isn't that true?
THE COURT: Mr. Steel.
MR. STEEL: You want money from Mr. Combs based upon your testimony, true, don't you?
MR. STEEL: After leaving Mr. Combs' employment in March of 2017, have you worked since?
MR. STEEL: Have you worked in this same industry?
MR. STEEL: Who did you work with?
MR. STEEL: And what did you do with Madonna, the artist Madonna?
MIA: A myriad of things. I was hired to help lead her film division. She also needed help restructuring her internal executive team, then it morphed into multiple roles.
MR. STEEL: What type of roles, if you can make it simple, if you don't mind?
MR. STEEL: Give us an idea.
MR. STEEL: Did you work directly with the artist Madonna?
MR. STEEL: And how long were you employed?
MIA: I left -- initially, I said I was there for three months. I think I allowed it to extend to eight.
MR. STEEL: And when was the term? What dates, if you best remember?
MIA: It was April of -- I don't remember what year. I guess 20- -- I don't know if it was 2018 or 2019 until, I think, like, October the next year.
MR. STEEL: And --
MR. STEEL: And when you were doing that position, to your knowledge -- if you don't know, just say I don't know -- did Mr. Combs assist you in getting that job?
MR. STEEL: OK. This is after you sued Mr. Combs and no longer worked with him that you worked with Madonna, right?
MS. SMYSER: Objection.
THE COURT: Sustained. It just needs to be rephrased.
MR. STEEL: After March 2017, you just gave us the dates, you worked with Madonna for the eight months, fair, is that true?
MR. STEEL: Do you have any evidence to share with this jury that you were somehow blacklisted?
MS. SMYSER: Objection.
THE COURT: Overruled.
MR. STEEL: No retribution or retaliation by Mr. Combs even after you went to mediation with him, true?
MS. SMYSER: Objection.
MR. STEEL: To your knowledge?
THE COURT: It's overruled.
MIA: Yeah. He took away the TV show that I had created, he took away the credit that I was promised in the documentary, and other projects that I was working on.
MR. STEEL: Ma'am, you told the jury that you were surprised you were let go from your position with Mr. Combs' entities. Do you remember that?
MR. STEEL: You really didn't understand why?
MR. STEEL: Isn't it true that you were let go for failing to arrive on time and for drinking?
MS. SMYSER: Objection.
THE COURT: It's overruled. A. Absolutely not.
MR. STEEL: You were never told that?
MR. STEEL: Now, I want to talk with you about Ms. Ventura's career. OK?
MR. STEEL: In Ms. Ventura's career, are you aware of Official, called Girl video 2009. Do you remember that?
MR. STEEL: Yes. Are you aware of a video, musical video, Official Girl, and the music, 2009?
MR. STEEL: OK. Is that Ms. Ventura on the song?
MR. STEEL: Along with a performer, did you ever hear of Lil' Wayne?
MR. STEEL: Would you consider him a well-known accomplished performer, musical performer?
MR. STEEL: Are you familiar with Ms. Ventura's music King of Hearts?
MR. STEEL: Do you remember the year about 2012?
MR. STEEL: Tell the jurors what you remember about that, if you don't mind, what that is?
MR. STEEL: Do you remember anybody on the song with her?
MR. STEEL: Do you remember that song being released?
MR. STEEL: 2012, do you remember a musical and a video The Boys?
MR. STEEL: Yes?
MR. STEEL: Do you remember any artists, well-known artists, that performed with Ms. Ventura on that song and the video?
MR. STEEL: Who would that person be?
MR. STEEL: Is Nicki Minaj also an internationally known bright light in the entertainment industry, musical industry?
MR. STEEL: How about 2013, do you remember a mix tape being released with Ms. Ventura, RockaByeBaby?
MR. STEEL: Can you explain to the jury what a mix tape is and what was on it with Ms. Ventura, if you do? Do you remember?
MIA: I don't remember everybody or who exactly who was on it. The mix tape was just her way to present her music.
MR. STEEL: That was released to the public, true?
MR. STEEL: The same year, 2013, do you remember music and video Paradise that Ms. Ventura released?
MR. STEEL: Did you ever know Ms. Ventura to work with a very well-known artist Whiz Khalifa?
MR. STEEL: That was released to the public, fair to say?
MR. STEEL: How about 2013, music video, Ms. Ventura released Numb, do you remember that one?
MR. STEEL: Do you remember a gentleman, I think there were pictures in your social media, the jurors have seen Rick Ross. Do you know who that is?
MR. STEEL: Tell the jurors who that is.
MR. STEEL: Fabulously famous, true?
MR. STEEL: And he was on that with Ms. Ventura, that song, true?
MR. STEEL: OK. Do you remember Numb being released to the public?
MR. STEEL: How about 2013, I Know What You Want, do you remember that musical video?
MR. STEEL: Do you remember 2013, I Love It, a song, video by Ms. Ventura released?
MR. STEEL: Do you remember an artist being featured on that, Fabolous?
MIA: Yeah. I would have to see it to remember it. I just can't -- I'm not good, with, like, titles of things, I guess.
MR. STEEL: About 2016, do you remember Bad Boy Reunion tour?
MR. STEEL: Do you remember Ms. Ventura being part of that tour and that video release and musical release?
MR. STEEL: And then in 2017, do you remember the song Love a Loser, the video as well?
MR. STEEL: Do you remember, starting in 2011, Ms. Ventura being in the studio a great deal with a gentleman, performer known as Kid Cudi?
MIA: Again, I don't know the years of things. I do know Cass -- I mean, I've been to the studio with Cass multiple times. I just don't remember, like, the schedule.
MR. STEEL: Do you remember Ms. Ventura also working with performer, well-known performer, G-Eazy?
MR. STEEL: French Montana?
MR. STEEL: And Mr. Combs himself?
MR. STEEL: Do you remember Ms. Ventura being promoted and appearing at an editorial, photo shoots, and modeling opportunities throughout the years that you worked with her and even when you maintained your friendship with her?
MR. STEEL: Photo shoots?
THE COURT: Sustained.
MR. STEEL: Modeling?
THE COURT: Rephrase.
MR. STEEL: Do you remember Ms. Ventura being a participant in photo shoots throughout the years?
MR. STEEL: Modeling throughout the years --
MR. STEEL: -- that she was with Mr. Combs. How about being in movies?
MR. STEEL: Perfect Match, released 2016, true?
MR. STEEL: Honey 3, filmed fall of 2016 in South Africa, right?
MR. STEEL: Who else was in that film?
MR. STEEL: Correct.
MIA: Oh, there was a bunch of people. I don't -- I don't have, like, a call sheet to say all their names, but... It as a dance movie, so there were a lot of dancers.
MR. STEEL: Did you ever go to South Africa with Ms. Ventura?
MR. STEEL: Did you spend approximately 30 days or more with her there?
MR. STEEL: And was there other artists there making the movie?
MR. STEEL: Michael B. Jordan?
MR. STEEL: OK. Nearly every year, did you attend or know if Ms. Ventura, personally know Ms. Ventura attended events, such as film festivals?
MR. STEEL: Tell the ladies and gentlemen what you did there.
MIA: That was the film festival that we were at because Puff and I -- well, we had coproduced a movie that was there. So Cass was with us as well.
MR. STEEL: OK. How about Met Gala?
MR. STEEL: That's true.
MR. STEEL: Can you tell the jurors what that is?
MR. STEEL: How about Paris Fashion Week?
MR. STEEL: Yes, and Ms. Ventura.
MR. STEEL: And Grammy Awards events?
MR. STEEL: And Ms. Ventura was there with you, as well?
MR. STEEL: What's VMAs?
MR. STEEL: Yes. Tell the jurors.
MR. STEEL: Were you, all of this that you just referred to, and I'm not limiting to it, but all of this, if you know, was with the knowledge, permission, and consent of Sean Combs to promote Ms. Ventura, is that true?
MS. SMYSER: Objection.
THE COURT: That's overruled.
MR. STEEL: What you just articulated to the jury about Ms. Ventura's career, all of that was promoted by Mr. Sean and encouraged by Mr. Sean Combs, true?
MIA: Was all of it promoted? Was -- Did he promote some of her -- did he promote her at all throughout the years?
MR. STEEL: Yes, that's my question.
MR. STEEL: Now, you mentioned several times throughout your testimony that you were a part of creating certain ideas and bringing it to life at Revolt Films, is that true?
MR. STEEL: Can you tell the ladies and gentlemen of the jury some of the things that you, you, helped create along with Mr. Combs?
MR. STEEL: You've got to go slower. I apologize for stopping you. Go ahead.
MR. STEEL: What was that TV show about?
MR. STEEL: The show's essence really focused on, through your eyes, how a person from a smaller town lived with such a significant person in the entertainment and business industry as Mr. Combs, is that a fair way to say it?
MR. STEEL: And you were saying that there is other films that you helped create the idea for?
MR. STEEL: Go ahead.
MR. STEEL: Yeah. Tell us what they were, please.
MIA: I wouldn't come up with the idea for the film, just about the partnerships. There was a movie called Dope that we coproduced.
MR. STEEL: Is Dope, you say dope, d-o-p-e?
MR. STEEL: Go ahead.
MIA: There was a movie called Lawless that we coproduced. There was a movie called Undefeated that we coproduced. And then the documentary, which we did all on our own.
MR. STEEL: You also mentioned that, through your work and your efforts, the company was making money. Do you remember saying that?
MR. STEEL: There was a profit, I mean, right?
MR. STEEL: And you thoroughly enjoyed working on these projects, right?
MR. STEEL: And you explained to the jury that you thoroughly enjoyed meeting the people from your inception. I'm saying the first day of hire through the conclusion and even beyond, some of the people that you met working with and for Mr. Combs, true?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MR. STEEL: The people that you met, you had great relations with certain people at the job, true?
MR. STEEL: And, in fact, you call them, like, a second family, right?
MR. STEEL: And you're still very close with a lot of those people, is that fair?
MR. STEEL: Some of them, fair to say?
MR. STEEL: OK. And through all of that, you also respected Mr. Combs when working with him, right?
MR. STEEL: You also thought that he is a genius, to use your word, true?
MR. STEEL: You also thought that he had insight into what was relevant and impactful to the community at large, true?
MR. STEEL: And you're telling the jury, you use this term, the highs were highs, the lows were lows. Do you remember saying that multiple times?
MR. STEEL: But my question I would like you to answer, if you don't mind, is: How could any high cover up the lows that you talked about, by being threatened with your life?
MS. SMYSER: Objection.
THE COURT: That's overruled.
MR. STEEL: And being, God forbid, seen actually abused, according to you, same question?
MS. SMYSER: Objection.
THE COURT: That's sustained.
MR. STEEL: Ma'am, would you agree with me that the reason you wrote that text message exchange on December 6, 2017, that the jurors had seen saying, I'm going to kill myself, was because you were told that you're no longer working with Mr. Combs and the industry, is because you loved that job?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MIA: My entire world was being ripped away from me immediately and even, in hindsight, that world was awful. I didn't know it at the time, so that's why it felt like everything was ending.
MR. STEEL: You wanted to work and continue to work for Mr. Combs and his industry businesses, right?
MIA: I wanted to continue -- I wanted to continue following my dreams. I was finally making real -- real stuff, and I had a separation from them.
MR. STEEL: And that means that you wanted to continue the work at that location with Mr. Combs and his businesses, that's my question, is that true?
MR. STEEL: And nobody forced you to work at that business, at that time that you were working there, is that true?
MR. STEEL: Yes. You were doing this, you wanted -- Well, it was a voluntary -- your mind was, I want to stay here and work, right?
MR. STEEL: Sure. Sure. While working with Sean Combs and the related businesses, that was your voluntary decision, you wanted to work for those companies and with Mr. Combs, is that true?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MR. STEEL: I couldn't hear you.
MIA: I'm just trying to -- Did I want to work for those companies? Did I want to work the film production we had created, is that what you're asking? I'm just a little bit confused by the wording.
THE COURT: Mr. Steel, why don't you try to reask the question just a little bit, and maybe you can rephrase it just a little bit to be a little more clear about what you're asking.
BY MR. STEEL:
MR. STEEL: You made the decision to continue to work for Sean Combs and his businesses, right, while you were there, right?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MR. STEEL: That's why you were devastated, because you liked working there so much when you were let go, right?
MIA: Again, I was devastated because it came out of nowhere and it was confusing about the film company being dissolved. It had -- and I was told it had nothing to do with me. Then I was called to come back -- again, it was all confusing. And, yeah, again, my world that I knew, the only world that I knew was being taken away. And so, yeah, that felt devastating.
MR. STEEL: And when you were called to come back, you came back, right?
MIA: No, not in that capacity. Not in the capacity that I believe you're trying to frame it. I worked from afar.
MR. STEEL: But you were allowed -- You continued to work even after December 6, 2016 into March 2017, right?
MR. STEEL: Now, we talked a lot about Ms. Ventura's career and the promotion of her career. Do you know whether Mr. Combs and the companies put in more money to promote Ms. Ventura's career than any other artist that they had on their label?
MS. SMYSER: Objection.
THE COURT: Sustained.
MR. STEEL: Do you have access and were you on e-mails, if you remember, talking about the amount of money being put forth for the various artists on the label?
MS. SMYSER: Objection.
THE COURT: That's overruled.
MIA: I'm not sure. I don't remember. I mean, I was forwarded things from all over and, just, for him to review. So I didn't have time to absorb every piece of information.
MR. STEEL: Did you ever absorb information that Ms. Ventura was being promoted more moneywise than any other artist with Mr. Combs' companies?
MR. STEEL: Let me show you what's been marked just for your eyes and the parties, Defense Exhibit No. 1769, if that's OK. Just do me a favor and just orient yourself with this. Don't say what it is. Just look at it and tell me, it's multiple pages, by the way, just tell us when to turn the page, if you need it.
MS. SMYSER: Objection.
THE COURT: Mia, just read over the document, and Mr. Steel is going to follow up with a question.
THE COURT: OK. Mr. Steel.
BY MR. STEEL:
MR. STEEL: Did you review the document, did you say yes?
MR. STEEL: Is that document accurate for what it purports to be in the e-mail?
MR. STEEL: Do you remember receiving and being part of this e-mail chain?
MR. STEEL: Who is Jason Wiley, W-i-l-e-y?
MR. STEEL: Do you know what position?
MR. STEEL: Do you remember he was in budgeting?
MIA: I don't know what everybody does all the time, so I don't remember exactly. But he could have been.
MR. STEEL: Did that exhibit that you just reviewed, 1769, refresh your memory as to how much money was being expended on Ms. Ventura's career compared to other artists?
MR. STEEL: You're not saying that Ms. Ventura was not promoted the most by Sean Combs, are you?
MS. SMYSER: Objection.
MR. STEEL: Compared to other artists. Sorry.
THE COURT: It's overruled.
MR. STEEL: You're not telling the jury that Mr. Combs did not promote Ms. Ventura more than any other artist assigned to the label, are you?
THE COURT: All right. I'm going -- A. Sorry. I'm just confused.
THE COURT: Mr. Steel, there is, like, a triple negative in there. Maybe you've got to rephrase it.
MR. STEEL: Is it true that Mr. Combs promoted Ms. Ventura more than any other artist in the label? When I say Mr. Combs, I'm also talking about the other persons who work for the businesses.
MR. STEEL: OK. Now, do you know an artist and actor and artist model Michael B. Jordan?
MR. STEEL: Did you ever -- do you know him personally?
MR. STEEL: Were you ever with him when he was with Ms. Ventura?
MR. STEEL: OK. I would like to ask you about, you mentioned Kim Porter?
MR. STEEL: Yes. Do you know who I'm talking about, right; you mentioned her name?
MR. STEEL: And she is the mother and significant other to Mr. Combs, is that your understanding?
MR. STEEL: And Mr. Combs and Ms. Porter are very close or were very close, true?
MR. STEEL: And that's the funeral you went to in November of 2018 you talked about, right?
MR. STEEL: And you liked Ms. Porter, true?
MR. STEEL: And you knew from your observations Mr. Combs' love for her, true?
MR. STEEL: And do you remember speaking with Ms. Ventura -- don't say what was said -- about jealousy, that she was jealous at times of Ms. Kim Porter spending time with Mr. Combs? Do you remember that?
MR. STEEL: Well, did she indicate to you, from your observations, that it bothered her when Mr. Combs would be, at times, with Ms. Kim Porter?
MR. STEEL: Ms. Ventura wanted to be with Mr. Combs as his significant other, from your observations, is that true?
MR. STEEL: And Ms. Ventura was disappointed -- I'm not saying anyone lied to her, but she was disappointed that Mr. Combs was with other women, true?
MS. SMYSER: Objection.
THE COURT: That's sustained.
MR. STEEL: That Mr. Combs spent time with other women, including Kim Porter, is that true?
MS. SMYSER: Objection.
THE COURT: That's sustained.
MR. STEEL: Do you know personally from your observations whether it bothered Ms. Ventura when she would see, on social media or otherwise, that Mr. Combs was not spending time with her, but was spending time with Ms. Porter and other women?
MIA: From my memory and my experience, she only saw him on social media the one time in South Africa, and then there might have been -- there might have been with Kim, as well, but I don't remember. I'm sure she wasn't stoked.
MR. STEEL: You don't remember, but you -- Say it again.
MR. STEEL: You're saying "she" a lot. You're talking about Ms. Ventura was not thrilled, true?
MR. STEEL: And that's because Ms. Ventura wanted to be Mr. Combs' exclusive girlfriend-boyfriend, is that true?
MS. SMYSER: Objection.
THE COURT: Sustained.
MR. STEEL: Do you know from your own observations whether Ms. Ventura wanted to be exclusive with Mr. Combs?
MR. STEEL: But that was clearly not true, right?
MR. STEEL: Now, upon speaking with Ms. Ventura and being so close to her, did she ever tell you that she was being forced to have sexual contact she did not want before you read the November 16, 2023 lawsuit?
MS. SMYSER: Objection.
THE COURT: That's sustained.
MR. STEEL: Do you have -- did you have any reason to believe, from your observations, that Ms. Ventura was not freely spending all of her time with Mr. Combs?
MS. SMYSER: Objection.
THE COURT: That's overruled.
MR. STEEL: Let me go to an example. Do you remember telling the jury last week, I believe, on direct examination that there was a time in a hotel that you were asked by Ms. Ventura to bring some items, and Ms. Ventura -- you knocked on the door -- you went up to the room, knocked on the door, and Ms. Ventura opened the door. Do you remember something like that?
MR. STEEL: Do you remember how you said that Ms. Ventura peeked out of the door and took the items, or something to that effect?
MR. STEEL: Remember that? OK. Now, after that, did you ever have a conversation with Ms. Ventura that somehow she was held against her will in that hotel room?
MS. SMYSER: Objection.
THE COURT: Sustained.
MR. STEEL: All right. Let me ask you, do you recall being given the opportunity to have your therapist's notes permitted to be seen by the parties?
MS. SMYSER: Objection.
THE COURT: That's sustained. Sidebar.
(Continued on next page)
(At the sidebar)
THE COURT: Mr. Steel, how much time do you have left in cross-examination?
MR. STEEL: Not much.
THE COURT: Not much?
MR. STEEL: I don't believe.
THE COURT: All right. Now, since this is the third or fourth time we're getting into this therapist issue, which wasn't previously raised to the court, what is the issue? Let's figure it out.
MR. STEEL: The government met with and asked the lawyers for Mia, whether Mia would sign a release and waive confidentiality for the therapist's notes, and the 3500 says that they would not do so.
THE COURT: OK. But how can you possibly ask this witness about those discussions?
MR. STEEL: It's her agent. It's her lawyer. And I believe that constant statements and testimony of this witness saying you have to ask my therapist, and my therapist told me, and this is all explained in therapy and my therapist explained to me --
(Counsel confer).
MR. STEEL: -- I think opens the door. And Mr. Agnifilo just said that Mia also testified that she told her therapist when, in the 3500 she said that she did not tell her therapist, did not tell him, did not tell her lawyer, or anyone before the June 18, 2024 meeting with the government.
THE COURT: All right. Ms. Smyser.
MS. SMYSER: Let me clear up the record, your Honor. First of all, the government never asked for Mia's therapist's notes. There was one text message exchange when we searched Mia's phone. We didn't realize it was with her therapist. We were going to use that in trial, and then her lawyers and Mia asserted privilege over that. That was the end of that conversation, so I just wanted to make that clear. And I don't think there has been any opening the door to her privileged therapist's conversations. And my memory of the transcript is not that she testified to if or when she told the therapist about disclosures. I think all she said was that her therapist's conversations were privileged. So I don't think we should -- this should be an opening of the door into those many privileged conversations.
THE COURT: All right. Well, we're going to proceed with cross-examination. This is the type of issue that should have been brought up either before or after the lunch break, because it had been raised, questions had been asked, there were objections leveled, and then the court made a ruling on those objections. If there was going to be another attempt to elicit that testimony, that's the kind of thing that we would have brought up on the lunch break, not at a sidebar after the lunch break, when you're almost done with cross-examination. So, that's a procedural default from the defense in terms of raising this issue. If, to the extent, that there is any issue based on any testimony that Mia brought up concerning conversations with the therapist at this juncture, we'll address that. And if there is a need for a limiting instruction or a curative instruction, we can give that instruction. But it's going to have -- that's the kind of thing we're going to have to look at the transcript, see exactly what she said, and evaluate the objection, which is not something we can do right now. For present purposes, the objection is sustained. Let's move forward.
MR. STEEL: Can I ask the court a question? Would you consider taking a break? I'm almost done. I just wanted to organize the topics, I believe I'm done, and then see on this topic if I can find something in the transcript real fast.
THE COURT: How much time do you have left?
MR. STEEL: Ten minutes.
THE COURT: Ten minutes?
MR. STEEL: Something like that.
THE COURT: Why don't --
MR. STEEL: I'm not sure. I want to go over all my notes and streamline.
THE COURT: Do you have additional questions at this time for this witness?
MR. STEEL: Yes.
THE COURT: Why don't you finish up with those questions, we'll take a short break, and if there is anything further to ask me at that time, then we can address that.
MR. STEEL: OK. I think I can just...
THE COURT: The same thing we're talking about, re-sequencing it. We came back from a lunch break. I want to make sure, to the extent you have questions, you asked those questions and get that out of the way. Any loose ends or if there is anything on this issue to address at that juncture, we can take a break. All right. Let's do it that way.
MR. STEEL: That's fine. I think I could -- That's fine. I think I can be even shorter, though, is what I'm trying to tell you, because I think that I'm being told that Mr. Agnifilo found something in the transcript that Mia -- I'm not making this representation -- told her therapist about this supposed sexual assault.
MS. SMYSER: Your Honor, I want to say on this point, this came up on cross-examination.
THE COURT: Yes.
MS. SMYSER: The defense doesn't get to open their own door to Mia's privileged conversations with her therapist.
MR. STEEL: I think it depends on how it came out. I didn't open the door. I didn't bring up this conversation.
THE COURT: If the door has been -- Hold on. Finish up with whatever other questions you have, then we're going to take a break.
MR. STEEL: OK.
(Continued on next page)
(In open court)
THE COURT: All right. Mr. Steel, you may proceed.
BY MR. STEEL:
MR. STEEL: During the time that you were confused working with Mr. Combs, you testified that you never called law enforcement. Do you remember that?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MR. STEEL: And you said that, well --
THE COURT: You didn't get an answer.
MR. STEEL: I'm sorry. Do you remember saying that?
MR. STEEL: And you gave examples of why you didn't call the police. And if I'm wrong, just please correct me. But one example was, do you remember you were speeding to get to a meeting with Mr. Combs, or for Mr. Combs or for a business reason, and you were stopped by law enforcement, and Mr. Combs spoke with the officer and the officer let you go? Do you remember something like that?
MR. STEEL: The other reason you gave, the example you gave, was you were in a car with Mr. Combs stopped by law enforcement, and when law enforcement realized Mr. Combs was in the car, no ticket was issued. Do you remember that?
MR. STEEL: They were both, I think you said, in Los Angeles, right?
MR. STEEL: Did you ever anonymously think about calling law enforcement?
MR. STEEL: Did you ever think about getting a third party to call law enforcement?
MR. STEEL: Did you ever hear about a battered women's shelter while working for Mr. Combs and just reporting it there?
MR. STEEL: From 2009 up until November 24 of 2023, so that's approximately 14 years, 15 years -- 14 years, is that true?
MR. STEEL: And in all of that time, all of those days that passed, the only thing that you wrote to or about Mr. Combs were admiration statements, right, statements of admiration?
MR. STEEL: Yes. Or social media postings, you know, the jurors have seen?
MR. STEEL: And kindness towards Mr. Combs, right?
MR. STEEL: And laughter towards Mr. COmbs, right?
MR. STEEL: And love for Mr. Combs, right?
MR. STEEL: Do you remember telling this honorable court and the honorable jurors that Mr. Combs slammed a door on your arm, you thought it was an accident at first?
MR. STEEL: But then it continued, the pressure on the door -- I believe you said it was a big door -- continued where you believed, you know, in your mind, that Mr. Combs was actually trying to break your arm? Do you remember that?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MR. STEEL: And did you have to go seek any type of medical treatment?
MR. STEEL: Did you have any bruising?
MR. STEEL: Did you take a photograph of the bruising?
MR. STEEL: Was anyone there to watch this supposedly happen that you can identify?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MIA: The office was -- had people in it. I don't know who was there, who was watching, but people were around all the time.
MR. STEEL: Weren't you screaming?
MR. STEEL: Wasn't it painful?
MR. STEEL: How did you not scream, if you don't mind, if you know?
MR. STEEL: Are you done?
MR. STEEL: You talked about your very first day on the job, you went to an office in New Jersey or a home in New Jersey, and came back to a studio, and you were wiped out because it was a 24-hour day. Do you remember something like that?
MIA: I reported to the office, then I went to his house in Alpine, New Jersey, I reported back to the office, I went home. Before I got there, I was called to the studio, and then back to his place, yes.
MR. STEEL: And shortly thereafter, you talked about being sleepless, sleep deprived, rather, for five days in a row. Do you remember that?
MR. STEEL: And you were starting to -- these are my words -- but you were getting physically sick?
MS. SMYSER: Objection.
MR. STEEL: That's what you testified?
THE COURT: That's overruled.
MR. STEEL: Correct?
MIA: I didn't say sick. I said I had physical reactions. I just remember, like, seeing stars a bit and my equillibrum was off. And I remember, like, it felt like my hearing was under water.
MR. STEEL: How did you stay awake? Have You stayed awake for five days before?
MR. STEEL: Four days before?
MR. STEEL: Three days before?
MR. STEEL: Two days before?
MR. STEEL: At some point, didn't you just stop and say, I have to go to sleep?
MR. STEEL: And your testimony in front of the jurors is you were still functioning, though, day one, day two, day three, day four, and day five, that's what you're saying?
MR. STEEL: You were doing your work, is what you're saying, that's why you're not sleeping, is that true?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MR. STEEL: You're working for those five days, is what you're telling the jurors, correct, that's why you couldn't sleep?
MR. STEEL: You're productive, is what you're saying, I believe? If not, just say.
MIA: Was I productive? I don't remember really what was happening, but I'm assuming I made it through. Definitely not my best work.
MR. STEEL: But you didn't quit?
MR. STEEL: You didn't complain?
MIA: Well, I guess I burst into tears because I couldn't hold it anymore. I don't know if that's complaining.
MR. STEEL: There is no text message or note or self-reflection that this happened, right?
MS. SMYSER: Objection.
THE COURT: That's overruled.
MIA: There -- I did e-mail multiple times to the office saying, I haven't slept in this many days. Please, please, please, please, please, like, let me off work, if that's what you're asking. Yeah, there was -- there was e-mails like that.
MR. STEEL: And your testimony is that HR -- you know what HR stands for?
MR. STEEL: What is it?
MR. STEEL: And it's your testimony human resources was really just a front for Mr. Combs, that's what I think you're saying? If not, just correct me.
MIA: The only interactions I had with human resources were for them to enforce whatever punishment he wanted.
MR. STEEL: And it's your testimony that you didn't deserve any of that punishment or suspensions of work, is that what you're telling the jury?
MR. STEEL: And who in HR were the people you're talking about did not get it right?
MR. STEEL: Who suspended you without cause? Who were those people who were working there?
MR. STEEL: Say that again?
MR. STEEL: Now, you talked about blood dripping down your leg or flowing down your leg. Do you remember that?
MR. STEEL: Any witness to that, that you know about?
MR. STEEL: Who would that be?
MR. STEEL: 40 people. OK.
MR. STEEL: And during this whole time working with Mr. Combs, you testified and told the government in your prior statements that you were terrified at all times. Do you remember that?
MS. SMYSER: Objection.
THE COURT: That's sustained.
MR. STEEL: You were afraid of being killed. Do you remember that?
MS. SMYSER: Objection. Timeframe, your Honor.
THE COURT: Mr. Steel.
MR. STEEL: Yes, sir.
THE COURT: Can we get some clarification on what you're talking about?
BY MR. STEEL:
MR. STEEL: While working with Mr. Combs, you testified that there were times that you felt that you could die at the hands of Mr. Combs. Do you remember that?
MS. SMYSER: Objection.
THE COURT: It's overruled.
MIA: He threatened my life before and physically assaulted me before, if that's what you're asking.
MR. STEEL: But then your answer is the highs are highs and the lows are lows, right?
(Continued on next page)
BY MR. STEEL:
MR. STEEL: You testified that you would give up all of the money if there was no sexual abuse. Do you remember that conversation you had with the prosecutor?
MR. STEEL: Have you had any discussions — I'm not asking for any type of attorney-client matters — did you have any discussions with anybody that you believe that you will make money by testifying against Mr. Combs in the manner you testified today?
MR. STEEL: Your Honor, can I organize those other matters?
THE COURT: Yes. We're going to take a short break and come back in ten minutes. Thank you, members of the jury. All rise.
(Continued on next page)
(Jury not present)
THE COURT: Thank you, Mia. We'll see you back here in about ten minutes. Thank you.
(Witness not present)
THE COURT: Mr. Steel?
MR. STEEL: Your Honor, can I just have one minute to get some notes together on the therapist issue?
THE COURT: Yes.
MR. STEEL: Thank you, sir.
MS. SMYSER: Your Honor, while he's doing that, can we be heard on the therapist issue?
THE COURT: You may.
MS. SMYSER: So, your Honor, I was carefully objecting throughout Mia's testimony when conversations with her therapist came up. I don't think she disclosed anything that would waive that privilege. And I'll remind the Court that this witness is a lay witness, she is not a lawyer. I think she was trying very hard not to disclose conversations with her attorneys or conversations with her therapist. And as we pointed out at sidebar, to the extent any conversation with her therapist came up, it was on cross-examination and in response to cross-examination, and defendant shouldn't be able to open their own door here. I will also note, just before I sit down, if there's any possibility that you're considering any waiver, I understand that Mia's counsel would like to be heard, also.
THE COURT: Understood. I take it the government has no objection to an instruction to the jury that to the extent there was any testimony concerning discussions with Mia's therapist, they should disregard that testimony and not consider it as part of their deliberations?
MS. SMYSER: That's fine, your Honor.
THE COURT: All right.
MS. COMEY: Your Honor, while we are waiting, we have some logistical issues to flag. We have the custodian from a hotel, who has an 8:00 p.m. flight. We thought she'd be on the stand hours ago. We're hoping that, if necessary, we could stay a little late so that she doesn't have to stay until tomorrow.
THE COURT: That's fine.
MS. COMEY: Thank you, your Honor. And, also, we're going to have to reorder some of our witnesses, given how long Mia's cross was today. We have other logistical issues with other witness travel that we're going to have to take into account, given how long the cross was today.
THE COURT: Understood. And I appreciate that.
MR. STEEL: Your Honor, I believe we're going to be done based upon the Court's colloquy just now with an instruction. I just have to make sure with the rest of the people here.
MR. AGNIFILO: Only because I was looking for the testimony when your Honor was speaking, so I might not have gotten what your Honor said. Your Honor was talking about instructing the jury in regard to something in connection with any reference to the testimony about the therapist?
THE COURT: Yes.
MR. AGNIFILO: And what's the Court's proposal?
THE COURT: Before the break, there were some questions about the witness' discussions with her therapist. You should not consider that testimony in this case or as part of your deliberations.
MR. AGNIFILO: All right. Thank you.
THE COURT: With that, that resolves the issue?
MR. AGNIFILO: I think that resolves the issue. Thank you, Judge.
THE COURT: With that, if anyone needs a very short break, you can take it, but, otherwise, we will proceed in a couple of minutes. Why don't we take five minutes and come back.
(Recess)
THE COURT: Please be seated. Let's have Mia come back to the stand.
MR. STEEL: Your Honor, thank you for that break. No other questions.
THE COURT: All right. Thank you.
(Witness present)
(Continued on next page)
(Jury present)
THE COURT: Please be seated. Anything further, Mr. Steel?
MR. STEEL: No, sir.
THE COURT: Members of the jury, before the break there was some testimony concerning the witness' discussions with her therapist. You should not consider that testimony in this case or as part of your deliberations. With that, Ms. Smyser.
MS. SMYSER: Thank you, your Honor.