THE COURT: Ms. Geragos, you may proceed with cross-examination.
MS. GERAGOS: Thank you, your Honor. JANE, resumed.
CROSS-EXAMINATION BY MS. GERAGOS:
MS. GERAGOS: Good morning, Jane.
MS. GERAGOS: As Ms. Comey said, we've met before, right?
MS. GERAGOS: We've met several times in person prior to this case or this trial starting, right?
MS. GERAGOS: And then, as you said yesterday, once the trial began, you made the decision not to meet with me or Mr. Agnifilo any more, right?
MS. GERAGOS: Because you understood that was your choice, right?
MS. GERAGOS: And nobody ever pressured you to meet with us again once you made that choice, right?
MS. GERAGOS: And since January, I think you said, you've met with prosecutors and agents in this case several times. Does that sound right?
MS. GERAGOS: And would you say it's about 24 times since January this year?
MS. GERAGOS: And every one of those 24 times, you went over the substance of your testimony with the prosecutors and the agents involved here, right?
MS. GERAGOS: And Ms. Comey asked you yesterday who was paying for your attorney, and you said Mr. Combs is, right?
MS. GERAGOS: Has Mr. Combs ever attempted to interfere with your attorney's representation of you?
MS. GERAGOS: And do you believe your attorney has represented you to the best of her ability?
MS. GERAGOS: And you're testifying here at this trial against Mr. Combs despite him paying for your attorney, right?
MS. GERAGOS: Well, you're testifying as - I should rephrase that - as a witness here at this trial?
MS. GERAGOS: Despite him paying for your attorney, right?
MS. GERAGOS: So no pressure has been exerted by him on you at this trial, right?
MS. GERAGOS: In other words, he's been paying for your attorney, and that has not prevented you from doing what you would like to do, right?
MS. GERAGOS: It's been eight months or so since his arrest. Does that sound right?
MS. GERAGOS: And you haven't spoken to him?
MS. GERAGOS: And you haven't seen him. The first time you've seen him is this week, right, or Friday?
MS. GERAGOS: And in the meetings, approximately 24 meetings with the government that you had, how many times did they prep you on how to be cross-examined at this trial?
MS. GERAGOS: Did they bring other prosecutors into the meetings and cross-examine you?
MS. GERAGOS: How long did those parts of the meetings last?
MS. GERAGOS: And in the other 24 meetings, or over the approximately 24 meetings, did they go over all of your messages that we admitted yesterday over the course of your examination with you?
MS. GERAGOS: And they did that with you at pretty much every meeting. Does that sound right?
MS. GERAGOS: And some of the screenshots that we went over as well?
MS. GERAGOS: I think you said yesterday you did not go to homeland security asking to participate in this case, right?
MS. GERAGOS: They came to you?
MS. GERAGOS: They came to you in March right after the raids on Mr. Combs' home?
MS. GERAGOS: Two agents came to your home?
MS. GERAGOS: Then they came to you again after Mr. Combs' arrest in September or October, right?
MS. GERAGOS: And you wanted -- well, in March when they came to your home, did you want anything to do with them at that point?
MS. GERAGOS: And those warrants, to your memory, were those in March of 2024?
MS. GERAGOS: It was about a month after you had gotten back together with Mr. Combs after your break?
MS. GERAGOS: And you had the choice to speak to them if you wanted to, right?
MS. GERAGOS: And you chose not to speak with them, right?
MS. GERAGOS: You chose to get an attorney, and then you and your attorney - I'm not asking about those conversations - made decisions on what to do with the agents at that time, right?
MS. GERAGOS: And at that time, you had gotten back together with Mr. Combs about a month earlier, right?
MS. GERAGOS: And so you knew he was under investigation in March of 2024, and at that time, you had done one more -- it wasn't a hotel night, right, because you said it was at 1 Star Island, but you had done one more night with Mr. Combs, and I think you said it was Don?
MS. COMEY: Objection.
THE COURT: Is there an objection?
MS. COMEY: Objection to the form of the question, your Honor.
THE COURT: Why don't you rephrase your question.
MS. GERAGOS: In February -- I believe you testified yesterday in February of 2024, you had gotten back together with Mr. Combs around your birthday, right?
MS. GERAGOS: And you had done a night with, I believe you testified, Don in February of 2024 at his house in Miami, right?
MS. GERAGOS: And then at that -- and then one month later, in March of 2024 when the warrants were executed at Mr. Combs' homes, you knew at that point he was under investigation, right?
MS. GERAGOS: Okay. And after Mr. Combs' arrest when they subpoenaed you, you went into the grand jury, right?
MS. GERAGOS: And did the government give you immunity?
MS. GERAGOS: And what is your understanding of what a grant of immunity is?
MS. GERAGOS: Is your understanding that they can't prosecute you for any federal crimes if they determine you tell the truth?
MS. GERAGOS: You didn't want the government to prosecute you, obviously, right?
MS. GERAGOS: One of the texts we looked at yesterday, you said that you had regret about some of the choices you made with Mr. Combs. Do you remember looking at that?
MS. GERAGOS: All right. I do have it. We'll get to it later, but I guess I'll change my questions.
You spoke on direct examination about regret, right?
MS. GERAGOS: Because you regret a lot of the choices that you made in your three and a half years of a relationship with him, right?
MS. GERAGOS: And you chose to participate in that lifestyle for many years, right?
JANE: I would say that my choices were made under a lot of emotional pressure due to my relationship.
MS. GERAGOS: Because you were in a relationship with him, right?
MS. GERAGOS: And you wanted to stay in that relationship?
MS. GERAGOS: You loved him very much?
MS. GERAGOS: And you did not want to break up?
MS. GERAGOS: And at times, he would say, "Okay, we could just break up," right?
MS. GERAGOS: He would say to you, "We could just break up," right?
MS. GERAGOS: And then you did not want to break up with him, right?
MS. GERAGOS: There were several times that you didn't talk to him for a few weeks or even a few months, but ultimately you did not want to break up with him?
MS. GERAGOS: And so you feel resentful at this time that you had sex with other men for a long time in your relationship with him, right?
JANE: Yes, I resented the way that he went about introducing me to this lifestyle was built under a lot of emotional manipulation and pressure. Yes, I do resent that about our relationship very much.
MS. GERAGOS: Because you wanted to just be in a relationship with him for three and a half years?
JANE: No. Because I was already so hooked from the beginning, I fell in love with somebody who I didn't understand like the terms and conditions of what our relationship would be like. And so once I was hooked into that and I fell in love, but my emotions were in play so it was many, many blurred lines of love and affection mixed with emotional pressure to perform these things that my lover really desired, and so I wanted to fulfill my duties as a good girlfriend and --
MS. GERAGOS: Because you wanted to be a really good girlfriend and partner. You used the word partner over and over again?
MS. GERAGOS: On direct, you wanted to be a very good partner for him, right?
MS. GERAGOS: And lover for him?
MS. GERAGOS: And you just said you were hooked on the love and affection that you felt from him, right?
MS. GERAGOS: And you kept coming back because you loved his love and affection and the way he treated you, right?
MS. GERAGOS: Right, you came back because you loved his love and affection and your relationship with him?
MS. GERAGOS: And I think on direct examination, you said you're having trouble answering for yourself why you agreed to these nights over and over again, right?
MS. GERAGOS: And these are questions you're trying to answer for yourself now eight months later after his arrest, right?
MS. GERAGOS: And because sometimes, I think you testified on direct, the why was different; at times it could be because not doing these nights meant not being with him, right?
MS. COMEY: Objection to form.
THE COURT: Can you rephrase the question?
MS. GERAGOS: Sure. Of course.
MS. GERAGOS: The why -- you spoke about on direct examination that you're having trouble understanding why even now eight months later, right?
MS. GERAGOS: Why you came back and started doing these nights over and over again, right? You're having trouble understanding why eight months later still, right?
JANE: I struggle with my why, but it's becoming more and more clear as I'm in therapy and as I've had this healthy distance to really assess the situation.
MS. GERAGOS: You're in therapy now?
MS. GERAGOS: And it's becoming clear to you now that you're in therapy, right?
MS. GERAGOS: But as -- but this is something you are trying to understand now, and it wasn't something you could be clear about until you went to therapy, is that right?
MS. GERAGOS: Can you answer my question, which is you're in therapy now eight months later?
MS. COMEY: Your Honor, I'd ask that the witness be able to answer the questions.
THE COURT: That's a fair objection.
So, Ms. Geragos, if you're not getting a responsive answer, you can make an application to the Court, but otherwise the witness should be permitted to complete her answers.
MS. GERAGOS: Understood, your Honor.
MS. GERAGOS: In the end, what you knew, Jane, was that you love Mr. Combs, right?
MS. GERAGOS: And I think you said even two days ago you love him currently, is that right?
MS. GERAGOS: You would have done anything during this time to spend time with him?
MS. GERAGOS: You wanted to be close to your partner?
MS. GERAGOS: You wanted to be close to your lover?
MS. GERAGOS: And you wanted to cuddle with him, does that sound right?
MS. GERAGOS: He liked the foot rubs part of it?
MS. GERAGOS: I think you've told me before that you enjoyed taking care of him after these hotel nights, does that sound right?
MS. COMEY: Objection to counsel making herself a witness, your Honor.
THE COURT: Overruled.
MS. GERAGOS: You liked kind of mothering, you liked taking care of your partner and your lover?
MS. GERAGOS: So after these nights when you guys would be up for a long time, it would be, I think you testified, sometimes 24 to 36 hours, right?
MS. GERAGOS: And then you would go back to his home or you would stay in the hotel, and you loved the time when you guys got to be close and spend that time together, right?
MS. GERAGOS: You loved to hug him and cuddle him?
MS. GERAGOS: And bathe him and give him foot rubs?
MS. GERAGOS: What was his favorite show?
MS. GERAGOS: And you would watch that for hours, right?
MS. GERAGOS: I think you testified that he would take Xanax to fall asleep, right?
MS. GERAGOS: But that you would stay up, and that was your favorite time; you felt very close to him afterwards, right?
MS. GERAGOS: You also said you didn't want him to feel judged. What does that mean?
MS. GERAGOS: Yes.
JANE: In the context of these rooms, I felt that my partner was trusting me in a very vulnerable moment, and, well, so he made me believe that this was something really special; that this was something him and I only did, and I really took that on very strongly, and I really wanted to just go along with these things because I felt like if I can be my partner's escape, then I would be. And I didn't want to judge him for the things I noticed in these rooms about his behavior and the things that he liked, and I just would kind of put blinders on and just go along with what he was telling me to do, but deep down in my heart and from what I could assess in the situation, I mean, I didn't want him to feel that eyes were on him while he was in this vulnerable state.
MS. GERAGOS: So you viewed these rooms when you were there, he was there, and an entertainer as a vulnerable state for him, right?
MS. GERAGOS: And you also said in that answer — because I want to unpack it — that he made you believe he wasn't doing this with anybody else. Is that what you believed?
MS. GERAGOS: Okay. And you -- fair to say you would look at his phone from time to time throughout your relationship?
MS. GERAGOS: His password was easy to break through on his phone?
MS. GERAGOS: So would you look at his messages with other women to see if this was something he did with anybody else?
MS. GERAGOS: So you believed based on looking at his phone and reviewing his messages that he was telling the truth; that this is something within your timeline he was only doing with you, right?
MS. GERAGOS: Okay. So he was trusting only you, out of all of his girlfriends at that time and during this vulnerable time that you guys had together in the hotel rooms, right?
MS. GERAGOS: How did him trusting you make you feel?
MS. GERAGOS: And so you felt really loved by him in those rooms because he was able to be vulnerable with you?
JANE: I felt really loved by him because we experienced these things together and because they were something really special for him. And as time went on, it was very conflicting for me internally because I'm breaking all of my own boundaries just to make him feel extremely loved in these times.
MS. GERAGOS: You've said to the government before that what you needed and what you craved about those nights were the loving things he said to you, do you remember that?
(Continued on next page)
BY MS. GERAGOS:
MS. GERAGOS: What were some of the loving things he said to you that you craved or that you needed from these nights?
JANE: I loved when we would make love and he would say that he was in love with me and that he loved me and he just wanted me and never wanted -- in some instance, like, if I had left or anything, he would say things like he never wanted me to leave. And just so many nice, beautiful, loving things.
MS. GERAGOS: And that was something that brought you -- did you feel that that was something that brought you two together during those nights?
MS. GERAGOS: And what other loving things did you experience that he did during these hotel nights?
MS. GERAGOS: You talked about things he said. Were -- if there were anything, were there things that he did that you enjoyed about these nights?
MS. GERAGOS: The lovemaking between you and him afterwards?
MS. GERAGOS: That was something that you really enjoyed and craved about these nights?
JANE: That was truly the only reason why I endured these nights, so that at the very end I could just have my love and affection with my partner.
MS. GERAGOS: And did you feel during these nights that this is something that really turned him on and made him -- and he really enjoyed?
MS. GERAGOS: And he was very close to you, would you say, afterwards, like, he would be very -- I know you said he was loving; he would say nice things and there would be lovemaking, but would you feel closeness with him as well?
MS. GERAGOS: And is that something you enjoyed also?
MS. GERAGOS: Because you wanted to feel closeness with your lover and your partner?
MS. GERAGOS: And you wanted him to be satisfied, right?
MS. GERAGOS: Did you feel -- if you did, did feel that these nights satisfied him?
MS. GERAGOS: And at the time you started dating him, did you feel that he had a very demanding life, business life, work life?
MS. GERAGOS: What kind of things was he working on for work at the time you started dating him, let's say from 2021 to -- we'll do what Ms. Comey did -- to 2023?
MS. GERAGOS: And tell me about the album.
MS. GERAGOS: Ms. Comey asked you about a term called "off the grid." Was his album also called Off the Grid?
MS. GERAGOS: And called The Love Album?
MS. GERAGOS: And was this something that you observed he was really pouring his heart and soul into?
MS. GERAGOS: And was this his first solo album in a very, very long time?
MS. GERAGOS: And so was he at the studio working on this album a lot?
MS. GERAGOS: Did you join him at the studio sometimes?
MS. GERAGOS: Did you like to see him in that environment?
MS. GERAGOS: Because he was your partner and your lover, and you wanted to be with him and see what excited him?
MS. GERAGOS: So was he working a great deal on this album?
MS. GERAGOS: Is this something that had a pressure on him or a demand on him in any way --
MS. COMEY: Objection.
MS. GERAGOS: -- from your perspective?
THE COURT: That's overruled.
MS. GERAGOS: From what you could tell, was he working on anything else, like, business wise? Was it just the album?
MS. GERAGOS: And did it take him many years, from 2021 to eventually 2023, to complete that album?
MS. GERAGOS: Was he working on it the whole time?
MS. GERAGOS: OK. And then does he eventually release the album in September of 2023?
MS. GERAGOS: And is that the time when you went to New York that we spoke about yesterday, in September of 2023, he launched that album?
MS. GERAGOS: OK. And so did you feel that you were the only person -- I mean I think we talked, he had many girlfriends at the time you were dating him, right?
MS. GERAGOS: Do you feel that he, that you were the only person who he truly liked sexually?
MS. GERAGOS: Did you feel that that brought a closeness between you two because you shared a secret of his nobody else knew?
MS. GERAGOS: And did you feel that he entrusted you with that and you took that seriously?
MS. GERAGOS: And you tried -- tell me if this is right -- to be very sexy for him in those rooms because this is something he liked, right?
MS. GERAGOS: You were very sexy to him, right?
MS. GERAGOS: Because you're beautiful woman, right?
MS. GERAGOS: And he would tell you that?
MS. GERAGOS: And say that -- that's why you would choose a lot of the lingerie you would wear?
MS. GERAGOS: You can tell me, starting from the beginning, would you choose lingerie or did he, or did you learn what he liked and then you started choosing?
JANE: I remember when we were in Turkos and Caicos, it was Valentine's Day, and he led me into a bedroom and he opened the closet and there was an array of outfits and high heels. And so I would say he initiated the tone of the wardrobe of these nights at first, yes.
MS. GERAGOS: OK. So that was the Turkos and Caicos trip you went on in February of 2021?
MS. GERAGOS: And then you started choosing, after that, when he set the tone of what he liked sexually and you said you felt sexy then, right?
MS. GERAGOS: And you were in those rooms to him, right?
MS. GERAGOS: And you started -- it was a mix of him choosing outfits and you choosing outfit, right?
MS. GERAGOS: All right. And you also talked about baby oil. You know that he liked baby oil, right?
MS. GERAGOS: And that was something that you used for him not just in hotel nights but regularly in your sex life, because that was something that turned him on?
MS. GERAGOS: And that was fine with you because you wanted to turn on your partner, right?
MS. GERAGOS: And in these hotel rooms, you could see that it meant a lot to him that you were in there, right?
MS. GERAGOS: This was something that he -- that he really enjoyed, for example, when you spoke dirty to one of the guys?
MS. GERAGOS: And so you said that you, you knew the things that he liked you to say and you would say all of them during these nights, right?
MS. GERAGOS: And so to your mind, you thought he was enjoying it, right?
MS. GERAGOS: And then you also thought that the escort thought, the entertainer thought you really enjoyed it as well, right?
MS. GERAGOS: Because you were voicing, you were very vocal about the things that you were doing and the way that you were performing, right?
JANE: Under these drugs and ecstasy, sometimes I would just fantasy talk and fantasy talk and fantasy -- fantasy talk the whole way through. I can't even recall all the things I would say, but I believed that they enjoyed it, yes.
MS. GERAGOS: And because when you decided to take ecstasy, that was more of like an uninhibited drug when you would get on it, right?
MS. COMEY: Objection to form.
THE COURT: Rephrase.
BY MS. GERAGOS:
MS. GERAGOS: You said that on ecstasy, you would do a lot of fantasy talk, right?
MS. GERAGOS: And Ms. Comey asked you a lot about the ecstasy that you took during these nights, right?
MS. GERAGOS: And that Mr. Combs would have the ecstasy, right?
MS. GERAGOS: And that you chose to take the ecstasy, right?
JANE: My choice to take the ecstasy, I would say that Mr. Combs would offer me the ecstasy and expect me to take it.
MS. GERAGOS: And you would take it, right?
MS. GERAGOS: How old were you at the time that you started your relationship with Mr. Combs?
MS. GERAGOS: OK. And so on ecstasy, you testified that you would feel more uninhibited, right?
MS. GERAGOS: And more sexual?
MS. GERAGOS: And so then you would be able to engage in hours and hours of fantasy talk, right?
MS. GERAGOS: And what kind of talk is that?
MS. GERAGOS: No. What are some examples of the things you would say in these rooms at hotel nights during these three years or three and a half years?
JANE: I would say that Sean really enjoyed setting a tone of a role play, so he would have me and the entertainer have a role play, and then that would cue me to play into that role play.
MS. GERAGOS: What are examples of the role play that he liked that you would play into?
JANE: I would say a lot of cheating role play; that they would be -- that Sean left town and I'm all alone with me and whoever and I'm sneaking in this entertainer and it's just me and this entertainer and I'm just fantasy talking about how Sean's on a plane and I couldn't wait to get this entertainer all alone to myself, etc.
MS. GERAGOS: And even when you were not in these rooms, say just times that you guys were watching porn or having a movie night, would you engage in this same type of role play?
MS. GERAGOS: Yes.
MS. GERAGOS: So role play and fantasy talk is something that would take place even if it was just you and him having sex as well, right?
MS. GERAGOS: All right. And I think you testified that he would kind of give directions during these hotel nights, right?
MS. GERAGOS: And from your perspective, part of what turned Mr. Combs on was that he could kind of also prompt you and the entertainer to do things, right?
JANE: From my perspective, it turned him on because he could prompt what me and the entertainer would do?
MS. GERAGOS: Would he give you directions and would that turn him on?
MS. GERAGOS: OK. Would Mr. Combs give you direction, you and the entertainer, during these nights?
MS. GERAGOS: And did that, from your perspective, excite him?
MS. GERAGOS: And you also then would say things for the entertainer to do, as you just said, during the role plays, right?
MS. GERAGOS: And -- all right. And the high heels, are you somebody who often wears high heels?
MS. GERAGOS: The high heels, these ones were pretty tall, right?
MS. GERAGOS: How many inches?
MS. GERAGOS: But you're somebody who regularly wears high heels in your daily life, right?
JANE: These are a particular kind of high heels, so I would say I would occasionally wear these type of heels, but in real life I would wear things that are about three to four inches, in real life.
MS. GERAGOS: OK, but -- so you're not, you're accustomed to wearing high heels, maybe not these ones, but in your real life, you're accustomed to wearing these high heels outside of these hotel rooms, right?
MS. GERAGOS: Including four-inch ones?
MS. GERAGOS: Maybe not five to seven inch ones?
MS. GERAGOS: You talked about how he liked it when you made arrangements with entertainers, right?
MS. GERAGOS: And so sometimes you did, you made the calls and you made those arrangements because you knew that he liked it, right?
JANE: I knew that there was a undertone of this expectation of me to set up a party or make an arrangement, and so I picked up on that fairly quickly and I would make these arrangements, because the undertone was a expectation.
MS. GERAGOS: Because this was -- I think what you said on direct examination, fairly quickly you learned that this was the tone of your relationship, right?
MS. GERAGOS: Having hotel nights.
MS. GERAGOS: OK. And you knew that when you made arrangements, that that turned Mr. Combs on, right?
MS. GERAGOS: All right. So during this three-and-a-half-year relationship, you guys were never living in the same place, is that right?
MS. GERAGOS: So in the beginning time period, you were living on the East Coast and he was living in Florida?
MS. GERAGOS: And you were living on the East Coast from about, I would say, like, the first half of your -- of 2021, is that right?
MS. GERAGOS: OK. And you would make the choice every time to see him to then get on a plane and come to Miami, right?
MS. GERAGOS: And then you moved to Los Angeles in, I think, you said June of 2021, right?
MS. GERAGOS: And he helped pay your moving expenses to be in Los Angeles, right?
MS. GERAGOS: And you were on the East Coast in 2021 because you wanted your child to be closer to the child's father, right?
MS. GERAGOS: And during that entire time you were on the East Coast, did your child's father see your child at all?
MS. GERAGOS: Why did you move to -- why did you move to Los Angeles?
JANE: I moved to Los Angeles because the purpose of living on the East Coast wasn't being fulfilled. So we moved.
MS. GERAGOS: And Mr. Combs was the one who helped pay for your moving expenses, right?
MS. GERAGOS: Your child's father didn't help you pay for those, right?
MS. GERAGOS: And you wanted to be in Los Angeles to be near family?
MS. GERAGOS: And you were at that point across the country from Mr. Combs, right?
MS. GERAGOS: And you would make the choice over three and a half years every time you went to Miami to get on a plane and to go see him, right?
MS. GERAGOS: And you also then ended up being about 30 minutes away from his house in Los Angeles, so you would see him there as well, right?
MS. GERAGOS: I'm going to talk a little bit about -- I think you said you saw him every week. So would you get on a plane every single week when he was in Miami to go from Los Angeles to Miami?
MS. COMEY: Objection, your Honor. Misstates the testimony.
BY MS. GERAGOS:
MS. GERAGOS: How often would you say you saw him? Once you moved to Los Angeles, how often would you say that you saw him? So let's say May, that would have been June of 2021 to end of 2024 -- we know when you saw him in 2024, so until October of 2023?
JANE: It honestly varied. Sometimes I would see him every week and a half. Sometimes I would see him every couple weeks. Sometimes it would be more than five weeks. And then just -- it would vary.
MS. GERAGOS: You talked about the times that you would take breaks from Mr. Combs on direct examination, and you would say that you would tell him I don't want to do this anymore sometimes and then he would say -- you said he would say -- he would be dismissive. Does that sound right?
MS. COMEY: Objection to form.
THE COURT: Rephrase the question.
BY MS. GERAGOS:
MS. GERAGOS: On direct examination, you talked about the times that you would tell Mr. Combs that you didn't want to do this anymore. Do you remember that?
MS. GERAGOS: Hotel nights anymore.
MS. GERAGOS: And he would say -- you testified that he would be dismissive in response, right?
MS. GERAGOS: And he would say things to you like we can just break up, right?
MS. GERAGOS: And we saw in texts that you would then get back together with him in; one instance it was about two weeks later, right; that was in 2023?
MS. GERAGOS: And that was early in 2023, I should say.
MS. GERAGOS: And another instance it was like two and a half months later, right?
MS. GERAGOS: And in 2024, it was a couple of, about a month later, right?
MS. GERAGOS: And each of those times, it's because you missed him dearly, right?
MS. GERAGOS: He also really missed you?
MS. GERAGOS: And so the reason you got back together is the two of you missed each other as partners?
MS. GERAGOS: And as lovers?
MS. GERAGOS: And it's because you wanted to be with him?
MS. GERAGOS: And so you would get back together with him on your own volition, right?
MS. GERAGOS: Thank you for allowing my water break.
MS. GERAGOS: We listened to a few Voicenotes on direct examination, and I would say, by my count, it was about five, and he was a bit angry in some of those Voicenotes. Do you remember that?
MS. GERAGOS: Fair to say Mr. Combs probably sent you thousands of Voicenotes over your relationship?
MS. GERAGOS: He is somebody who communicated quite often over voice note?
MS. GERAGOS: And we just listened to a very, very small sample of the total Voicenotes that he sent to you over the course of your relationship, right?
MS. GERAGOS: Can you please tell me -- I know you talked about -- I know you talked about this a little bit on direct, but you said that you fell in love with him because he was this larger-than-life, charismatic personality. Can you explain what it is? Why did you feel he was a larger-than-life, charismatic personality?
JANE: He was very confident and strong and very boisterous and very sure of him, very righteous, and just beamed, beamed a very bright light when I met him.
MS. GERAGOS: And that bright light was something that you loved being around, right?
MS. GERAGOS: Can you explain that a little bit more? What were you fascinated by and why did you like it?
JANE: He was just something unique and different. Like, I had never met anybody with such a big personality and very big energy and very motivating, encouraging and just larger than life. He wasn't afraid to just have his voice heard, and it was attractive.
MS. GERAGOS: What about him was motivating to you?
JANE: I believe that he wanted you to believe in yourself. He was a really good motivator and had really good motivational speeches, pushed you to be your best and really had a lot of great leadership skills.
MS. GERAGOS: How did he push you to be your best?
JANE: I would say with me, I think that when he first met me, I probably was a lot shier than I am now, and he just, you know, told me that I was -- I don't know, just saw the good in me, and I appreciated that.
MS. GERAGOS: Do you remember saying that he was strong and unafraid and saw you for you?
MS. GERAGOS: Can you explain what you mean by saw you for you?
JANE: I would say that -- I would say that -- it's something I can't really describe. It's like he just would -- I don't know -- just be encouraging, like he would just bring me up and bring everything about me up. He would uplift me.
MS. GERAGOS: In what ways would he uplift you?
MS. GERAGOS: Did you feel stronger being with him?
MS. GERAGOS: Did you struggle, maybe, with self-esteem issues beforehand?
MS. GERAGOS: And then being with him you felt stronger and more confident?
MS. GERAGOS: Because he exuded confidence to you as well, right?
MS. GERAGOS: And what other positives would you say came from your relationship with him?
JANE: Just giving me different perspective on life and introducing me to gospel, and we would have really insightful conversations, just various topics. And he had really good perspective on a lot of things.
MS. GERAGOS: So you guys would also engage in very deep conversations with one another, right?
MS. GERAGOS: So it was not just -- your relationship essentially was not just hotel nights; you were able to speak with him?
MS. GERAGOS: And you enjoyed listening to his perspective on different issues, right?
MS. GERAGOS: And you were able to open up with him in a way you weren't able to with other people, right?
MS. GERAGOS: He introduced you to gospel. Can you explain that?
JANE: Yeah, sure. He had a favorite pastor, and he would often put a lot of sermons on the television and we would watch it together and we would talk about it. And he would send me sermons and I would start sending him sermons and I would watch them on my own and gospel music and things like that.
MS. GERAGOS: Was that something that has stayed with you even in the months since his arrest?
MS. GERAGOS: And is that something that was a positive from your relationship with him?
MS. GERAGOS: And has -- do you still watch that same pastor today?
MS. COMEY: Objection, your Honor.
THE COURT: Sustained.
BY MS. GERAGOS:
MS. GERAGOS: You said that he gave you a different perspective on life. Can you explain that?
JANE: It's not really something completely concise, just that -- I would just listen to him and just gain different perspective and insights in general. It could be about people. It can be about life, family, children.
MS. GERAGOS: And talk to me about family. What about family did -- what perspective did you gain about family from him?
MS. COMEY: Objection.
THE COURT: Sustained.
BY MS. GERAGOS:
MS. GERAGOS: What about -- All right. I'll just move on. You said that he was strong and encouraging and motivating, and on direct examination you talked about how when you first met him you were a content creator and an influencer on Instagram, right?
MS. GERAGOS: And was he -- I don't think you spoke about this. Did you also have two businesses during your relationship with him, with a swimwear line?
MS. GERAGOS: And you had a dress line?
MS. GERAGOS: And he was encouraging of those as well, right?
MS. GERAGOS: And did he invest money into those businesses for you?
MS. GERAGOS: How much money did he invest in the dress line?
MS. GERAGOS: And how long was your dress line in business for?
MS. GERAGOS: And so you worked on the dress line during your relationship with Mr. Combs?
MS. GERAGOS: And was he encouraging of that business?
MS. GERAGOS: And so much so that he invested $20,000 into it?
MS. GERAGOS: And is that something that you found motivating from him, that he was encouraging of your entrepreneurial ways?
MS. GERAGOS: And so when you said on direct examination that you weren't able to put all the time into your work as a content creator and an influencer, you were also doing other work, right?
JANE: I would say that in the time that I could focus, I was able to focus and just launch something, yes. But I still had a lot of fog during that time.
MS. GERAGOS: And in your dress line, what was, like, the purpose behind your dress line? Is there -- is it just dresses for women? Is there a tag line for it? Tell me about the dress line.
MS. COMEY: Objection.
THE COURT: Overruled.
MS. GERAGOS: OK. And so did your work shift from content creation to apparel?
JANE: I believe that I dabbled into apparel, and then as far as content creating, that was kind of hard to upkeep because it needed my presence, and a lot of my presence were focused on Combs and my child and I definitely, probably scratched, maybe, 10 percent of my potential during those three years.
MS. GERAGOS: OK. You just testified that there were times that you wouldn't fly and see him for months, right?
MS. COMEY: Objection.
THE COURT: That's overruled.
JANE: Sometimes, yes, we could go, like, a couple -- like six weeks or so without seeing each other.
MS. GERAGOS: OK. And he was, Mr. Combs was in the apparel industry, right; he had launched a clothing line? You knew that?
MS. GERAGOS: If you don't know, no problem.
MS. GERAGOS: All right. When you first met him, you had -- you said you had minimal income from the influencer side of things, is that right?
MS. GERAGOS: How much would you say were you generating per month from the influencer business?
JANE: I would say when I was really active on Instagram, if I were to book maybe two brands, that would be about 50,000 or so. And then it just depended how many brands I was able to commit to.
MS. GERAGOS: OK. And you also received child support at the time, right?
MS. GERAGOS: How much was that per month?
MS. GERAGOS: And but you were living within your means, right?
MS. GERAGOS: You were paying your own rent?
MS. GERAGOS: Between 20 -- when you met him in January -- let's say November of 2020 and April of 2023, you were responsible for paying your own rent, right?
MS. GERAGOS: And you worked in order to pay that rent, right?
MS. GERAGOS: And Ms. Comey asked you whether you had a conversation with Mr. Combs about wanting to make your own money in the beginning, right?
MS. GERAGOS: Ms. Comey asked you on direct examination whether you had a conversation with Mr. Combs when you started dating him about wanting to make your own money, right?
MS. GERAGOS: OK. So when she asked you about making your own money, it was specific -- you understood that question was specific to OnlyFans?
MS. GERAGOS: Because you were already making money on the Instagram side of things, right?
MS. GERAGOS: And you said that Mr. Combs, when you spoke to him about OnlyFans, he would kind of brush it off or he would say we'll talk about it or we can talk about that later, right?
MS. GERAGOS: What was your understanding of why he may not have wanted you on OnlyFans during that time of your relationship?
JANE: My understanding was he just didn't want, maybe, to be -- didn't want me to be a part of something that was, maybe, frowned upon.
MS. GERAGOS: And then you eventually joined OnlyFans again in 20 -- not again, in 2024, right?
JANE: My decision to -- my decision to join the website was, truthfully, because it was just something that I needed. It was -- if I could get off that website, I would.
MS. GERAGOS: You needed it financially?
MS. GERAGOS: And he didn't stop you from joining it in 2024, right?
MS. GERAGOS: You independently made that choice outside of him, right?
MS. GERAGOS: And he saw how lucrative it was and he was proud of you, right?
MS. GERAGOS: And when you spoke to, on direct examination, to Ms. Comey about making your own income, you said that you didn't need his permission to get your own income, but you wanted his approval. Do you remember that?
MS. GERAGOS: Sure. Do you remember testifying on direct examination, when Ms. Comey asked you why did you need Sean's permission to get your own income, you answering that in my heart he was my boyfriend and I wanted his approval, right?
MS. GERAGOS: And that was solely about OnlyFans, right?
MS. GERAGOS: Because he was -- he was helping you in these other ventures, like your dress line, right?
MS. GERAGOS: OK. So he never explicitly told you that you needed to get his permission to earn your own income, right?
MS. GERAGOS: Because --
MS. GERAGOS: -- in your heart, he was your boyfriend and because of OnlyFans specifically you wanted his approval?
MS. GERAGOS: Because OnlyFans comes with it implied nudity, you said, and bikini and lingerie photos, right?
MS. GERAGOS: OK. And in addition to the $20,000 he gave you for the dress line, he also gave you money sporadically throughout your relationship, right?
MS. GERAGOS: And most of the time you didn't have to ask for any of that money, right?
MS. GERAGOS: And he would just send you a wire or give you cash or just because, right?
MS. GERAGOS: And you were really grateful for that, right?
MS. GERAGOS: Do you think over -- does it sound right that over the three, three and a half years of your relationship, he wired you over $150,000?
MS. GERAGOS: And you've told the government previously that you've always gravitated towards providers. Do you remember telling them that?
MS. GERAGOS: Can you explain that?
JANE: Yes, I do find men who are successful, attractive. As a woman, my ideal partner is a protecter and a provider.
MS. GERAGOS: And you found that attractive in Mr. Combs?
MS. GERAGOS: And you testified a lot about the house, which you signed a lease in 2023. Do you remember?
MS. GERAGOS: And I noticed on direct examination that you referred to it as our house and our residence. Do you remember that?
JANE: Yes, there was always -- Sean would say it was our house, and then we would say it was our house. Sometimes I would say my house. I don't know. It would be a mix.
MS. GERAGOS: Did you view it as your house or our house? How do you view it?
JANE: When we first got it, I would say our house. And then as time went on, it's, like, my house.
MS. GERAGOS: Did you envision it at the beginning as a house for you both?
JANE: Yes. The way that I was speaking about the house was that I wanted to get something bigger and also I wanted to be up to Sean's taste level as well. And I knew that at this point in our relationship, we had just done so many hotels and privacy was starting to become just an issue for me, and I figured, in my mind, if we got a home that was to his taste level, that we could just start at least doing them here in the privacy of our own home.
MS. GERAGOS: OK. So just so I understand that, when you -- your thought process at the time you got the -- you signed the lease in April, started in April of 2023, right?
MS. GERAGOS: So at that point it had been nearly two years since your first hotel night, right?
MS. GERAGOS: And privacy was becoming an issue, right?
MS. GERAGOS: Both of you wanted -- did not want anything about the hotel nights to leak in any way, right?
MS. GERAGOS: This was something that was very private behavior, right?
MS. GERAGOS: These were very private nights?
MS. GERAGOS: And it was important that his security didn't know about these nights?
MS. COMEY: Objection, your Honor.
BY MS. GERAGOS:
MS. GERAGOS: From your perspective, it was important that none of his employees knew about the entertainers at these nights, right?
MS. GERAGOS: And it was important that none of the general public knew about these nights, right?
MS. GERAGOS: And that was from your perspective, right?
MS. GERAGOS: And you understood that that was also from his perspective, right?
MS. GERAGOS: OK. So in March or April of 2023, part of the thinking behind getting a very nice home was that you guys could shift it from hotels to the home, right?
MS. GERAGOS: OK. And that was nearly two years after you started the hotel nights?
MS. GERAGOS: OK. You had every intention of, if you were going to do these nights you would have them at that home instead?
MS. GERAGOS: OK. And when you said you wanted something, you wanted something, I think, you said for you and your XXXXXXXXXX -- or your child, that was large, had a big yard, right?
MS. GERAGOS: I corrected myself. Of course. For you and your child, you wanted a big yard, right?
MS. GERAGOS: And you wanted a big home?
MS. GERAGOS: And so you wanted something for your child, but you also wanted something up to Mr. Combs's taste levels?
MS. GERAGOS: And explain what that means, his taste levels.
JANE: I would say that Mr. Combs had really nice properties that were always decorated well and very manicured, and I wanted to pick a home that was a home away from home; that if he would visit me he would still feel like he was at home, to his taste level.
MS. GERAGOS: And you had nights -- before you moved into that home, you had nights at your previous apartment with him as well, though, right?
MS. GERAGOS: He would come to that home and you guys would have entertainers there?
MS. GERAGOS: OK. I would like you to, and if we could pull it up for the parties but it's also in your binder at tab 3, I think, 3103, defense exhibit. If you could look at it and --
MS. GERAGOS: Well, you have two options. Really, whatever you prefer. There's one in the binder. There's one on the screen. If you could just look at it and read it over very quickly.
MS. GERAGOS: Have you read it over?
MS. GERAGOS: OK. What is this, generally? Is this a message between you and Mr. Combs?
MS. GERAGOS: OK. And is it dated March 25, 2023?
MS. GERAGOS: All right. We move this into evidence, your Honor.
MS. COMEY: No objection.
THE COURT: 3103 will be admitted.
(Defendant's Exhibit 3103 received in evidence)
MS. GERAGOS: This is dated -- can we publish it for the jury?
Can we do pages 1 and 2 side by side.
MS. GERAGOS: Is this dated March 25, 2023?
MS. GERAGOS: Is this after the Turkos and Caicos trip that you and Mr. Combs went on?
MS. GERAGOS: All right. And here, you had, if you look on page 2, you say: You're taking off, you have no idea how torn I am right now. I know I could have powered back up, but also I didn't want you to be distracted. I love you so, so, so, so much. Right?
MS. GERAGOS: OK. And so this was your leaving Miami after your Turkos and Caicos trip and you were flying back home to Los Angeles, right?
MS. GERAGOS: OK. So if we could now play the voice note at -- we'll go to the next page, No. 3. All right. So then we'll have No. 2 and No. 3 side by side, if we could.
All right. If we could play the voice note.
First, your Honor, we seek, with the government's consent, to admit 3103A, which is this first voice note on page 2.
MS. COMEY: No objection.
MS. GERAGOS: If we could play 3103A; this is Mr. Combs's response to your message saying taking off.
(Media played)
MS. GERAGOS: All right. You can turn that off now. Thank you so much.
MS. GERAGOS: All right. What is get in your bag?
JANE: Get in your bag means just stay focused on what you're doing and just, like, elevating yourself and don't get out of that space.
MS. GERAGOS: And then he says you got your contract, right?
MS. GERAGOS: So is this a voice mail where it's after the love contract that you talked about after Turkos and Caicos and Miami?
MS. GERAGOS: All right. And you respond with some emojis, you see with the crying-laughter face and the kissing face?
MS. GERAGOS: And you said: Baby, you make me laugh, LOL. The addiction is real. I really had to get to this point to stop honestly. Fuck or die trying -- apologies -- nothing's going to stop me or us. What do you mean by that? Is that in response to the crack pipe comment?
JANE: No. This was, this was a quote from him the night before, where he says I'm going to fuck or die trying and I think either him or me say nothing's going to stop us or nothing's going to stop me.
MS. GERAGOS: OK. Now, what -- to your knowledge, what was he saying you're the crack pipe? He had an addiction to you, is that what you understood?
MS. GERAGOS: OK. And then at the end, he says you got your contract, and this is, again, after the Miami and Turkos and Caicos trip, right?
MS. GERAGOS: OK. So can we play -- with the government's consent, we're going to admit Defendant's Exhibit 3103B, which is on the right-hand side, the audio message from you at the top at 6:51 p.m.
MS. COMEY: No objection.
THE COURT: All right. 3103A and B will be admitted.
(Defendants' Exhibits 3103-A received in evidence)
(Defendant's Exhibit 3103-B, sealed, received in evidence)
(Media played)
BY MS. GERAGOS:
MS. GERAGOS: At the end of that voice note, you're saying yay to your contract, that refers to the love contract?
MS. GERAGOS: And this is after Turks, and you're saying that you had so, so, so much fun, right?
MS. GERAGOS: And you told him that, right?
MS. GERAGOS: And you told him that you felt closer to him on another level, right?
MS. GERAGOS: And, and that you were then going to, he told you get in your bag and you said you're going to focus on your health and wellness for the week, right?
MS. GERAGOS: All right. And then you respond to him; you sent another message and said: Can't get enough of your love, baby. Is that in response to the song that's in the background playing?
MS. GERAGOS: You're saying: I'm a lucky girl, super happy and all smiles, listen to my voice mail when you can, right?
MS. GERAGOS: And are these two examples of Voicenotes that you and Mr. Combs would send you?
MS. GERAGOS: I asked you earlier if he would send you a lot of Voicenotes, and this is an example of one?
MS. GERAGOS: And this is right after you guys spent -- you went to Miami, right?
MS. GERAGOS: And then you went to Turkos and Caicos for many days?
MS. GERAGOS: And then you went to Miami again?
MS. GERAGOS: And all three of those trips, there were entertainers there, right?
MS. GERAGOS: But you're telling him in these messages on March 25 I had so, so, so much fun, I feel closer to you on another level, right?
JANE: Yes. The fact that I could parcel out those moments with Sean, those moments made me very happy, yes.
MS. GERAGOS: And you've been pretty clear on that, right; that you loved spending time with him? Right?
MS. GERAGOS: But in this voice mail that we just listened to, after this Turks and both Miami trips, you're saying I feel closer to you, I had so, so, so much fun, right?
MS. GERAGOS: And that you had fun?
MS. GERAGOS: And you feel close to him on another level, right?
MS. GERAGOS: All right. Could we go to 3110. That should be behind, I think, 10, tab 10 of your binder and if it's not, let me know.
MS. GERAGOS: OK. Great. Of course. And it's also on the screen. You can put both pages up.
MS. GERAGOS: And if you could just take a look at it, tell me if you recognize it, and when you're done reading it, just let me know.
MS. GERAGOS: Your Honor, while she's doing that, I realize that I didn't offer 3103 under seal. I just wanted to make the record clear that I'm offering those under seal.
THE COURT: All right. 3103 will be admitted under seal.
MS. GERAGOS: 3103A, I believe, can be under seal but 3103B, I believe, would be.
Is that right, Ms. Comey?
MS. COMEY: Yes. And thank you, Ms. Geragos. I had also forgotten.
THE COURT: All right. 3103B will be admitted under seal as well.
BY MS. GERAGOS:
MS. GERAGOS: Have you had a chance to look at the exhibit?
MS. GERAGOS: Yes. All of the pages.
MS. GERAGOS: OK. Do you recognize this as a message between you and Mr. Combs on April 4 of 2023?
MS. GERAGOS: Your Honor, we offer this under -- we offer this under seal, and we will offer a redacted one later.
MS. COMEY: No objection.
THE COURT: All right. 3110 will be admitted under seal.
(Defendant's Exhibit 3110, sealed, received in evidence)
MS. GERAGOS: OK. Publish this for the jury.
Let's turn, have both pages side by side. Let's go to pages 3 and 4. All right.
MS. GERAGOS: Are these messages -- are you sending Mr. Combs messages of the home that you had identified that you wanted to move into?
MS. GERAGOS: And so on the left here --
MS. GERAGOS: If we could zoom in to both of these photos.
MS. GERAGOS: -- is this the master bath on the left?
MS. GERAGOS: All right. And then the outside, is that on the right-hand side?
MS. GERAGOS: And that's a patio area that leads out into the yard?
MS. GERAGOS: All right. If you can go to the next two pages.
All right. If we could zoom in on those two photos, please.
MS. GERAGOS: It's a little bit blurry, but this was the large -- the kitchen and the family room?
MS. GERAGOS: OK. If we could take -- unzoom, I guess, would be the word. All right. If we go to the next page.
MS. GERAGOS: All right. So then if you look at page 7, you write, and I'll read this part: I know it's big but LOL, for everything I'm looking for for our time, family time, safety, privacy and school district, this is the perfect place. And you say where it is. You say where the location is And you say: On a good day from Mapleton, it's a 25 to 30-minute commute. Mapleton is his home in Bel Air?
MS. GERAGOS: All right. And when you talk about here, you say, for our time, is that part of what -- time together, right?
MS. GERAGOS: And part of what you said was times that you would have entertainers over, right?
MS. GERAGOS: Safety, because that was important, right?
MS. GERAGOS: Privacy was important, of the utmost importance to him and to you, right?
MS. GERAGOS: And school district for your child, right?
MS. GERAGOS: OK. So for privacy, I think you mentioned on direct, but I want to make it clear, this is a gated community, right?
MS. GERAGOS: In order for anybody to get through, they had to go through, like, a guard essentially?
MS. GERAGOS: And nobody could just go into your home?
MS. GERAGOS: OK. If we could zoom out.
MS. GERAGOS: And it was important that you were somewhat close to Mr. Combs's home in Los Angeles, right?
MS. GERAGOS: And you say: It's four bedrooms and four and a half bath. It's a brand-new home. The landscaping's waiting approval and this one is going -- skipping ahead -- for $10,000 per month?
MS. GERAGOS: OK. And on the bottom text on the left there, you say: So I got approved, yay. So now they need a first and last month's rent and two months of security deposit, totaling for the first month 10K, last month's 10K, security deposit of 20K, total of 40K, the place is ready for move-in by April 15, right?
MS. GERAGOS: So in order -- do you know that in order to move into your apartment, did it cost $40,000?
MS. GERAGOS: OK. So if, and we can unzoom, and then if we could to, skip ahead to page 8, to the bottom text there.
MS. GERAGOS: You say: Let me know what you think of the backyard. It's your place too. I want you to be happy wherever, whenever you're in it, so if you have any suggestions for them in the backyard. I told my realtor once I speak to you I'll email him concerning the payment to lock it in. Thank you so, so, so, so, so much, baby. You have no idea how much this means. I'm beyond grateful for you, and I thank God for you. Right?
MS. GERAGOS: There are some emojis next to that?
MS. GERAGOS: OK. So if you unzoom on that one.
MS. GERAGOS: So when you moved into your apartment -- your house, there was first month already paid for, right?
MS. GERAGOS: Last month is already paid for, right?
MS. GERAGOS: And then the security deposit is two full months' rent, right?
MS. GERAGOS: All right. So -- and this rent was, as you said, always been paid on time, right?
MS. GERAGOS: And he ensured with Robin, his accountant, that that rent gets paid on whatever day of every month it has to get paid, right?
MS. GERAGOS: And that has never stopped, right?
MS. GERAGOS: OK. And even if the rent had not been paid, you would have last month's rent already paid, right?
MS. GERAGOS: And the two months' security deposit that was with the landlord, right?
MS. GERAGOS: So that totals about three months of rent that would be -- that was in the landlord's possession if, for some reason, he stopped paying the rent?
MS. GERAGOS: OK. And then you testified, it may have been --
MS. GERAGOS: We can take it down now. Thank you.
MS. GERAGOS: You testified, it may have been yesterday, but I'm losing my track of days, frankly, that he offered, that he said at one point when you were going to break up that he would then pay three months of rent. Do you remember that?
MS. GERAGOS: OK. So at that time when he had said that he would pay three months of rent, it would be three months of rent plus the three months of rent that the landlord also already had, right?
MS. GERAGOS: OK. And in that moment, I think you testified that you felt frustrated, right?
MS. GERAGOS: Yes.
MS. GERAGOS: And -- all right. And at the end of the day, you never actually believed that he would withhold the rent from you, right?
JANE: There were some times that I definitely felt that he would do that. And he used it kind of as a, as a little tool. The rent was always just like a reminder.
MS. GERAGOS: Well, what he said was we could discuss three more months, right; that's what we looked at?
MS. GERAGOS: OK.
MS. GERAGOS: And do you remember saying to the government that when he would use it as a tool, that you would then say to him I'm not Cassie and I could make your life hell?
MS. COMEY: Objection. Could we get a time frame to when she said that?
MS. GERAGOS: Can we pull up, Mr. McLeod, 3502-24, page 11.
MS. COMEY: Your Honor, I don't think there's a basis --
THE COURT: Hold on. Hold on. Take a step back.
MS. GERAGOS: Let me take a step back, and I'll rephrase.
MS. GERAGOS: Do you remember saying to the government that when he would use the rent as a tool, that you would tell him I'm not Cassie and I could make your life hell?
JANE: There was only one argument that we had towards the end when I had hit my wall and I was depressed over these nights and we got on the phone. He was consoling me, and then he smoothly inserted that, so, what, do you need three more months' rent? And that infuriated me because it didn't feel genuine, the previous talk of consoling me, etc. And then we had some really nasty text exchanges. And so in this one instance, I did bring up his ex and say I'm not either of your exes.
MS. GERAGOS: OK. So, and this was the phone conversation that we spoke about yesterday?
JANE: The phone conversation detailed the consoling and then the -- the threat about rent. And then the text messages is what you guys have --
MS. GERAGOS: OK.
MS. GERAGOS: So you guys were in an argument and he was consoling you, right?
MS. GERAGOS: On the phone call.
MS. GERAGOS: And then after he was consoling you, that's when he brought up the three more months of rent, and that made you really upset, right?
MS. GERAGOS: And then that's when you said I'm not either one of your exes and you fought back to him, right?
MS. GERAGOS: All right. Now, after you got the house, he sent you, I think, you said a random wire of $20,000, right?
MS. GERAGOS: And that's because you needed furniture for the home?
MS. GERAGOS: And obviously it was going to cost a lot of money to furnish?
MS. GERAGOS: And were you grateful for that $20,000?
MS. GERAGOS: And you wanted to use that money to get furniture that was up to his taste level?
MS. GERAGOS: And we looked at some photos of the house yesterday, and you got really nice furniture for the home, right?
MS. GERAGOS: And some of that you paid for?
MS. GERAGOS: And some of it he paid for, right?
MS. GERAGOS: All right. I want to go back to the beginning of your relationship with Mr. Combs that you testified about, and you talked about going to his house in November of 2020 with your friend who had been seeing him, right?
MS. GERAGOS: And she had been seeing him for a couple of years, right?
MS. GERAGOS: She was one of many, you would say, right?
MS. GERAGOS: And I think you said she wasn't engaged at the time, but she was seeing somebody else, right?
MS. GERAGOS: And she had been seeing him then -- seeing him as well as Mr. Combs, right?
MS. GERAGOS: And so you said you felt a little bit hesitant when he was trying to flirt with you?
MS. GERAGOS: Because you knew your friend had strong feelings for him, right?
MS. GERAGOS: And they had been seeing each other, she had had feelings for him for two years, right?
MS. GERAGOS: And you also knew that there were a lot of other things that made you conflicted about this, for example, the person that was really close to him that you had a relationship with, right?
MS. GERAGOS: And then you also talked about how he and your child's father also did not get along, right?
MS. GERAGOS: And so when you did start your relationship with Mr. Combs, privacy, as you've said, was of the utmost importance, right?
MS. GERAGOS: It was important that your relationship was essentially on the down-low, right?
MS. GERAGOS: OK. So can we pull up for the witness and the parties only Defense Exhibit 3003.
And Jane, this is behind tab 3 of your binder. And this is a short exhibit, but if you could review it.
And can we just show page 1, please, only. Thank you.
MS. GERAGOS: And just let me know when you're done reviewing it.
MS. GERAGOS: OK. So is this a message between you and Ms. Khorram?
MS. GERAGOS: And from April 9 of 2021?
MS. GERAGOS: All right. We offer this under seal, your Honor, I believe, without objection.
MS. COMEY: No objection to it coming in under seal, your Honor.
THE COURT: Defense Exhibit 3003 will be admitted under seal.
(Defendant's Exhibit 3003, sealed, received in evidence)
(Continued on next page)
MS. GERAGOS: You can show this to the jury.
MS. GERAGOS: So this is about four months after your relationship starts with Mr. Combs, right?
MS. GERAGOS: And you say to Ms. Khorram, KK we got papped, right?
MS. GERAGOS: And were you concerned at that time because nobody really knew you were in a relationship together?
MS. GERAGOS: It was important for you guys that it essentially stayed on the down low because of many different reasons, right?
MS. GERAGOS: Okay. And you say to KK, can you have him call me, please. I don't know what to do.
MS. GERAGOS: And KK says, When? Where? Right?
MS. GERAGOS: And then you link to a website about where you guys got papped, which means paparazzi, right?
MS. GERAGOS: Can we please go to page 3 of the exhibit. And you say, I'm shaking, right?
MS. GERAGOS: Because you were worried you didn't want to be out there in the open. You didn't want it to be public at the time, right?
MS. GERAGOS: And KK responds, I showed him there are other people in the pictures that helps-ish. He said, Don't panic he has friends that come over to his house all the time, right?
MS. GERAGOS: And so you wanted at this point -- at this point, did your friend know that you were in a relationship with him?
MS. GERAGOS: And your child's father didn't know either, right?
MS. GERAGOS: And the person close to Mr. Combs didn't know either, right?
MS. GERAGOS: So it was important then that you keep your relationship private at the time, right?
MS. GERAGOS: When you flew to -- when you were in Miami that trip, you talked about how one of the friends that you were with wanted some drugs, and you weren't sure what those were, but you went with Mr. Combs to, I think you said, the studio or guest house for him to get those, right?
MS. GERAGOS: So you knew even in November or December of 2020 that he would purchase those drugs, right?
MS. GERAGOS: And then you asked is it safe, right?
MS. GERAGOS: And he kind of laughed, you said, right?
MS. GERAGOS: All right. And so you also testified that during that trip you were drawn to him instantly. Do you remember that?
MS. GERAGOS: You found that he was really hospitable?
MS. GERAGOS: What kind of things did he do on that trip for all of you that you thought was really hospitable?
MS. GERAGOS: So there was a yacht for all of you?
MS. GERAGOS: It came to the dock at 2 Star Island?
MS. GERAGOS: And that was really fun?
MS. GERAGOS: And you found -- and he was with you guys on the yacht or was it just you and the girls?
MS. GERAGOS: So you thought he was really nice and really funny and really hospitable?
MS. GERAGOS: And then you guys started flirting with each other after that?
MS. GERAGOS: Can we pull up what's already in evidence as A-906, and go to page 11.
MS. GERAGOS: And you say to him -- this is December 1, 2020, is that right?
MS. GERAGOS: You say, LOL, we had so much fun. And at some points I felt like I couldn't be myself. I didn't want to step on anyone's toes. Just in case you felt I was a little off but just know the vibes were really great and you were a gentleman and your energy is addicting. I'm happy I got to see this side of you. I had a lot of fun celebrating you, love and I hope you did too, right?
MS. GERAGOS: What was addicting about that trip or what about his energy was addicting?
MS. GERAGOS: If we go to page 17 of this exhibit. You could put it side by side with 18, if it's easy.
MS. GERAGOS: Then he starts telling you, this is on the 7th, come to Miami this weekend, right?
MS. GERAGOS: And so pretty soon after you first saw him, he's inviting you down there, right?
MS. GERAGOS: Okay. And so you can take this down.
MS. GERAGOS: You go -- you go to Miami for a baby shower, right, maybe a month later?
MS. GERAGOS: An event, okay.
MS. GERAGOS: And I may have made that up. I don't know where I got that.
And you -- he got you a hotel that trip?
MS. GERAGOS: Okay. And you ended up staying for about five days?
MS. GERAGOS: And that was a really, really fun trip, right?
MS. GERAGOS: Did you fall in love with him on that trip?
MS. GERAGOS: Okay. And you've told the government in the past that he seemed pretty excited but also a little bit nervous on that trip, right?
MS. GERAGOS: Why did you perceive him as being a little bit nervous?
JANE: Well, later on he told me that because we had our first initial big night, and then the next day he wanted to have more of a calm dinner, and he was telling me that he was just so excited to finally have this like time and date time with me that he had overdone it with drugs and stuff; that he came in with like all this energy, and he felt like he kind of ruined it. But I was -- I was okay, I was okay with his energy, and so that's where I kind of now -- after he revealed that, then I could see why he was -- seemed a little nervous-y in the beginning.
MS. GERAGOS: Your Honor, could we have a quick sidebar?
THE COURT: You may.
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(At the sidebar)
MS. GERAGOS: We have cough drops.
THE COURT: We're checking on it right now.
MS. COMEY: Just so the record is clear, there is a juror who is coughing. We've given the deputy a bottle of water. We've offered cough drops.
THE COURT: The deputy is up there right now. He's talking to her.
MS. GERAGOS: We would take a break if she needs one. That's all I wanted to say because there was a lot of coughing.
THE COURT: Fair.
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